Regarding crew illness and injury claims, the Clubs will often be the Shipowners’ employers’ liability insurers and in such cases it will be necessary for the shipowner to provide the crewmembers with notice that their personal data may be shared with its insurers and other third parties.


The Japan Club mentioned:

We expect that for the majority of our Members, their crew contracts and collective bargaining agreements (CBAs) will either not contain data protection clauses/notices or will need updating. We would therefore ask Members who fall within the scope of GDPR to ensure that they provide their crewmembers with the necessary notice.

Furthermore, the Club called operators to include in the notice the following provisions dealing with injury and illness claims:

  • What information is being processed: Personal and sensitive data about the crewmember’s identity, health, illness and injuries. Financial information.
  • Why is it being processed: To help with medical treatment and insurance claims.
  • On what legal basis is it being processed: To protect interests of the individual, perform the employment contract and respond to any claim, comply with legal or statutory obligations or  provide insurance.
  • Who it may be transferred to: Insurance companies, insurance brokers, health facilities and entities.
  • How long will it be kept for: Consideration should be given to the length of employment, limitation periods and other relevant factors.