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DSG-compliant processes for claims and investigations
Clear steps for Swiss businesses to handle claims and internal investigations in line with the DSG: minimise data, log actions and issue deletion receipts.
Quick answer
To stay DSG‑compliant, collect only necessary personal data, log each step and issue deletion receipts. Define purpose, legal basis and retention periods; record accesses and decisions; and give affected persons a clear contact for enquiries.
What DSG compliance means for claims
DSG compliance means processing personal data for a clear purpose, having a legal basis and respecting rights. For a claim, the purpose is resolving the issue and serving the customer. Only record fields needed to investigate and close the claim.
Data minimisation: what to collect
Before storing anything, ask if name, order number or a photo are required. Record only data that supports the investigation. Avoid extra details like health data or unnecessary identifiers. Use pseudonyms or internal case numbers when feasible.
Logging: what to record and how long
Log who accessed or edited data, when and why. Note decisions, communications with the customer and deadlines. Retention periods should match purpose and legal rules. Define deletion schedules per data category and review them regularly.
Deletion receipts and proof
When you delete personal data, issue a deletion receipt listing what was removed, the date and the legal basis. Keep the receipt itself for audit purposes, but do not reconstruct the deleted personal data.
Technical and organisational measures
Control access, encrypt sensitive fields and protect endpoints. Train staff on minimal data collection and correct logging. Assign clear roles for claims handling and data protection responsibilities.
Handling access and objection requests
Respond to requests promptly and clearly. Explain what data you process, why and how long you retain it. On objections, document the review and outcome. Use standard templates to ensure consistent replies.
Frequently asked questions
Can I store photos of damage without consent?
Yes, if the photo is necessary to process the claim and you have a legal basis such as contract performance. Record purpose and retention. Avoid including unrelated personal items in images.
What should a deletion receipt include?
A deletion receipt should state the data categories deleted, the deletion date, the deletion method (e.g. secure erase) and the responsible person. Retain the receipt only, not the deleted content.
How do I set retention periods?
Set retention periods by purpose and applicable law. Create internal retention rules and review them periodically. For example, customer correspondence can have shorter retention than accounting records.
How strict should access rights be?
Limit access to the minimum necessary for each role. Use role-based access control and log exceptions for accountability.