Personal Information Protection Rules | Comprehensive Review of Customer Center Outsourcing Structures and the Growing Need for Personal Information Protection Consulting

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.

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

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.

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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