The draft bill amending the InfoAct, as prepared by the Ministry of Justice, contains provisions on the processing of deceased persons' personal data. It grants to the deceased persons' close relatives the right to erasure and to obtain restriction of processing, upon request made within five years following the death.
Update (04 December 2017): it is likely that the Ministry of Justice will retain these provisions in the next draft.
The Section 2-duodecies of the IDPA, as amended, foresees that the rights referred to in Sections 15 to 22 GDPR can be activated by an individual who has an interest in the protection, by his agent, or for family reasons worthy of protection ("Representative").
The exercise of rights by Representatives is not permitted in cases prescribed by law or when, in respect of the direct offer of information society / online services, the data subject has expressly forbidden it by way of a written declaration provided or communicated to the data controller.