Following the 25 May, the LMA claims team, alongside legal & compliance representatives, have been working with DXC to understand their internal processes when dealing with requests such as DSAR, Rectification & Erasure. Additionally, following market interaction, a list of scenarios and questions have been posed by claims adjusters surrounding the correct procedures for dealing with the issuance of privacy notices.
DXC internal processes
DXC have produced documentation to support their process when dealing with all types of data subject requests. Simultaneously, the LMA claims team have produced process maps from a market perspective which will overlay on top of the DXC model, clearly outlining who has ownership and responsibility throughout these processes and ensuring there is visibility to the following markets. These have been agreed by all parties including the GDPR Working Group and will be made available to the market during Q2 2019.
There is currently an expectation that these requests will be limited in number and on that basis, DXC have agreed to perform this service at no cost. DXC reserve the right to review this position if there is a significant increase in the amount of requests being raised.
Issuance of privacy notices
Through the various claims committees, a list of questions have been drawn up which require review and guidance from the GDPR Working Group. Clyde & Co have been engaged to draft a Reinsurance clause for future use and will be providing legal guidance on the issuance of these privacy notices.
A number of solutions are being investigated to release the burden on the claims community and to make this procedure as seamless as possible. It is anticipated the target completion is end of Q2 2019.