AZLP initiated supervision due to Bogdanović's announcement about Aco Đukanović's assets

The Agency for Personal Data Protection and Free Access to Information (AZLP) has initiated a procedure for supervising the implementation of personal data protection regarding the publication of real estate titles of Aco Đukanović on the Facebook profile of Democratic Montenegro MP Boris Bogdanović.

Bogdanović delivered the notification of the AZLP decision to the media.

AZLP initiated the supervision procedure based on a request for protection of rights filed on March 9, 2026 through an attorney, lawyer Neda Ivović from Podgorica.

The request states that Aco Đukanović's personal data was collected, processed, systematized and publicly published contrary to the provisions of the Personal Data Protection Law, which, it is claimed, grossly violated his rights.

According to the document, on March 3, Bogdanović posted 38 photos of real estate deeds registered to Aco Đukanović on his Facebook profile, along with a systematized overview of his assets and political qualifications for the alleged illegal acquisition.

The request states that the overview is not an individual piece of data from the public register, but the result of systematic collection and combination from multiple real estate records, and that this created a complete overview of one person's property, which indicates unauthorized acquisition and processing of data.

It is also stated that, given the structure of the published real estate documents, the search was most likely carried out using a unique identification number or other identification data, for which, as it says, there was no consent, thus violating the Law on the Protection of Personal Data.

"By posting on the social network Facebook, personal data is made available to an unlimited circle of persons via the global digital infrastructure and is effectively taken outside the legal protection regime that applies on the territory of Montenegro," the AZLP request states.

The applicant pointed out that the social network operates within the platform of the company Meta Platforms, whose server infrastructure is located outside of Montenegro, and that this is additionally confirmed by the transfer of data from the country.

It is added that such conduct is contrary to the European Convention on Human Rights, which guarantees the right to privacy, citing the practice of the European Court of Human Rights in cases against Finland, Romania and Switzerland.

The ASK request states that it is necessary for Bogdanović to provide a written statement on the allegations in the request in order to establish the factual situation.

"Upon reviewing the post on Boris Bogdanović's FB profile from 03.03.2026, it was determined that photographs of transcripts from 11 real estate titles owned by Aco Đukanović were published, which transcripts were printed on 26.12.2025 between 14:07 and 14:39. In this regard, describe in detail how the search for the real estate titles in question was conducted? What is the legal basis and purpose of publishing the real estate titles in question? Was the real estate cadastre search also conducted for other natural persons? Submit copies of all real estate titles published on 03.03.2026 on the social network 'Facebook'," the AZLP request states.