We have been reporting to credit bureaus the same way for years. Is that no longer enough under Law 21.719?
Reporting to a rating agency is still possible, but you must now be able to support the lawful basis for that transfer and have it formalized with the third party. Historical continuity does not equal compliance: the law requires you to demonstrate why you process and share each piece of financial data, not just that you have always done so.
A customer asks us to explain how we calculate their scoring. Are we required to respond?
ARSOP rights extend to credit profiling. Individuals can access the data used, request its rectification, and object to certain processing. You do not need to reveal your model, but you do need traceability: which data feeds the scoring, for what purpose, and under what lawful basis, so you can respond on solid grounds.
We have customer data spread across many systems. Where do we start?
With the inventory. Before any policy, we map where each piece of financial data lives, which systems and providers touch it, and where it is transferred. That data processing record is the basis for establishing lawfulness, prioritizing the highest-risk flows, and responding in an orderly way to an ARSOP rights request or a breach.
Has the entry into force of Law 21.719 been postponed?
No. The legal date in force is December 1, 2026. A bill before the Senate (Bill 18.623-07) proposes moving it to December 1, 2027, but that would only change if it is passed and published in the Diario Oficial.
How much does the initial diagnosis cost?
The initial diagnosis is free. It is a 30-minute meeting to review where you stand against the law and agree on next steps. If you need a full analysis, we do it in the comprehensive assessment.
How long does a full implementation take?
It depends on size and scope. The comprehensive assessment takes about 21 business days. Implementation takes 1 to 4 months for an SME solution and 3 to 6 months for an enterprise one. That is why it pays to start early.
What fines does Law 21.719 provide for?
Up to 5,000 UTM for minor violations, 10,000 UTM for serious ones and 20,000 UTM for the most serious (article 35). If a company that is not a smaller enterprise repeats a serious or most serious violation, the fine can reach 2% or 4% of its annual revenue.
What can the Agency audit?
The Personal Data Protection Agency can review your legal bases, the record of processing activities, the handling of ARSOP rights, breach management and compliance documentation.