Guidance on registration

Summary

This is ODPA guidance explaining the annual registration obligation under The Data Protection (Bailiwick of Guernsey) Law, 2017. It sets out who must register, how registration fees are calculated, and how various categories of entity (landlords, companies, branches, administrators, sole traders) should treat their registration duty. It also answers common questions on processing, personal data, special category data, and the domestic purposes exemption.

• Who must register: Any controller or processor 'established in the Bailiwick' of Guernsey that processes personal data for purposes other than personal/household affairs must register annually with the ODPA or pay via a Levy Collection Agent.
• 2026 levy rates: Annual levy of 2,488.80 pounds for organisations with 50+ FTE staff; 62.22 pounds for organisations/administered entities with 0-49 FTE staff; 0 pounds for charities and not-for-profit organisations.
• Companies: Companies are almost always required to register, including dormant, non-trading, asset-holding or personal investment companies; the only exemption is where all directors are corporate directors and no other processing occurs.
• Branches and parent organisations: A parent organisation with an office, branch or regular practice in the Bailiwick is established there and must register; a Bailiwick-based branch that is itself a controller or processor must maintain its own separate registration.
• Non-Bailiwick entities using Bailiwick processors: A non-Bailiwick controller or processor that uses a Bailiwick-based processor (e.g. for company administration, payroll, IT support) is also treated as established in the Bailiwick and must register.
• Companies in closure or dormancy: Companies in liquidation, administration, being struck off, or dormant/non-trading businesses must maintain registration while they still hold or process personal data (e.g. a Directors' Register or retained client data).
• Updating or cancelling registration: Registered controllers and processors must notify the ODPA of changes to their registration within 28 days, though doing so sooner is encouraged.
• FTE calculation: Registration fee tier is based on total full-time-equivalent employees of the entity worldwide, not just those located in the Bailiwick, using the Schedule 1D definition of full-time employee.

The guidance also clarifies exemptions (domestic/household use of data) and points specific sectors, such as landlords, sole traders, NEDs, fund/company administrators and fiduciaries' administered entities, to further detailed guidance notes for their circumstances.

Key obligations

• Entities established in the Bailiwick of Guernsey that process personal data outside domestic/household purposes must maintain an annual registration with the ODPA or pay the levy through a Levy Collection Agent.
• Registered controllers and processors must notify the ODPA of any changes to their registration details within 28 days.
• Organisations must pay the applicable annual registration levy based on their full-time-equivalent staff count (worldwide), except charities and not-for-profit organisations which pay nothing.
• Companies established in the Bailiwick must register unless all directors are corporate directors and no other personal data processing occurs.
• Bailiwick-based branches that are themselves controllers or processors must maintain their own separate registration in addition to any parent organisation registration.
• Non-Bailiwick controllers or processors using a Bailiwick-based processor must also register with the ODPA.
• Companies or businesses in closure, liquidation, or dormancy must maintain registration for as long as they continue to hold or process personal data.

Applies to

controllers, processors, landlords, sole traders, small businesses, companies, charities and not-for-profit organisations, branches of parent organisations, non-Bailiwick based organisations using Bailiwick-based processors, administrators and administered entities, fiduciaries' administered entities, Levy Collection Agents, non-executive directors in the finance industry

Deadlines

• 28 days: Registered controllers and processors must notify the ODPA of any changes to their registration within 28 days of the change.
• January 2026: Updated registration levy rates (2,488.80 pounds, 62.22 pounds, or 0 pounds depending on entity size/type) take effect.