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Data, nowadays, is a highly valuable commodity, not least in sport. Athletes\u2019 performances can be tracked, measured and analysed through a wide range of personal data.<\/p>\n
In Israel, the legal protection of such data is governed primarily by the Basic Law: Human Dignity and Liberty, 5752-1992<\/strong>; the Protection of Privacy Law, 5741-1981<\/strong> (PPL); the Regulations promulgated thereunder, including the Privacy Protection Regulations (Data Security), 5777-2017<\/strong> and the Privacy Protection Regulations (Transfer of Data to Databases Abroad), 5761-2001<\/strong>.<\/p>\n Amendment No. 13<\/strong> to the PPL was approved in August 2024 and entered into force on 14 August 2025<\/strong>. <\/strong>It has significantly modernised Israeli Privacy Law, strengthened enforcement and brought the regime closer to international standards, including the European Union General Data Protection Regulation.<\/p>\n The Privacy Protection Authority (PPA) is the Israeli regulatory and enforcing authority for personal digital information, in accordance with the PPL. The PPA is responsible for the protection of all personal information held in digital databases. The PPA includes administrative and criminal enforcement, and applies to all entities in Israel – private, business and public – that hold or process personal digital information.<\/p>\n In sport, athletes\u2019 data may include:<\/p>\n Scope of the Israeli Law<\/strong><\/p>\n Under Israeli Law, privacy protection applies both through the general prohibition on infringing privacy and through the statutory regime governing databases. The PPL regulates computerised collections of personal information and imposes legal obligations on entities that collect, process, store and use such data. Accordingly, athletes\u2019 data held by sports bodies may fall within the Israeli privacy legal regime where it is processed in a database and relates to an identified or identifiable person.<\/p>\n Athletes\u2019 data and sensitive personal data<\/strong><\/p>\n Under the updated Israeli legal framework, personal data includes data relating to an identified or identifiable individual, who is one that can be identified by reasonable effort, directly or indirectly, including by identifiers, such as an ID number or location data.<\/p>\n Israeli Law treats certain categories of information as \u2018Highly Sensitive Data<\/em><\/strong>\u2019<\/strong>. Amendment No. 13 to the PPL introduced that broader category, which includes, amongst other things, private affairs; sexual orientation; medical information; genetic data; biometric identifiers; ethnicity; criminal records; political opinions; religious beliefs; location data; salary and financial activity; personality assessments; and personal data protected by statutory confidentiality obligations.<\/p>\n In sport, this is especially relevant where sports bodies process injury reports; diagnoses; rehabilitation plans; medical assessments; biometric identifiers; location data; and certain anti-doping or disciplinary information.<\/p>\n Core legal obligations<\/strong><\/p>\n Israeli Law places strong emphasis on transparency; purpose limitation; proportionality; and data minimisation<\/strong>.<\/p>\n Where information is requested from a person for inclusion in a database, the request must be accompanied by a notice stating whether there is a legal duty to provide the information or whether provision depends upon consent; the purpose for which the information is requested; the recipients of the data; and the purpose of use. Amendment No. 13 to the PPL has expanded these notice obligations to include, amongst other things, the consequences of refusal; the controller\u2019s name and contact details; and the data subject\u2019s rights of access and rectification.<\/p>\n Israeli Law also imposes important compliance obligations in relation to databases. Amendment No. 13 to the PPL has significantly narrowed the legal obligation to register databases with the PPA. Registration is now required principally for certain databases used for the commercialisation of personal data containing information on more than 10,000 individuals, and for certain databases of public bodies.<\/p>\n The Privacy Protection Regulations (Data Security), 5777-2017 apply to both the public and private sectors and establish organisational mechanisms intended to make data security part of routine management. These rules are particularly relevant for clubs, federations and other sports bodies using athlete-management platforms; wearable technologies; cloud storage or medical databases.<\/p>\n Reporting Obligation of Databases with Highly Sensitive Data<\/strong><\/p>\n Amendment No. 13 to the PPL has also introduced a reporting obligation.<\/p>\n Controllers of databases that are not subject to registration, but which contain Highly Sensitive Data<\/strong> relating to more than 100,000 individuals<\/strong>,<\/strong> must report such databases to the PPA.<\/p>\n International transfers<\/strong><\/p>\n The transfer of personal data abroad is subject to the Privacy Protection Regulations (Transfer of Data to Databases Abroad), 5761-2001<\/strong>.<\/strong> As a general rule, data may not be transferred from databases in Israel to another country unless the Law of the receiving country ensures a level of protection not lower than that provided under Israeli law.<\/p>\n Personal data may also be transferred abroad in certain specified cases, including where the data subject has consented; the transfer is necessary to protect health or physical wellbeing; the transfer is intra-group; the foreign recipient is contractually bound to comply with Israeli privacy standards; the transfer is required by law or justified by public safety or security; or the transfer is made to certain recognised jurisdictions. In addition, the database owner must obtain a written undertaking from the recipient to maintain adequate privacy safeguards and prevent onward transfers.<\/p>\n Rights of athletes<\/strong><\/p>\n Athletes, as data subjects, have rights under Israeli Law, including the right to inspect information relating to them that is held in a database and the right to request amendment or deletion where the information is incorrect, incomplete, unclear or not up to date. In certain cases of refusal, the Law provides for an application to the Magistrate\u2019s Court.<\/p>\n These rights may become particularly relevant in disputes involving medical records, disciplinary matters, anti-doping issues or performance-related data.<\/p>\n\n