Data protection requirements in the visa outsourcing sector are being reshaped by rapid technological advances, the vast possibilities offered by artificial intelligence, and the adaptation of regulatory frameworks to new digital capabilities. In a field closely connected to national and internal security, where organisations process highly sensitive identity, biometric, and travel data, these transformations are elevating expectations around safety, compliance, and operational resilience.
The convergence of data privacy governance and cyber security
Personal data is becoming increasingly digital. International travel and border processes now rely heavily on electronic registration and identity verification. A key example is the EU’s Entry/Exit System (EES), introduced in October 2025, which enables the systematic electronic registration of non-EU travellers entering the Schengen Area for short stays. Beyond this, visa application procedures themselves are becoming ever more digitalised, with online application forms, electronic document submission, and – in some cases – remote biometric enrolment.
Read our article Digital transformation in visa processing
With this increasing digitalisation comes new requirements in terms of information management and cyber security. Indeed, the security of the underlying information infrastructure for visa application management is becoming an absolutely critical component of legal compliance and operational integrity.
In this context, organisational maturity on cyber security is a key differentiating factor. To formalise this maturity, a structured information security management system is essential. Key ISO certifications such as ISO 27001 for information security and ISO 27701 for privacy management – issued by a renowned, internationally accredited certification body – provide independent assurance that controls, governance frameworks and operational processes meet internationally recognised standards. A strong Bitsight cyber security rating is another important marker of performance, demonstrating a robust vulnerability management approach, heightened network security, and incidentresponse readiness.
Balancing compliance with EU GDPR rules and local data protection laws
Public debate is intensifying around government access to personal data, biometric databases, and international data sharing. For organisations such as visa outsourcing companies, operating across multiple jurisdictions, there is a dual requirement:
- to meet the GDPR’s stringent standards when processing data on behalf of European authorities, and
- to comply with local dataprotection laws in countries where data collection is actually taking place.
In these local jurisdictions, organisations are often required to rely on explicit consent for personal data collection, even when it is not always the most operationally efficient or conceptually appropriate basis for highly regulated, securitydriven processes.
This dual compliance environment demands robust legal governance, careful assessment of crossborder data flows, and contractual structures that ensure alignment between European and local regulatory expectations.
AI governance: a question of privacy, not just technology
As organisations increasingly adopt AI-powered solutions for customer support, document triage, fraud detection, and quality assurance, European regulation is tightening accordingly. The EU AI Act, which entered into force on August 1st 2024, has accelerated expectations around:
- data minimisation and lawful data sourcing,
- transparency and explainability requirements,
- human oversight of automated decisionmaking processes,
- risk assessments for the most sensitive AI applications, particularly in bordermanagement contexts.
For visa outsourcers, this makes it essential to establish a robust data governance framework before deploying any AI-enabled solution. Clear policies on data collection, access control, retention, and deletion must be put in place, alongside thorough risk assessments and defined human oversight of any AI-assisted decision-making processes.
Read our article: AI in cyber security: a new era in government visa services
The importance of “privacy and security by design”
Leading organisations are responding to the challenges set out in this article by embedding “privacy and security by design” into the way their services are designed and delivered:
- collecting only what data is strictly necessary for the service,
- limiting access by role,
- encrypting data end-to-end,
- strengthening supplier controls, and
- applying privacy-enhancing techniques where feasible.
For visa outsourcing companies, these developments are not simply about meeting regulatory requirements. They reflect a broader shift towards greater accountability, operational resilience, and transparency across the entire visa journey. By proactively aligning privacy, cyber security, and data governance practices, service providers can build lasting trust with applicants, government partners, and stakeholders, while positioning themselves as reliable, future-ready partners in an increasingly digital travel and identity ecosystem.
Ultimately, as Data Privacy Week invites us to reaffirm the importance of responsible data stewardship, our commitment remains clear: to combine legal rigour, technological innovation, and operational integrity, to deliver services that are both secure and human‑centric, in an increasingly complex and interconnected world.
Article written by Aurélie Naudé,
Chief Legal & Compliance Officer