Over the past year, a spate of personal information leakage incidents in Korea has highlighted the importance of privacy compliance in Korea. To address this area of concern, the Personal Information Protection Commission (the "PIPC"), Korea's primary privacy regulator, also recently announced a series advance compliance inspections, formal investigations, and sanctions across consumer-facing industries such as food and beverages.
To help companies in Korea prepare, particularly those in the food and beverage ("F&B") sector, we provide this update on privacy regulatory trends and key risks.
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Result of a large-scale survey on the F&B sector
In February 2026, after conducting an investigation 10 restaurant reservation platforms and franchise companies, the PIPC imposed administrative penalties/fines totaling approximately KRW 1.68 billion, along with other sanctions for violations of Korea's privacy law, the Personal Information Protection Act (the "PIPA"). These violations included failure to destroy personal information and collecting the personal information of children without consent from legal representatives.
Such enforcement activity demonstrates the PIPC's focus on protecting the vast amount of customer data held by the entities including those operating in the F&B sector, as well as the PIPC's efforts to strictly examine compliance with the strict obligations mandated by the PIPA.
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Investigations Expand into the F&B Industry
With the PIPC's stated focus on consumer-facing sectors, the F&B industry is highly likely to remain on the PIPC's radar, particularly given the enormous amount of personal information processed by businesses operating in this sector. Although the focus of the aforementioned PIPC's investigation has been the digitalization of personal information by the F&B industry, including kiosks, remote reservations, and app order systems, the F&B industry is expected to remain part of the PIPC's enforcement focus in the future. For example, PIPC's 2026 priorities specifically include "businesses that process personal information on a large scale," a category that encompasses most major F&B brands regardless of whether they were previously audited for specific digital tools
Accordingly, even companies that underwent inspections last year are advised to remain vigilant given the larger net of the PIPC's focus. Businesses within the F&B sector that process significant amounts of personal information are advised to take preemptive measures by establishing a regular compliance system, rather than handling matters on an issue-by-issue basis.
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Types of Privacy Violations within the F&B Industry
Given the PIPA's stringent and specific technical requirements for data processors, violations of PIPA varied; examples include:
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Potential third-party exposure of order and customer data due to insecure API integration between online platforms and in-store systems;
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inappropriate consent procedures, such as requiring marketing consent as a mandatory condition for registration or ordering, or restricting the use of services for users that fail to consent to such optional consent;
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when providing large amounts of customer information to delegatees (third parties handling data processing functions on behalf of the data controller, such as delivery platforms, marketing agencies, and call centers), neglecting management and supervision of the delegatee, such as not inspecting the implementation of technical and managerial protection measures;
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failing to obtain consent of legal representatives for processing the personal information of children under 14 years of age; and
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Failing to implement key technical and managerial safeguards (e.g. neglecting periodic usage notifications required for data controller who processes large-scale data, failing to maintain access records, continued storing of personal information after its purpose or retention period expired)
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Need to Inspect Privacy Compliance
Given the PIPA's very specific requirements, particularly those relating to the technical and managerial requirements on data controllers to ensure the protection of collected personal information, companies within the F&B industry are advised to thoroughly examine whether the internal policies and practices meet the unique requirements under Korean law. Compliance with other regulations, such as the General Data Protection Regulation ("GDPR"), may not be enough.
In particular, the PIPC is closely reviewing whether cross-border transfers of personal information are compliant with the PIPA. Accordingly, we recommend that companies conduct an internal audit of its practices on the collection and use of personal information—including technical security inspections and legal review of key documents—to ensure compliance with the PIPA.
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