Glossary

11.4 Privacy and data protection in insurance

11 min read•august 21, 2024

Privacy and data protection are crucial aspects of the insurance industry. Insurers collect vast amounts of sensitive information, including personal, financial, and medical data, to assess risk and process claims. Protecting this data is essential for maintaining customer trust and complying with regulations.

The insurance sector faces unique challenges in balancing data use for innovation with privacy concerns. Insurers must implement robust security measures, obtain proper consent, and provide transparency about data practices. Emerging technologies like AI and IoT present new opportunities and risks for privacy in insurance.

Definition of insurance privacy

  • Insurance privacy encompasses the protection and responsible handling of collected by insurance companies from policyholders and claimants
  • Involves safeguarding data throughout its lifecycle, from collection to storage, use, and disposal
  • Crucial for maintaining trust between insurers and customers, as well as complying with legal and regulatory requirements

Types of sensitive data

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  • Personal identifiable information (PII) includes names, addresses, social security numbers, and birth dates
  • Financial data consists of bank account details, credit card information, and income statements
  • Medical records contain health history, diagnoses, treatments, and prescription information
  • Claims history details past insurance claims, settlements, and policy information
  • Behavioral data includes lifestyle choices, driving habits, and home security measures

Importance of data protection

  • Preserves customer trust and loyalty by demonstrating commitment to safeguarding personal information
  • Mitigates financial and reputational risks associated with data breaches or misuse
  • Ensures with legal and regulatory requirements, avoiding potential fines and penalties
  • Enables fair and accurate underwriting and claims processing based on protected, reliable data
  • Supports the ethical use of customer information in developing new products and services

Regulatory landscape

  • Privacy regulations in insurance have evolved rapidly in response to technological advancements and increased data collection
  • Compliance with these regulations is essential for insurers to operate legally and maintain customer trust
  • Failure to adhere to privacy laws can result in severe penalties, reputational damage, and loss of business

Key privacy regulations

  • General Data Protection Regulation () governs data protection and privacy in the European Union
  • (CCPA) provides enhanced privacy rights for California residents
  • Health Insurance Portability and Accountability Act () protects sensitive patient health information
  • (GLBA) requires financial institutions to explain their information-sharing practices
  • New York Department of Financial Services (NYDFS) Cybersecurity Regulation sets standards for financial institutions

Compliance requirements

  • Implement comprehensive data protection policies and procedures across the organization
  • Conduct regular risk assessments and audits to identify and address potential vulnerabilities
  • Appoint a (DPO) to oversee privacy compliance efforts
  • Maintain detailed records of data processing activities and be prepared for regulatory inspections
  • Provide clear and transparent privacy notices to customers, explaining data collection and use practices

Data collection practices

  • Insurance companies gather extensive personal information to assess risk, determine premiums, and process claims
  • Ethical data collection practices are essential for maintaining customer trust and complying with regulations
  • Insurers must balance their need for data with individuals' right to privacy

Purpose of data gathering

  • Underwriting involves analyzing personal information to assess risk and determine appropriate premiums
  • Claims processing requires detailed information about incidents, damages, and relevant circumstances
  • Fraud detection utilizes data analysis to identify suspicious patterns or anomalies in claims
  • Product development relies on aggregated data to design new insurance offerings and improve existing ones
  • Customer service improvements stem from analyzing customer interactions and preferences
  • Obtain explicit consent from individuals before collecting or processing their personal data
  • Provide clear and concise privacy notices explaining what data is collected and how it will be used
  • Offer opt-out options for certain types of data collection or processing (marketing communications)
  • Implement a preference management system allowing customers to update their consent choices
  • Regularly review and update consent mechanisms to ensure ongoing compliance with changing regulations

Data storage and security

  • Proper storage and security of insurance data are critical to protect against unauthorized access and breaches
  • Implementing robust security measures helps insurers comply with regulations and maintain customer trust
  • Regular security audits and updates are necessary to address evolving threats and vulnerabilities

Encryption methods

  • Data at rest encryption protects stored information using algorithms (AES, RSA)
  • Data in transit encryption secures information as it moves between systems or over networks (SSL/TLS)
  • End-to-end encryption ensures data remains encrypted from sender to recipient, preventing intermediary access
  • Homomorphic encryption allows computations on encrypted data without decrypting it
  • Key management systems safeguard encryption keys and control access to encrypted data

