First Communication from the Data Protection Authority: Risks Associated with the Use of Open Source CMS

January 12, 2026
1 min read

Dear clients and friends,

A CMS (Content Management System) is software that allows websites to be created and managed in a simple manner. However, its use, particularly open-source versions with generic plugins and templates, may involve significant personal data protection risks if not implemented with appropriate security controls.

In this context, on January 12, 2026, the Secretariat for Anti-Corruption and Good Governance issued its first communication on personal data protection, warning public authorities and private entities about these risks.

As a result of more than 20 investigations into alleged data breaches, the authority identified easily exploitable vulnerabilities that may compromise sensitive information and lead to administrative and even criminal sanctions, urging data controllers to strengthen their security measures.

The Secretariat also highlighted the need to update the personal data protection legal framework, which has remained substantively unchanged for more than 15 years.

Conclusion

This communication reflects a tightening of the regulatory approach and sends a clear preventive message. Organizations using CMS should review their platforms, strengthen security, and assess their level of regulatory compliance.

At Ramos, Ripoll & Schuster®, we remain at your disposal to advise you on the impact of this communication and the actions necessary to mitigate risks.

Our specialist lawyers

Our team of lawyers is ready to help you understand how to apply these new rules to your company or investment project.

Elías-Fernández, Edmundo

Senior Partner

Ripoll-González, Alejandro

Senior Partner

Amador Espinosa, Juan Rafael

Senior Associate

Márquez Ledezma, Daniela

Associate

Castañeda García, Sofía

Junior Associate

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