Five copiesbefore the policy issues.

Insurance distribution is a relay race. Every handover leaves a copy behind.

In one line: Where agents collect and handle data for an insurer, they generally act as its Data Processors, and the insurer remains responsible. Agreements should impose security and deletion duties.

The estate · InsuranceHover to inspect

The agent carries your brand and your liability in the same bag.

The scene

The agent photographed the form, the cheque and the medical declaration, sent them to a branch group of sixty people, and deleted nothing. Two years later the agent moved to a competitor. The photos moved with him.

Where the thinking breaks

The unclear thoughtWhat it breaksThe clearer thought
Agent licensing covers conduct. Licensing is not a data processing contract. Add DPDPA processing terms to agent and broker agreements.
Brokers are independent. Brokers may be fiduciaries for their own purposes and processors for yours. Map the role per activity, in writing.

Exit is a data event

When an agent leaves, their copies of customer data should be returned or destroyed, and confirmed. Build it into the exit checklist.

Monday morning

  1. 01Trace one proposal form end to end.
  2. 02Close the branch group chat.
  3. 03Add data return to agent exit.

Questions, answered plainly

Are insurance agents responsible for customer data under DPDPA?

Where agents collect and handle data for an insurer, they generally act as its Data Processors, and the insurer remains responsible. Agreements should impose security and deletion duties.

What should insurers do when an agent leaves?

Require return or destruction of all customer personal data held by the agent, revoke access and document confirmation.

Sector · InsuranceYour agent's phone is part of your data estate.Read → Insurance · Deep diveThe claims file is the most sensitive file you own.Read → Insurance · Deep diveCollect for the risk, not for the file.Read →

Tell us where your data sits.We'll show you where the exposure is.

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