Access control measures

  • (RBAC) restricts system access based on employees' roles within the organization
  • (MFA) requires multiple forms of verification before granting access to sensitive data
  • limits user access rights to the minimum necessary for their job functions
  • Regular access reviews and audits ensure appropriate permissions are maintained over time
  • (PAM) monitors and controls access for users with elevated system rights

Data sharing and third parties

  • Insurance companies often need to share data with third parties for various business purposes
  • Proper management of data sharing practices is crucial to maintain privacy and comply with regulations
  • Insurers must carefully vet and monitor third-party vendors to ensure they adhere to privacy standards

Information sharing policies

  • Establish clear guidelines for what types of data can be shared and under what circumstances
  • Implement data classification systems to categorize information based on sensitivity and sharing restrictions
  • Use principles to share only the necessary information required for specific purposes
  • Create audit trails to track all instances of data sharing, including recipients and purposes
  • Regularly review and update sharing policies to align with changing regulations and business needs

Vendor management

  • Conduct thorough due diligence on potential vendors, assessing their privacy and security practices
  • Implement contractual safeguards, including data protection agreements and confidentiality clauses
  • Require vendors to comply with specific security standards (, SOC 2)
  • Perform regular audits and assessments of vendor privacy practices and compliance
  • Establish incident response protocols for vendor-related data breaches or privacy violations

Customer rights and access

  • Privacy regulations grant individuals specific rights regarding their personal data
  • Insurance companies must implement processes to honor these rights and respond to customer requests
  • Empowering customers with control over their data builds trust and demonstrates commitment to privacy

Right to be forgotten

  • Allows individuals to request the deletion of their personal data under certain circumstances
  • Insurers must have processes in place to identify and erase relevant data across all systems
  • Exceptions may apply for data required for legal or regulatory purposes (claims history)
  • Implement verification procedures to ensure requests are legitimate before processing
  • Maintain records of erasure requests and actions taken for compliance purposes

Data portability

  • Enables customers to receive their personal data in a structured, commonly used, and machine-readable format
  • Allows for the transfer of personal data from one insurance provider to another upon request
  • Insurers must develop systems to extract and package customer data in standardized formats
  • Implement secure transfer methods to transmit portable data to customers or other providers
  • Establish timeframes for responding to portability requests in line with regulatory requirements

Privacy impact assessments

  • Systematic process to identify and mitigate privacy risks associated with new projects or changes to existing systems
  • Helps organizations comply with privacy regulations and demonstrate due diligence
  • Crucial for implementing privacy by design principles in insurance operations

Risk identification

  • Analyze data flows to map how personal information moves through the organization
  • Identify potential vulnerabilities in data collection, storage, processing, and sharing practices
  • Assess the likelihood and potential impact of privacy breaches or data misuse
  • Consider both internal and external threats to data privacy and security
  • Evaluate compliance gaps with relevant privacy regulations and industry standards

Mitigation strategies

  • Implement technical controls (encryption, access management) to address identified risks
  • Develop and enforce policies and procedures to guide privacy-conscious practices
  • Provide targeted training to employees handling sensitive data or involved in high-risk processes
  • Incorporate privacy-enhancing technologies (PETs) into system design and development
  • Establish ongoing monitoring and review processes to address evolving privacy risks

Data breaches and incidents

  • Data breaches pose significant risks to insurance companies, including financial losses and reputational damage
  • Proper incident response planning is crucial for minimizing the impact of breaches and meeting regulatory requirements
  • Regular testing and updating of incident response plans help ensure effectiveness in real-world scenarios

Breach notification requirements

  • Identify applicable notification laws based on the types of data involved and affected individuals
  • Establish timelines for notifying affected individuals, typically within 72 hours of breach discovery
  • Provide clear and concise information about the nature of the breach and steps taken to mitigate risks
  • Offer appropriate remediation services to affected individuals (credit monitoring, identity theft protection)
  • Report breaches to relevant regulatory authorities as required by law

Incident response planning

  • Develop a comprehensive incident response plan outlining roles, responsibilities, and procedures
  • Assemble a cross-functional incident response team including IT, legal, PR, and executive leadership
  • Implement a system for early detection and rapid containment of potential data breaches
  • Conduct regular tabletop exercises and simulations to test and improve response capabilities
  • Establish relationships with external resources (forensic experts, legal counsel) for additional support

