The Cayman Islands Data Protection Law, 2017 (DPL) comes into force on September 30, 2019, and will regulate the future processing of all personal data in the Cayman Islands. Drafted around a set of internationally recognized privacy principles, the new law provides a framework of rights and duties designed to give individuals greater control over their personal data. With the implementation date less than a month away, managers of Cayman funds must ensure that they understand their funds’ obligations under the new law, including enacting policies and procedures to ensure the proper protection of all personal data under their control, as well as creating an effective governance regime for approving, overseeing, implementing and reviewing those policies. Cayman funds must get it right – reputations and criminal liability will soon be at stake. In a guest article, Appleby partners Sailaja Alla and David Lee, along with counsel Peter Colegate, review the key provisions of the DPL and how Cayman funds can achieve compliance with it. See “How Fund Managers Can Navigate the E.U. General Data Protection Regulation and the Cayman Islands Data Protection Law
” (Aug. 9, 2018). For additional commentary from Appleby attorneys, see “Cayman Economic Substance Has Arrived: Steps In-Scope Fund Managers Must Take to Respond
” (Jun. 27, 2019); “How Funds Formed in the Cayman Islands Can Mitigate Legal Risk by Aligning Their Constitutional Documents and Operations
” (Oct. 11, 2018); and “Changes to Redeeming Investor Distribution Priority and Other Ramifications of the Primeo Appellate Decision for Cayman Islands Hedge Funds
” (Sep. 15, 2016).