Personal data protection during the processing of new biometric passports in Armenia is entirely under state control. This was stated by Nelli Davtyan, Head of the Migration and Citizenship Service of the country's Ministry of Internal Affairs, during a press tour at the HayPass service center located in the Megamall shopping center. According to her, the project's private partner, the HayPass company, performs exclusively technical tasks and does not obtain authority to independently manage citizens' personal information.

The procedure entails collecting applicants' biometric details with the subsequent immediate transfer of the information to the state data processing center. The center itself is hosted in the public sector, and the Ministry of Internal Affairs of Armenia acts as the personal data controller. Thus, the private entity ensures technical maintenance of the document processing workflow, while responsibility for data management remains with state agencies.

Nelli Davtyan also clarified the passport production procedure. Printing of a document begins only after the Migration and Citizenship Service reviews a specific application and separately approves its production. Consequently, HayPass makes no independent decisions regarding the issuance of biometric passports: final authorization for the production of each document is granted by the state service.