Emerging technologies and privacy

  • Advancements in technology present both opportunities and challenges for privacy in the insurance industry
  • Insurers must carefully consider privacy implications when adopting new technologies
  • Proactive privacy measures are essential when integrating emerging technologies into insurance operations

AI and machine learning

  • Implement privacy-preserving machine learning techniques (federated learning, differential privacy)
  • Ensure transparency in AI decision-making processes to comply with explainability requirements
  • Address potential biases in AI algorithms that may lead to unfair or discriminatory outcomes
  • Develop guidelines for ethical use of AI in insurance underwriting and claims processing
  • Implement robust data governance frameworks to manage AI training data and model outputs

Internet of Things (IoT)

  • Secure IoT devices used for insurance purposes (telematics, smart home sensors) against unauthorized access
  • Implement data minimization principles to collect only necessary information from IoT devices
  • Provide clear disclosures to customers about data collection practices related to IoT devices
  • Ensure proper consent mechanisms for ongoing data collection from connected devices
  • Develop protocols for securely transmitting and storing data generated by IoT devices

Privacy by design

  • Approach to system design that incorporates privacy considerations from the outset of product development
  • Helps insurers build trust with customers and reduce the risk of privacy violations
  • Aligns with regulatory requirements for data protection and privacy in many jurisdictions

Proactive vs reactive approaches

  • Proactive approach integrates privacy measures into systems and processes from the beginning
  • Reactive approach addresses privacy concerns after systems are already in place, often less effective
  • Conduct early in the development process to identify potential issues
  • Implement privacy-enhancing features as core components rather than add-ons
  • Foster a culture of privacy awareness among development teams and stakeholders

Privacy-enhancing technologies

  • Data anonymization techniques remove personally identifiable information from datasets
  • Pseudonymization replaces identifying data with artificial identifiers to protect individual privacy
  • Secure multi-party computation allows analysis of combined datasets without revealing individual data
  • enable verification of information without disclosing the underlying data
  • can provide transparent and immutable records of data transactions

International data transfers

  • Global nature of insurance often requires the transfer of personal data across borders
  • Complex regulatory landscape governs international data transfers, varying by jurisdiction
  • Insurers must implement appropriate safeguards to ensure compliant and secure cross-border data flows

Cross-border data flow

  • Identify all instances of international data transfers within the organization's operations
  • Implement appropriate legal mechanisms for transfers (, binding corporate rules)
  • Conduct transfer impact assessments to evaluate the privacy risks associated with specific transfers
  • Establish processes for monitoring and documenting international data flows
  • Develop contingency plans for disruptions to international transfers due to regulatory changes

Adequacy decisions

  • Recognize jurisdictions deemed to provide adequate levels of data protection by regulatory authorities
  • Simplify data transfers to countries with adequacy decisions, reducing administrative burden
  • Monitor changes in adequacy status that may impact existing data transfer arrangements
  • Implement alternative transfer mechanisms for countries without adequacy decisions
  • Assess the impact of geopolitical events on adequacy decisions and data transfer policies

Privacy training and awareness

  • Comprehensive privacy training programs are essential for creating a privacy-conscious organizational culture
  • Regular education helps employees understand their role in protecting customer data and maintaining compliance
  • Effective training reduces the risk of human error leading to privacy breaches or violations

Employee education programs

  • Develop role-specific privacy training modules tailored to different job functions and responsibilities
  • Conduct regular refresher courses to keep employees updated on evolving privacy regulations and best practices
  • Utilize diverse training methods (e-learning, workshops, simulations) to enhance engagement and retention
  • Implement assessment mechanisms to evaluate employee understanding and identify areas for improvement
  • Provide resources and guidelines for employees to reference when handling privacy-related issues

Cultural shift in organizations

  • Foster a privacy-first mindset across all levels of the organization, from leadership to front-line staff
  • Integrate privacy considerations into performance evaluations and recognition programs
  • Encourage open communication about privacy concerns and potential improvements
  • Establish privacy champions within different departments to promote best practices
  • Regularly communicate privacy successes and lessons learned to reinforce the importance of data protection

Ethical considerations

  • Insurance companies must navigate complex ethical issues related to data privacy and use
  • Balancing business interests with individual privacy rights requires careful consideration and transparent practices
  • Ethical data handling practices contribute to long-term customer trust and brand reputation

