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The Superintendence of Insurance and Reinsurance of Panama (“SIRP”) issued Agreement No. 5 dated July 17, 2025, which was published on August 5, 2025, in the Official Gazette (the “Agreement 5”), and which establishes new obligations for insurance sector participants in Panama regarding personal data protection:
- This agreement applies to all insurance companies, sales agents, reinsurers, insurance brokers, sales executives, or any other regulated entity that processes, stores, or transfers personal data of insurance consumers or policyholders.
- The agreement establishes a 90-calendar-day period, starting from its effective date, for regulated entities to comply with its provisions.
In addition to the obligations set forth in Law 81 of 2019 and Executive Decree 285 of 2022, Agreement 5 establishes, among other things, the following:
- Mandatory appointment of a personal data protection officer, who must work within the respective entity.
- Mandatory notification to the SIRP of any security incident.
- Mandatory maintenance of a database registry, which must be documented in writing, by any electronic means, and be available to the SIRP.
- Definition of publicly accessible or open-source information.
- Incorporation of privacy policies or accessible service terms.
It is important to note that non-compliance with these provisions may result in administrative sanctions and fines imposed by the SIRP.
For more information on this subject, please contact our legal team: