The Cayman Islands Data Protection Law
The Cayman Islands Data Protection Law became effective September 30, 2019. The Cayman Islands Data Protection Law (“DPL”) applies to any investment advisor who provides investment advice to a Cayman Islands-domiciled hedge fund. The law makes investments advisors “data controllers” whereas Cayman Islands hedge funds are considered “data processors.” The practical effect of the DPL is that hedge funds must update their subscription agreement to include specific data privacy language that comports with the DPL. Under the DPL, hedge fund administrators are also required to include DPL-specific language in their administration agreement.
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