Balancing privacy vs innovation

  • Evaluate the potential benefits and risks of new data-driven innovations in insurance
  • Implement privacy impact assessments for innovative products or services before launch
  • Engage in open dialogue with customers and stakeholders about data use in innovation
  • Explore privacy-preserving technologies that enable innovation while protecting individual privacy
  • Establish ethical review boards to assess the implications of new data-driven initiatives

Social responsibility

  • Recognize the broader societal impact of data privacy practices in the insurance industry
  • Implement fair and transparent pricing models that do not discriminate based on protected characteristics
  • Contribute to public education efforts on data privacy and responsible information sharing
  • Collaborate with industry peers and regulators to develop ethical standards for data use in insurance
  • Support research and development of privacy-enhancing technologies for the benefit of the industry

Future of privacy in insurance

  • Rapidly evolving technology and changing societal attitudes continue to shape privacy expectations in insurance
  • Insurers must anticipate and adapt to future privacy challenges to remain competitive and compliant
  • Proactive approach to privacy can create opportunities for differentiation and innovation in the market

Evolving consumer expectations

  • Increasing demand for greater transparency and control over personal data use in insurance
  • Growing interest in personalized insurance products balanced with privacy concerns
  • Shift towards more granular consent models for specific data uses and sharing practices
  • Rising expectations for real-time access to personal data and easy-to-use privacy management tools
  • Emerging preference for insurers with strong privacy reputations and demonstrated ethical data practices
  • Movement towards more comprehensive and stringent privacy regulations globally
  • Increasing focus on algorithmic fairness and transparency in AI-driven insurance decisions
  • Growing emphasis on privacy-by-design principles in regulatory compliance requirements
  • Potential for harmonization of international privacy standards to facilitate global data flows
  • Evolving regulatory approach to emerging technologies (IoT, blockchain) in insurance contexts

Key Terms to Review (32)

