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6th December 2017
GDPR guide for London Market published
With increasing concerns over the use of personal data, special categories of personal data(sensitive data) and the impending implementation of the General Data Protection Regulation(May 2018), the Lloyd's Market Association(LMA), with the International Underwritng Association(IUA), LIIBA and BIBA, has published a London Market: Core Uses Information Notice.
The notice is designed to provide data subjects with a consistent explanation of how various insurance market participants process their personal data in respect of core activities that take place throughout the insurance lifecycle. It takes into account the complexities of the London Market and the GDPR requirements and has two main functions:
-To assist insurers, brokers and other market participants, and their clients, in explaining to data subjects how their personal data may be disclosed and used through the distribution chain for core activities from pre-placement to claims payment.
-To cross-refer within contractual documentation when one market participant relies on another to provide notice of, or obtain consent to, the use of personal data.
The notice is a live working draft, and will be reviewed at least quarterly. The UK Data Protection Bill, when enacted, may lead to changes to the notice, as could further guidance from the Information Commissioner’s Office.
Manreet Sher, senior executive, Legal & Compliance, at the LMA, comments “This is an LMA-led initiative to improve efficiency within the market. Widespread use of the notice should greatly assist in educating consumers consistently on how their personal data is used throughout the insurance lifecycle and thereby support each market participant’s own efforts to meet its obligations under GDPR.”
The notice is the result of significant work by the LMA, LIIBA, BIBA, the IUA and the market working party, who are grateful for the assistance of the panel of law firms: Clyde & Co, DAC Beachcroft and Norton Rose Fulbright.
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