The Canadian Privacy Law Blog: Developments in privacy law and writings of a Canadian privacy lawyer, containing information related to the Personal Information Protection and Electronic Documents Act (aka PIPEDA) and other Canadian and international laws.

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The author of this blog, David T.S. Fraser, is a Canadian privacy lawyer who practices with the firm of McInnes Cooper. He is the author of the Physicians' Privacy Manual. He has a national and international practice advising corporations and individuals on matters related to Canadian privacy laws.

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Please note that I am only able to provide legal advice to clients. I am not able to provide free legal advice. Any unsolicited information sent to David Fraser cannot be considered to be solicitor-client privileged.

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The views expressed herein are solely the author's and should not be attributed to his employer or clients. Any postings on legal issues are provided as a public service, and do not constitute solicitation or provision of legal advice. The author makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the information contained herein or linked to. Nothing herein should be used as a substitute for the advice of competent counsel.

This web site is presented for informational purposes only. These materials do not constitute legal advice and do not create a solicitor-client relationship between you and David T.S. Fraser. If you are seeking specific advice related to Canadian privacy law or PIPEDA, contact the author, David T.S. Fraser.

Wednesday, September 05, 2007

If you touch personal information, act like a privacy officer 

Thanks to David Canton for leading me to this interesting article from IT Business. It discusses the recent breach in which unencrypted health information on a portable hard drive was lost in Toronto's airport. Looking at the issue from a practical angle, it concludes that all employees who touch personal information have to take responsibility for it.

IT Business: Everyone's a CPO: Why privacy needs to spread across every line of business

...Departmental executives need to do a couple of things. First, they need to perform an inventory on the devices they personally own but which may be used for work. What level of security is already in place and what might need to be upgraded? Are there technologies that could be added to help easily recover a device if it goes missing for some reason? Are there organization-wide guidelines or procedures with which personal devices need to comply before they can be used for work purposes? This is where a dialogue with IT should probably begin, and it may lead some IT managers to reject requests that such devices be able to access a corporate network.

A potentially bigger challenge will be for line of business executives to think in "big picture" terms of what kind of data they are managing, and what kind of responsibilities they have towards protecting the privacy of that information. We usually tackle these cases by looking at what kind of safeguards IT departments or senior management could have put in place from the beginning. As time goes on, the focus will be much more on what individual employees are doing to bolster those safeguards. No one is merely a VP of marketing, finance or HR anymore. If you touch customer or employee data in any way, shape or form, you're a chief privacy officer, too.

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