Curaçao

Curaçao's data protection regime rests on a single omnibus-style statute — Ordinance No. 84 of 4 September 2010 Laying Down Rules on the Protection of Personal Data — but the supervisory authority the Ordinance itself creates, the Data Protection Board, has never been stood up. This is the textbook 'statute enacted, DPA not operational' pattern: the law is in force, yet there is no functioning regulator to receive filings, hear complaints, or issue guidance. Registration/notification duties, DPO appointment duties and breach-notification duties are all absent from the text.

No Curaçao-specific text on enumerated lawful bases, consent thresholds, special-category rules, or pseudonymisation/anonymisation safe-harbours was retrieved in this research pass. Professional summaries indicate the Ordinance follows the Dutch implementing-act model (itself derived from the EU data protection directive era), which would imply an analogous lawful-basis and sensitive-data structure, but this was not independently verified against the Curaçao statutory text, which is only available in Dutch.

No Curaçao-specific detail on access, rectification/erasure, restriction/objection, portability, or statutory response deadlines was retrieved in this research pass; the underlying Ordinance text is Dutch-only and was not independently parsed article-by-article.

Professional legal-research sources are explicit that the Curaçao Ordinance does not set out DPO-appointment requirements or data-breach-notification requirements. Accountability/DPIA, ROPA, joint-controller, general security-measures and retention/disposal specifics were not independently retrieved.

The Ordinance affirmatively regulates cross-border transfers, restricting transfer of personal data to countries assessed as providing adequate protection. No confirmed adequacy decisions received from or granted to other regimes, SCC/BCR uptake, formal TIA requirement, or data-localisation mandate were located for Curaçao in this pass.

Curaçao is a member of the Caribbean Financial Action Task Force (CFATF) and is viewed by international supervisory bodies as having limited effective AML/tax-enforcement measures, a fact relevant to financial-sector data-sharing and customer due-diligence practices. No CW-specific health, telecoms/ePrivacy, employment, credit-scoring, education, or insurance sector DP overlays were located in this pass.

No Curaçao-specific cookie/tracker consent regime, dark-pattern prohibition, opt-out-signal recognition, clean-room rules, cross-context-advertising rules, or direct-marketing consent/suppression rules were located in this research pass.

No Curaçao-specific profiling-restriction, ADM-transparency, AI-risk-assessment, biometric-regime, genetic-data-regime, or state-surveillance-carveout text was located in this research pass.

No Curaçao-specific age-of-consent, parental-consent mechanism, minor-profiling ban, education-setting rule, or dependent-adult protection was located in this research pass.

Because the Data Protection Board provided for under the Ordinance has never been established, there is no dedicated data-protection regulator currently exercising investigative or enforcement powers under the Curaçao Data Protection Ordinance. No confirmed DP-specific enforcement activity, regulator funding/capacity data, collective-redress mechanism, private-right-of-action, or 180-day development was located for this jurisdiction. A 2021-dated Public Prosecutor penalty item surfaced in search but its substantive connection to the Data Protection Ordinance could not be confirmed from available content, so it was not cited as a claim.