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Data protection concerns raised with Article 29 Working Party

In its response to the European Commission’s Article 29 Working Party's consultation on draft guidelines on personal data breach notifications under the General Data Protection Regulation (GDPR), Insurance Europe said the guidelines should not expand the scope of the relevant GDPR provisions beyond what was outlined in the Level 1 text.

It also called on the Article 29 Working Party to consider the importance for insurers to be given access to relevant data in a sufficiently granular and anonymised format, and encouraged the Working Party to make use of its template on data breach notification, as a good practice, in its final guidelines.

In addition, Insurance Europe submitted comments on draft guidelines on automated individual decision-making and profiling. Here Insurance Europe called for clarity on several issues to provide the necessary legal certainty to market operators.

Insurance Europe also submitted its comments on the transparency requirements under the GDPR, where it called for increased flexibility in how disclosures can be made to consumers — for example, both offline and online — to avoid information fatigue.

Published 30 November 2017