In January, the federal Privacy Commissioner released Guidelines for Processing Personal Data Across Borders (PDF Copy of Guidelines). These guidelines set out the Commissioner’s view of how the Federal Personal Information Protection and Electronic Documents Act (PIPEDA) will be applied to transfers of personal information across borders. It’s worth noting that the document does not review obligations for public sector entities.  Transborder transfers of personal data would include transfers across provincial as well as national boundaries since PIPEDA does not distinguish between domestic and international transfers of data.  So if your organization is outsourcing data handling to a service provider in another province or another country, these guidelines will be applicable.

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