Blockchain technology: Blockchain technology is a decentralized digital ledger system that securely records transactions across multiple computers, ensuring transparency and preventing tampering. This innovative technology enables real-time tracking and verification of transactions, making it highly relevant for various sectors, including finance and insurance, where trust and accuracy are paramount.
California Consumer Privacy Act: The California Consumer Privacy Act (CCPA) is a landmark piece of legislation that enhances privacy rights and consumer protection for residents of California, which took effect on January 1, 2020. It allows consumers to know what personal data is being collected about them, the purpose of that collection, and provides the ability to access, delete, and opt-out of the sale of their personal information. The CCPA has significant implications for various industries, including insurance, as it compels businesses to be more transparent and responsible in handling consumer data.
Compliance: Compliance refers to the process of adhering to laws, regulations, and internal policies within an organization. In the insurance sector, it encompasses the obligation to protect sensitive customer information and ensure that technological advancements align with regulatory standards. The significance of compliance is heightened in the context of privacy and data protection, as well as emerging technologies like blockchain and smart contracts.
Compliance Officer: A compliance officer is a professional responsible for ensuring that an organization adheres to regulatory requirements and internal policies, particularly related to legal and ethical standards. They play a critical role in protecting sensitive information and maintaining the trust of clients by overseeing data protection practices and privacy regulations within the organization, especially in industries like insurance where personal data is abundant.
Cyber liability insurance: Cyber liability insurance is a type of insurance that provides financial protection to businesses against damages and legal liabilities arising from cyber incidents, such as data breaches and hacking. This insurance typically covers costs related to data recovery, legal fees, notification expenses, and potential regulatory fines, linking it to broader concepts of liability and risk management in specialized insurance contexts.
Data breach: A data breach is an incident where unauthorized access to sensitive or confidential data occurs, often resulting in the exposure of personal information such as names, social security numbers, and financial details. This can happen through various means, including hacking, malware attacks, or human error. Data breaches are particularly significant in sectors that handle large volumes of personal data, as they can lead to serious consequences for individuals and organizations alike.
Data encryption: Data encryption is the process of converting information or data into a code to prevent unauthorized access. This technique ensures that sensitive information, such as personal data or financial records, remains secure and confidential, especially in industries like insurance where privacy is paramount. By encrypting data, organizations can protect themselves against data breaches and comply with legal regulations that govern data protection.
Data minimization: Data minimization is a principle in data protection that involves limiting the collection, storage, and processing of personal information to only what is necessary for a specific purpose. This concept emphasizes the importance of handling only the minimum amount of personal data required, thus reducing the risks associated with data breaches and unauthorized access. By implementing data minimization practices, organizations can enhance privacy protection and comply with regulatory standards.
Data portability: Data portability is the ability for individuals to transfer their personal data from one service provider to another in a structured, commonly used, and machine-readable format. This concept is essential in promoting user control over personal information, allowing them to switch services without losing their data, thereby fostering competition and innovation among providers.
Data protection officer: A data protection officer (DPO) is a designated individual responsible for ensuring that an organization complies with data protection laws and regulations. This role is crucial in sectors like insurance, where sensitive personal data is often handled, as it helps maintain privacy and protects consumers' rights regarding their personal information.
GDPR: The General Data Protection Regulation (GDPR) is a comprehensive data protection law that went into effect in May 2018 in the European Union, aiming to enhance individuals' control over their personal data and establish strict rules for organizations handling this data. It connects to various aspects of governance and compliance, digital services, privacy rights, and cybersecurity measures, making it crucial for entities operating within or dealing with the EU market.
Gramm-Leach-Bliley Act: The Gramm-Leach-Bliley Act (GLBA) is a U.S. federal law enacted in 1999 that allows financial institutions to consolidate and offer a variety of financial services, including banking, securities, and insurance, under one umbrella. It plays a crucial role in regulating how these institutions share and protect consumer information, connecting it directly to regulatory compliance, privacy concerns, and the roles of financial regulatory bodies.
HIPAA: HIPAA, or the Health Insurance Portability and Accountability Act, is a U.S. law designed to protect sensitive patient health information from being disclosed without the patient's consent or knowledge. The act establishes national standards for the protection of health information, emphasizing privacy and security as key components in the healthcare and insurance industries. HIPAA also aims to improve the efficiency of healthcare delivery while ensuring that patient rights are maintained.
Identity theft insurance: Identity theft insurance is a type of coverage designed to protect individuals from the financial losses and expenses associated with identity theft. This insurance can cover costs such as legal fees, lost wages, and out-of-pocket expenses for restoring one's identity after a theft occurs. It is increasingly relevant as data breaches and cybercrime raise concerns about privacy and data protection.
Informed Consent: Informed consent is the process through which individuals are provided with clear and comprehensive information about a procedure or treatment, allowing them to make an educated decision about whether to proceed. This concept emphasizes the importance of transparency and understanding in interactions, particularly regarding the collection and use of personal data and consumer rights in various sectors.
ISO 27001: ISO 27001 is an international standard that provides a framework for managing information security risks. It helps organizations establish, implement, maintain, and continually improve an Information Security Management System (ISMS). By adhering to ISO 27001, organizations can better protect sensitive data, which is crucial in sectors like insurance and cybersecurity.
Liability: Liability refers to the legal responsibility that an individual or organization has for the consequences of their actions, particularly in the context of causing harm or damage to another party. This concept is crucial in understanding how individuals and businesses are held accountable for their actions, including the necessity of having insurance to protect against potential claims. It encompasses various forms, such as personal liability, professional liability, and product liability, each with unique implications for privacy and data protection.
