The President of the Personal Data Protection Office asks the President of the Republic of Poland to support solutions protecting Internet users

The President of the Personal Data Protection Office (UODO), Mirosław Wróblewski, has appealed to the President of the Republic of Poland to support solutions aimed at more effective protection of Internet users, in particular children and young people, against the unlawful use of their image and other personal data. In his letter, the President of the Personal Data Protection Office pointed to solutions developed during the legislative process aimed at ensuring the application of the Digital Services Act (DSA) in Polish law, which make it possible to respond more effectively and more quickly to illegal content on the internet.

The development of new technologies, in particular tools using artificial intelligence, creates new possibilities for processing and modifying personal data, and thereby leads to new threats. One such threat is undoubtedly the creation and dissemination of deepfake materials, including fake photos and recordings showing people in intimate situations. Such actions constitute a violation of personal data protection, as well as of the right to privacy and to dignity and good name.

Cyberbullying affects children and young people particularly severely. Minors' images are unlawfully used to create fake photos and recordings, including of a sexual nature. An example is the case of primary school pupils who generated a fake image of a naked female classmate and then encouraged others to distribute it. The President of the Personal Data Protection Office, Mirosław Wróblewski, notified law enforcement authorities of a possible criminal offence (more: https://uodo.gov.pl/pl/138/4182). This case shows that readily available technologies can be used to deeply interfere with a person's privacy and dignity, which may be especially harmful to a child or young person.

Appropriate mechanisms are needed

Protection against digital threats cannot be limited to penalising unlawful behaviour. Parallel preventive and educational measures are needed, including at the legal and technological level.

Authenticity verification mechanisms are needed that make it possible to detect manipulated content, including content classified as personal data. It is also essential to build digital skills and awareness of threats, especially among the youngest Internet users.

As a result of the President of the Personal Data Protection Office proposals, the Ministry of National Education has included in the curriculum for grades 4–6 of primary school topics on cyberbullying, hate speech, deepfakes, identity theft, phishing, child grooming, blackmail, and the benefits and risks of artificial intelligence and virtual reality. More on this topic: https://uodo.gov.pl/pl/138/4464

In the view of the President of the Personal Data Protection Office, one of the key elements of protecting Internet users should be the implementation of solutions arising from the Digital Services Act and the creation of an effective procedure for responding to illegal content.

Blocking content 

During work on the draft act amending the act on the provision of services by electronic means and certain other acts, the President of the Personal Data Protection Office called for the introduction of a special procedure for the most serious threats to children and young people.

The supervisory authority pointed above all to the need to enable the immediate blocking of content related to the sexual exploitation of minors. This solution was supported by the education ministry, which sent its position on the matter to the Secretary of the Standing Committee of the Council of Ministers. As a result of these actions, the draft was expanded by the drafter to include a solution that is right in principle: the rigour of immediate enforceability may be attached to a decision if it concerns illegal content whose dissemination may constitute an offence referred to in Article 200 § 3 and 5, Article 200a or Article 200b of the Act of 6 June 1997 – the Criminal Code. However, the President of the Personal Data Protection Office pointed out that the catalogue of offences allowing a decision to be given immediate enforceability did not cover all acts related to the processing of pornographic content involving minors or their image, as defined in Article 202 § 3–4c of the Criminal Code.

The President of the Personal Data Protection Office consistently called for this gap to be closed. On 3 September 2026, a relevant amendment was adopted by the Committee on Digital Affairs, Innovation and Modern Technologies with the votes of all members present at the sitting. More on this: https://uodo.gov.pl/pl/138/4561

The appeal of the President of the Personal Data Protection Office

In the assessment of the President of the Personal Data Protection Office, the solutions developed in the legislative process related to the implementation of the Digital Services Act can significantly strengthen the protection of privacy and personal data on the Internet and limit the possibility of using new technologies to unlawfully interfere with the most personal human interests. Accordingly, the President of the Personal Data Protection Office asked the President of the Republic of Poland to approve the statutory solutions protecting network users, including children and young people, against digital threats, developed during the legislative process implementing the Digital Services Act, as having been consulted with the personal data protection authority and positively assessed by it from the perspective of personal data protection and children's fundamental rights. In his position, the President of the Personal Data Protection Office stressed that introducing the DSA-implementing acts into the Polish legal order is crucial for ensuring effective protection of personal data processed on the Internet, and that the support of the President of the Republic of Poland is also invaluable in other areas of action taken to combat digital threats associated with unwanted processing of personal data.

The President of the Personal Data Protection Office declared expert support for further actions aimed at countering digital threats and protecting the rights of Internet users.