Privacy and GDPR in the Utrecht Personal Injury Fraud Register

The personal injury fraud register in Utrecht balances fraud prevention with privacy rights under the GDPR, particularly relevant for local traffic accidents and employment claims. Personal data such as name, BSN and claim details from Utrecht cases are processed on the basis of 'legitimate interest' (Article 6 GDPR). Insurers in the Utrecht region must conduct a DPIA for high-risk processing, taking into account the high incidence of injury claims at the District Court of Midden-Nederland. Data subjects have the right to information (Articles 13-14), access (Article 15), rectification (Article 16) and erasure (Article 17). The CFEL, active in Utrecht, acts as the controller and publishes a privacy statement. Data sharing with Utrecht police or FIOD requires a strict necessity test. Complaints are filed with the Dutch Data Protection Authority (DPA), which can impose fines of up to 20 million euros. Case law from the District Court of Midden-Nederland, comparable to CBF cases in Amsterdam, requires minimal data and short retention periods for Utrecht registers. Automatic inclusion is prohibited; a 'reasonable suspicion' is essential, for example in suspicious bicycle accidents in the city. Victims from Utrecht can claim damages for data breaches via the sub-district court. The NVV has a code of conduct for compliant use in a provincial context. Experts warn against over-retention in busy regions like Utrecht, which is disproportionate. Transparency regarding algorithms in fraud scoring is mandatory under the emerging Algorithm Transparency Act, with a focus on local claim patterns.