Canadian Lawyer InHouse

June/July 2021

Legal news and trends for Canadian in-house counsel and c-suite executives

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Page 26 of 35 25 "This data-mapping exercise is to make sure you have visibility on exactly what types of personal information is collected and how it's shared within the business, with service providers and outside the company to make sure they can adapt internal processes procedures and update their external-facing policies," says Gratton. Tighter rules will bring new requirements when outsourcing personal information, so maintaining an inventory of service providers that may be processing this information will be critical, Gratton says. There is also a requirement under Bill C-11 to document the purpose of all data. "Regulators want to make sure that businesses are quite transparent as to what they are doing," says Gratton. "Sometimes, the data-sharing arrangements that you have with service providers or as a consortium of a few businesses can become quite complex." It is essential for in-house counsel to raise awareness to ensure that specific projects that warrant a privacy impact assessment are escalated to the privacy team right from the start, not after making business decisions, says Gratton. Schober says problems sometimes arise when organizations onboard new technology without informing in-house counsel and, therefore, miss doing a privacy impact assessment. Given a recent influx of new telehealth services for employees amid the pandemic, employees must ensure that foreign health service providers adapt their processes for Canadian privacy laws. "A lot of health service providers are coming from the U.S. It's important to review agreements and assess these new vendors and ensure the platforms are managing sensitive health information of employees appropriately for Canadian privacy laws," says Schober. "If companies have already done risk assessments pre-pandemic, a critical thing to do would be dust off that risk assessment and consider whether risks have changed in terms of type and magnitude." Suzanne Morin, Sun Life

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