Mitigation strategies: Mitigation strategies refer to the systematic approaches and actions taken to reduce the severity or impact of potential risks, particularly in relation to privacy and data protection in the insurance industry. These strategies aim to identify vulnerabilities in data handling processes, implement safeguards, and enhance compliance with regulations to protect sensitive information from breaches or misuse. By proactively addressing these risks, organizations can maintain trust and safeguard their operations while minimizing potential financial losses.
Multi-factor authentication: Multi-factor authentication (MFA) is a security process that requires users to provide two or more verification factors to gain access to a resource, such as an online account or application. This method enhances security by combining something the user knows (like a password), something the user has (like a smartphone or security token), and something the user is (like a fingerprint). By using multiple factors, MFA helps protect sensitive data, especially in fields like insurance, where personal and financial information is at risk.
New York Department of Financial Services Cybersecurity Regulation: The New York Department of Financial Services (NYDFS) Cybersecurity Regulation is a set of comprehensive standards that requires financial institutions operating in New York to implement robust cybersecurity measures. Established to protect sensitive consumer data and ensure the integrity of the financial services industry, the regulation outlines specific requirements for risk assessments, cybersecurity policies, incident response, and the reporting of cyber incidents.
NIST Cybersecurity Framework: The NIST Cybersecurity Framework is a voluntary guidance framework developed by the National Institute of Standards and Technology to help organizations manage and reduce cybersecurity risk. It provides a structured approach with key components, including identifying, protecting, detecting, responding, and recovering from cybersecurity incidents. This framework is particularly relevant for industries like insurance, where data protection and privacy are paramount, as it helps organizations assess their cybersecurity posture and implement effective controls.
Non-public personal information: Non-public personal information refers to any data that is personally identifiable and not publicly available, including financial details, medical records, and other private information that individuals share with institutions. This type of information is particularly sensitive in the context of financial services, such as insurance, where protecting this data is crucial to maintaining client trust and compliance with privacy laws.
Principle of Least Privilege: The principle of least privilege is a security concept that asserts that any user, program, or system should have only the minimum levels of access necessary to perform its functions. This principle helps to protect sensitive information and systems by limiting exposure to potential misuse or attack, making it crucial for effective privacy and data protection strategies, especially in environments like insurance where personal data is handled.
Privacy Impact Assessments: Privacy impact assessments (PIAs) are systematic processes designed to evaluate the potential effects of a project, system, or initiative on individuals' privacy. They help organizations identify and mitigate privacy risks, ensuring compliance with laws and regulations while protecting personal data. In the context of data protection in insurance, PIAs are essential for assessing how insurance products and services handle sensitive information.
Privacy notice: A privacy notice is a statement that informs individuals about how their personal information is collected, used, and shared by an organization. This notice is crucial in the insurance industry as it builds transparency and trust, ensuring that policyholders understand their rights regarding their data and how it may be utilized or disclosed by the insurer.
Privileged access management: Privileged access management (PAM) refers to the strategies and tools used to control and monitor access to sensitive data and systems by users with elevated privileges. It focuses on protecting critical information by ensuring that only authorized personnel can access it, while also tracking their activities to prevent misuse. PAM is vital in maintaining the security and privacy of data, particularly in industries that handle sensitive information, like insurance.
Right to be forgotten: The right to be forgotten is a legal concept that allows individuals to request the removal of personal information from internet search results and online databases, particularly when the information is outdated or no longer relevant. This right seeks to protect individuals' privacy and dignity, enabling them to regain control over their personal data in the digital space. It also intersects with broader issues of data protection and privacy rights, especially in the context of how organizations manage and handle personal information.
Risk assessment: Risk assessment is the systematic process of identifying, analyzing, and evaluating potential risks that could negatively impact an organization's assets or objectives. This process helps organizations understand the risks they face and informs decision-making regarding risk management strategies.
Role-based access control: Role-based access control (RBAC) is a method of regulating access to computer or network resources based on the roles of individual users within an organization. This approach helps to manage permissions and ensures that sensitive data is only accessible to authorized personnel, thereby enhancing privacy and data protection. By assigning roles that reflect a user's responsibilities, organizations can minimize the risk of unauthorized access and improve compliance with data protection regulations.
Sensitive personal information: Sensitive personal information refers to specific data that, if disclosed, can lead to harm or significant privacy breaches for an individual. This type of information often includes details such as Social Security numbers, financial information, medical records, and any data that could reveal one's racial or ethnic origin, political opinions, or sexual orientation. The management of such information is critical in ensuring privacy and data protection, especially within industries like insurance where trust is paramount.
Standard contractual clauses: Standard contractual clauses (SCCs) are legal tools used in data protection and privacy regulations that provide a framework for transferring personal data between entities in different countries. They are essential for ensuring that data transferred outside of a certain jurisdiction meets adequate protection standards, particularly when transferring data from the European Union to countries lacking equivalent data protection laws. SCCs help organizations comply with privacy laws by outlining obligations and rights concerning the handling of personal data.
Zero-knowledge proofs: Zero-knowledge proofs are cryptographic methods that allow one party to prove to another that they know a value without revealing the value itself. This technique is crucial for ensuring privacy and security, especially in scenarios where sensitive information must remain confidential, such as in the insurance industry where personal data protection is paramount.
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