CONTENTS
- 1. Background of the Personal Information Protection Rules Inspection and the Direction of Supervision
- - The Legal Framework, Reorganized around the “Outsourcing Structure”
- 2. The Structure of Legal Liability under the Personal Information Protection Rules
- - Main Inspection Items and Practical Issues
- - The Potential for Expansion of the Inspection Scope
- 3. The Importance of a Personal Information Protection Rules Control System
- - Response Strategies by Business Type
- - Assistance from Daeryun Law Firm LLP
1. Background of the Personal Information Protection Rules Inspection and the Direction of Supervision
On April 6, 2026, the Personal Information Protection Commission (hereinafter the "Commission") announced that, prompted by an incident in which a customer center agent made unauthorized inquiries into personal information and exploited it for criminal purposes, it would conduct an advance inspection under Article 63-2 of the Personal Information Protection Act.
This inspection will be carried out with a focus on five industries in which the outsourced operation of customer centers has become common, namely delivery, home shopping, online shopping, rental, and fixed-line telecommunications, and it is regarded as structural supervision examining the overall operation of businesses' personal information protection rules.
In particular, because the entire management and supervision system, including entrusted parties (call centers), is included within the scope of the inspection, demand for personal information protection consulting is also expected to grow.
The direct trigger for this advance inspection was an incident in which a customer center agent privately accessed customer information obtained in the course of duties and used it for a crime.
The Commission appears to have determined that this was a problem arising from structural vulnerabilities across access-authority controls and the overall management system for entrusted parties.
Customer center work, in particular, is characterized by the routine processing of sensitive everyday information such as customers' addresses, contact details, and usage records, and it is an area in which risk is concentrated because such work is frequently operated through external outsourcing.
Owing to these structural characteristics, the effectiveness of personal information protection rules is emerging as a key compliance element for businesses.
Because this inspection is aimed at preventive supervision in advance rather than at sanctions after a violation, there is also a possibility that it will expand into a continuous, standing inspection system going forward.
The Legal Framework, Reorganized around the “Outsourcing Structure”
The core of this inspection is whether the duty to take safety measures and the entruster's duty of management and supervision under the Personal Information Protection Act have been fulfilled.
In particular, where personal information processing is outsourced externally, liability for unlawful acts by an entrusted party's employees is, in principle, attributed to the entruster, that is, the business.
Accordingly, a business cannot be relieved of liability merely by concluding an outsourcing contract; it must be able to prove that it has in fact fulfilled its duty of management and supervision.
This legal structure means that a business's personal information protection rules must not remain a mere set of internal regulations but must function as an actual operational and control system.
In particular, access-authority management, account control, access-log management, and the education and inspection of entrusted parties are all key elements directly tied to legal liability.
2. The Structure of Legal Liability under the Personal Information Protection Rules
Legal Basis | Main Obligations | Practical Significance | Risk upon Violation |
Article 26 of the Personal Information Protection Act | Duties of contract, education, and supervision when outsourcing | Liability for an entrusted party's unlawful acts is attributed to the entruster | Administrative fine, corrective order |
Article 29 of the Personal Information Protection Act and its Enforcement Decree | Safety measures such as access authority, access control, and log management | Both technical and managerial protective measures are required | Penalty surcharge (up to 3% of revenue), criminal punishment |
Article 63-2 of the Personal Information Protection Act | Advance inspection and recommendations for improvement | Advance supervision can be converted into a subsequent investigation | Expansion into investigation and sanctions |
Main Inspection Items and Practical Issues
In this inspection, the key elements of personal information protection rules will be intensively reviewed, including the management of agents' access authority, the recovery of authority upon a change in duties, the prohibition of account sharing, access-log management, and the education and supervision system for entrusted parties.
In particular, the issue in practice is not “whether formal regulations exist” but “whether they are actually implemented”.
For example, even if a least-privilege policy exists, a violation may be found where excessive inquiry authority has in fact been granted, and a failure to immediately revoke the accounts of departing employees is likewise assessed as a major risk.
In addition, whether an anomalous-access detection system has been established, beyond the mere retention of access logs, is also expected to serve as an important inspection element.
