GDPR & Trust Administration: Data Protection Obligations for Trustees

Trustees must now ensure full GDPR compliance when managing beneficiary data. New guidance clarifies consent requirements, data transfer rules, and liability under recent EU enforcement actions.

Trustees should audit their data handling practices immediately, with particular attention to information shared with investment managers and offshore administrators.

Disclosure requests from beneficiaries increasingly arrive framed as subject access requests. The two regimes overlap but are not the same, and the response should address both.