Update In Respect Of Data Protection In The Cayman Islands

The Cayman Islands Data Protection Law, 2017 ("DPL"), which was expected to come into force in January 2019, will now not come into force until September 2019. The Office of the Ombudsman has issued a Guide for Data Controllers which aims to explain how the Ombudsman will interpret certain provisions of the DPL. Businesses are therefore well-positioned to prepare.

Overview of the DPL

International financial sector businesses will find many similarities between the data protection law of the Cayman Islands and of other jurisdictions where they are active. The DPL requires a data controller to comply with eight data protection principles when processing personal data and to ensure that those principles are complied with in relation to personal data processed on the data controller's behalf pursuant to a written contract. The DPL deals also with data security, data breaches and the rights of individual data subjects, including providing a privacy notice.