Core Inspection Structure of Personal Information Protection Rules
Inspection Area | Key Control Point | Signs of Practical Risk | Matters to Verify During Inspection |
Access-authority management | Application of the least-privilege principle | Unnecessary customer information can be accessed | Whether role-based authority is designed and whether the scope of authority is appropriate |
Authority-change management | System for immediate revocation of authority | Residual accounts of departing or transferred employees | Time taken to revoke authority and the history of periodic review |
Account-operation management | One account per person principle | Account sharing and use of shared IDs | Account issuance and use policy and whether unauthorized sharing occurs |
Access-log management | Log generation and inspection | Inability to detect abnormal inquiries | Access-log retention period and the anomalous-conduct detection system |
Management and supervision of entrusted parties | Control of the outsourcing structure | Absence of control over outsourced personnel | Whether education, inspection, and the contractual safety measures are implemented |
The Potential for Expansion of the Inspection Scope
Although this inspection centers on five specific industries, the structure of processing personal information through customer centers commonly exists across various industries.
In particular, although the financial, platform, telecommunications, and medical sectors are already subject to a high level of regulation, they carry similar risks in terms of customer center operation structures, and the scope of inspection is therefore highly likely to expand to them in the future.
For example, in the financial sector, the Personal Information Protection Act and financial regulations apply in an overlapping manner, and platform companies likewise combine customer center operation with data processing structures, so that they may become subject to substantially the same regulation.
Accordingly, even where a business is not currently a direct target of inspection, this is a time when a proactive review of personal information protection rules as a whole is warranted.
Industry Group | Dependence on Customer Centers | Main Risk Types | Potential for Regulatory Expansion |
Delivery and distribution | Very high | Unauthorized inquiry into address and location information | Currently a direct inspection target |
Finance and insurance | High | Leakage of financial transaction and asset information | High potential for future expansion |
Telecommunications and platforms | Very high | Inquiry into subscription information and call records | Some are included as direct targets |
Public sector and medical | Medium | Access to sensitive information (health and civil complaints) | Phased expansion possible |
3. The Importance of a Personal Information Protection Rules Control System
This measure clearly demonstrates that personal information protection rules must operate as a control system that actually functions.
In particular, in external outsourcing structures such as customer centers, responsibility for personal information protection is not dispersed but rather expanded, so businesses must establish an integrated management system that also encompasses entrusted parties.
Ultimately, the core of personal information protection rules lies in operation and proof, and achieving this requires a systematic approach that combines technical, managerial, and legal elements.
Response Strategies by Business Type
Business Type | Key Risk Question | Response Direction |
Business operating directly | Can it prove the management and supervision of entrusted parties? | Systematize the records of contracts, education, and inspections |
Specialized call center entrustee | Can authority be separated by client company? | Multi-tier authority structure and log separation |
Business in a similar industry | What is the likelihood of becoming the next inspection target? | Proactive review of rules and application of standards |
Business operating globally | Can overseas outsourcing be controlled? | Requirements for overseas transfer plus evidence of substantive supervision |
Assistance from Daeryun Law Firm LLP
Personal information protection rules should be designed as a structure that can control risk in an actual operating environment.
In particular, where multiple stakeholders are combined, as in a customer center outsourcing structure, reviewing the overall management system through personal information protection consulting is crucial.
Daeryun Law Firm LLP comprehensively analyzes related statutes, including the Personal Information Protection Act, the Network Act (Information and Communications Network Act), and electronic financial regulations, to diagnose a business's personal information protection rules system.
In particular, it provides practice-oriented personal information protection consulting, ranging from reviewing outsourcing contract structures, to designing the management and supervision system for entrusted parties, to establishing access-authority and log management policies, to building internal audit and response systems.
Drawing on its experience in responding to personal information leaks and investigations, it also presents strategies that connect the advance inspection stage through to the investigation response stage, supporting businesses in reducing their legal risks.
In an increasingly stringent regulatory environment, personal information protection rules are a key element directly tied to corporate trust.
Daeryun (ranked ninth among law firms in Korea, based on 2025 value-added tax filings with the National Tax Service) will respond to the changing regulatory environment and provide practical legal advice and strategic response measures so that businesses can carry out their operations stably.
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