Personal data is an asset.  It seems obvious as to its ownership, but it’s complicated. When you dig into it, the ownership line is blurry.  From Amazon, Facebook, Google, to your recordkeeper and payroll provider, they all possess increasing amounts of data about you.  The focus thus far has been on privacy and confidentiality.  The question is, for those service providers with rights to your data, how far can they stretch the use of your data beyond the original intent?  Within the context of a retirement plan, how should plan fiduciaries protect us and what should they require of each service provider?  Is personal data also a plan asset and should it be subject to ERISA protection?

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