European Regulation Was a Massive Undertaking for VvAA, but Legal Manager Provided the Solution

Digital resilience is a major concern, especially for organizations such as VvAA, which supports healthcare professionals in several areas, including as a non-life insurer. Since January, VvAA has been required to comply with new European legislation. Preparing for it was a massive undertaking, but Legal Manager was able to provide the support the organization needed.

In-house counsel Coert van Driel and Tjitske Hoek, together with paralegal Mandy Vroon and colleagues from the Risk Management, IT, Security, and Compliance departments, have been through an intensive period.

Financial organizations such as VvAA are now required to comply with the Digital Operational Resilience Act, or DORA, a regulation designed to improve the management of IT risks and strengthen resilience against cyber threats. This meant that additional contractual provisions had to be agreed upon with suppliers, while a large volume of data also had to be collected.

“Approximately 12,000 European companies are required to submit a register of information,” Coert explains. “Regulators then perform a range of data analyses to identify concentration risks. We now know from experience that submitting that register correctly is no easy task.”

VvAA had to provide metadata for 65 of its IT suppliers. Each agreement involved 94 data fields, ranging from the Legal Entity Identifier code to information about subcontractors.

“It was a hell of a job,” Coert says. “We suddenly went from being lawyers to data entry specialists, with a team of only three people.”

Tjitske adds: “I can review the work and understand what is happening, but it is simply not my area of expertise. On top of that, we still had many other responsibilities to manage.”

Additional Support Was Needed

“We initially explored whether we could use AI for the project,” Coert says. “There are tools that can analyze contracts in a contract management system and extract the relevant data. However, the process proved too complex and produced too many errors. We realized that we needed additional people to help us.”

“You could hire external attorneys, but they are far too expensive for this type of work. That would not make sense. That is how we ended up working with Legal Manager.”

Starting in early 2024, Mandy took the lead in the collaboration.

“We first adapted a template from the Dutch Association of Insurers so we could use it as effectively as possible,” the paralegal explains. “Each agreement required an addendum containing additional provisions. That meant preparing a separate addendum for every agreement. Legal Manager was able to generate those addenda for our IT suppliers using the templates. The process went very smoothly.”

“We kept communication direct and informal through chats and video meetings,” Mandy says. “Sil Vogel coordinated everything very effectively, and I mainly worked with Nassim Aoulad Haddou. We agreed on the approach together, after which they could complete the work whenever it best fit Legal Manager’s schedule.”

“We tracked changes in an Excel spreadsheet so everyone could easily see what still needed to be added to the register. We use Legisway ourselves, and Legal Manager has extensive experience with that system, which made the process even easier.”

Strong Digital Skills

The Legal Manager team was able to work on VvAA-issued laptops, giving them remote access to all the necessary systems.

“That worked perfectly,” Coert says. “We also created a separate environment in Teams, so we could see exactly when someone was online or had worked on a particular task. It is clear that they have very strong digital skills.”

“They work with students and recent graduates, but those team members still have a solid understanding of the contents of an agreement.”

After an intensive summer, VvAA began to see the first results of the collaboration.

“We volunteered to participate in a dry run,” Mandy says. “That gave us a better understanding of exactly what was expected and allowed us to determine whether we were on the right track.”

“Receiving the feedback was naturally a little nerve-racking, but the results were much more positive than expected. From there, Legal Manager continued to move the project forward.”

Most of the work has now been completed, and Legal Manager’s support team has finished its assignment. Coert notes that the project was also structured in a way that will benefit VvAA in the future.

“DORA is here to stay. We will have to submit this data for every new agreement. The good thing is that Legal Manager created a clear manual for us. We now know exactly how to approach the process and which areas require particular attention.”

“Another major advantage is the wide range of work they can handle,” Tjitske adds. “You can also bring them in when completing an acquisition or selling part of your business.”

“They are approachable and enthusiastic, professional while still being informal. That suits us well. Our collaboration has ended for now, but Legal Manager is definitely on our list for the next time we need support.”