How Companies in Guanajuato Must Protect Themselves Amid Telephone Line Registration

Mandatory telephone line registration is now a reality. For companies in Guanajuato, the risk lies not in complying, but in complying without a legal strategy. Robust privacy notices, integrity policies, and internal controls are no longer optional: they are corporate protection assets in the new legal environment. Although public debate has focused on privacy risks, the true challenge for the business sector is how to comply with the law without being exposed to legal, criminal, and security risks, warns Katya Morales Prado, president of the Mexican Bar Association, Guanajuato Chapter. “We are institutional and adhere to the law; our calling is to comply with it, but that does not prevent us from being critical when fundamental rights are violated,” she states.

What Changes for Businesses with the New Telephone Register?

The regulation mandates the registration of each telephone line with personal data, and for companies, to prove that the lines are linked to their operations. This implies that:

• Companies can register as many lines as they need,
• But they must demonstrate their business use,
• And assume legal responsibility for what occurs with them. This is where the main corporate risk arises. “Legal entities can incur criminal liability for actions taken with their assets or by their employees,” warns the specialist.

The Legal Context: Why Did This Measure Advance?

This type of registration had previously been halted by the Supreme Court of Justice of the Nation. The difference, explains the specialist, lies in the elimination of the INAI, which previously acted as guarantor of personal data protection rights. “Previously, there was an autonomous body that filed an unconstitutionality action and managed to halt the law. Today, that guarantor no longer exists; they eliminated the guardian, and that’s why the law can advance,” she states. Currently, data protection depends on a department subordinate to the government itself, which, from a legal perspective, reduces effective checks and balances and defense mechanisms.

More Security or More Exposure for Businesses?

One of the official arguments to justify the register is the fight against extortion. However, Morales Prado questions its effectiveness. “It is a confrontation between the right to security and the right to personal data protection. This measure does not guarantee greater security; on the contrary, it exposes us,” she asserts. The concern is not minor. Soon after registration began, data leaks were reported, raising alarms about the capacity of telecommunications companies to safeguard sensitive information. “Telephone companies have demonstrated that they do not have platforms robust enough to prevent leaks or hacks, and they are going to concentrate all our personal data,” she warns.

The Real Legal ‘Hack’ for Business Owners: How to Bulletproof Your Operations?

Beyond the criticism, the Mexican Bar Association, Guanajuato Chapter, focuses on the

that are indeed within companies’ control.

1. Demand a Robust and Professional Privacy Notice

“If I am going to provide my data, I need a well-drafted privacy notice, not a generic, ill-conceived template,” emphasizes Morales Prado. The notice must clearly state:

• What data is collected,
• How it is safeguarded,
• That it will not be made public,
• And that it will only be shared by judicial or ministerial order.

2. Implement a Corporate Integrity Policy

This is the main legal ‘hack’ for companies. “The antidote to reduce or even avoid criminal liability is to have a properly implemented corporate integrity policy,” she explains. The National Code of Criminal Procedures stipulates that if a company demonstrates due diligence, internal protocols, and clear controls over the use of its assets (such as telephone lines), penalties can be reduced or not imposed.

3. Document the Corporate Use of Lines

Assigning lines, defining functions, establishing internal controls, and training personnel is not just good practice: it is a legal shield against potential incidents.

What Legal Options Remain for Citizens and Businesses in Guanajuato?

With the disappearance of INAI, institutional avenues are reduced. However, an alternative still exists: “Amparos can be filed individually, demonstrating the direct impact generated by this obligation,” states the Bar Association president. For businesses, this implies evaluating on a case-by-case basis, with specialized legal advice.

Support for the Productive Sector in Guanajuato

From the Guanajuato Bar Association, the message is clear: compliance must be accompanied by strategy. “We are fully prepared to assist business organizations and companies to prevent highly damaging problems, including corporate criminal liability,” concludes Morales Prado. The post

first appeared in Líder Empresarial.