ADGM Public Consultation on Special Categories of Personal Data

The Riffle

The ADGM Registration Authority has issued Consultation Paper No. 6 of 2025, proposing critical changes to how Special Categories of Personal Data can be processed—particularly in insurance and safeguarding contexts.

What's New?

1. Substantial Public Interest Rules Proposed

• New rules introduced to fill two key regulatory gaps:

  • Insurance & Reinsurance Data Use

  • Safeguarding Children and At-Risk Adults

• These rules clarify when and how sensitive personal data can be processed without consent, under substantial public interest grounds.

2. Legal Backing:

• A new clause Section 7(2)(k)(xii) allows ADGM to define additional public interest grounds by issuing rules.

Insurance-Related Processing (Without Consent)

Permitted when:

• It’s necessary for an insurance purpose, and

• The data subject is not directly affected (e.g., no actions or obligations toward the insured), and

• Consent cannot reasonably be obtained.

✅ Covers underwriting, claims handling, and compliance-related obligations.

Safeguarding Children and At-Risk Adults

Permitted when:

• Data is processed to protect from harm or neglect.

• The individual is:

  • Under 18, or

  • 18+ and "at risk" (needs care/support, cannot self-protect).

• Consent is not viable (e.g., in urgent or dangerous situations).

Who Should Care?

These updates affect:

• Licensed ADGM entities

• Insurance providers

• Schools, nurseries, universities

• Healthcare & care providers

• Data controllers/processors & legal advisers

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