"US plan administrators may need to comply with the Data Privacy Regulation if the plan administrator gathers, processes, or has another entity gather or process personal data of individuals in the EU and it is determined that the processing is related to the offering of goods or services to EU residents.... [P]rocessing data in connection with the offering of pension or welfare benefits to EU residents could be deemed to be in connection with the offering of services ... [It] appears likely that administrators of both pension and welfare plans will be deemed to gather or process some personal data if any plan participant or beneficiary resides in the EU."

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