Data Management: Considerations for Integrating Compliance Requirements At Home and Abroad. Toronto, Ontario June 14, 2005

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1 Data Management: Considerations for Integrating Compliance Requirements At Home and Abroad Toronto, Ontario June 14, 2005

2 Outsourcing Update: New Contractual Options and Risks Lisa K. Abe June 14, 2005

3 Introduction Outsourcing involves the strategic use of outside suppliers to perform business activities in order to achieve efficiencies and other benefits Often involves transfer of data to a third party for processing Many recent legal developments affecting data transfer in outsourcing, e.g. with respect to: Privacy E-Commerce Securities Cross-border issues

4 Introduction Topics covered: Part I - Recent legal developments affecting data management in outsourcing New options for dealing with each of them in the outsourcing contract Part II Implications of data management on choosing the right service provider/outsourcer Handout: A checklist of terms for the outsourcing agreement to deal with data management issues and risks

5 Part I Recent Legal Developments Affecting Data Management in Outsourcing

6 Recent Legal Developments Affecting Data Management in Outsourcing Recent development in privacy Recent developments in e-commerce Recent developments under securities laws, stock exchange rules and regulatory guidelines Recent cross-border developments

7 Recent Developments in Privacy Privacy Commissioner of Canada, August 2004: PIPEDA and its Impact on e-commerce and e-economy speech at Transcend Business Services IT & Privacy Symposium, August 25, 2004, Ottawa, ON Businesses have an obligation under PIPEDA to ensure that personal information sent out for processing is protected under contract from inappropriate use or disclosure, the same as if it were processed in-house.. Companies that are subject to PIPEDA or similar provincial legislation must comply with the legislation. The Act requires personal information to be protected by security safeguards appropriate to the sensitivity of the information, including when it is transferred across borders.

8 Recent Developments in Privacy Organization is responsible for personal information under its control or custody, including information that has been transferred to a third party for processing and shall use contractual or other means to provide comparable level of protection while information is being process by a third party - PIPEDA Schedule 1, Clause Processing undefined Scope unclear, but clearly more than automatic/electronic Privacy Commissioner of Canada seems to contemplate administration or analysis

9 Recent Developments in Privacy Determine which privacy laws apply Privacy obligations will likely apply to both customer and outsourcer because have control or custody Customer will be liable if outsourcer breaches the law Each party will want warranties that the other has complied with all applicable privacy laws before data is transferred, and covenants that reflect what the other party has to do to continue to comply

10 Recent Developments in Privacy Do you need to obtain consent to provide data containing personal info to outsourcer? Disclosure vs. transfer agency concept PIPEDA Case Summary #145 re outsourcing contract for management of railway employees Not a disclosure because management company was acting on the railway s behalf in managing the railway employees Information was transferred not disclosed therefore consent of individual employees not required

11 Recent Developments in Privacy Ontario Superior Court case: Considered agency concept in situation of video surveillance taken by private investigator Private investigator found to be acting as agent of individual: Ferenczy v. MCI Medical Clinics, (April 14, 2004) Disclosure/release to third party requires consent Transfer, where sharing with agent, considered in possession or custody of customer and should not need separate consent Be cautious when relying on agency approach

12 Recent Developments in Privacy Do you need to obtain consent to have outsourcer collect data containing personal info on behalf of customer? Customer may disclose and outsourcer may use/disclose personal information collected from or on behalf of customer without consent if: Individual consented to the collection of the personal information by the customer; and Personal information is used/disclosed solely for the purpose for which the information was originally collected, and to assist outsourcer to carry out work on behalf of the customer

13 Recent Developments in Privacy Tip: Determine which privacy laws apply Customer must have obtained consent to collect/use/disclose personal information for identified purpose Manage the data transfer: Transfer to outsourcer only that data which is necessary for processing and which is consistent with the purposes identified by the customer collecting the information, and not for any other purpose

14 Recent Developments in Privacy In the outsourcing contract: Specify which party shall be responsible for obtaining the necessary consents Customer should retain control over data management and ensure outsourcer complies with all privacy requirements, including responding to and complying with to access requests, correction requests within time limits and protecting the personal information Specify protection, security and segregation of the personal information Require appropriate notices to customer of requests for access, corrections, complaints or inquiries (including court orders for disclosure) Include warranties and covenants that reflect applicable privacy laws compliance, during term of contract, transitioning and thereafter

15 Recent Developments in Privacy In the outsourcing contract: Restrict outsourcer to use data only for specific purposes of the transfer Prohibit subcontracting, assignment (without consent) Require outsourcer to have pre-approved agreements with employees, subcontractors, assignees Deal with limited/authorized access, use, disclosure, retention periods, disposal, audit and inspection rights and training of all relevant employees Require compliance with applicable laws and customer privacy, security and metadata policies Consider other provisions such as termination, survival, remedies, indemnities

16 Recent Developments in e-commerce Federal and most provincial governments have passed legislation establishing that electronic documents are generally functionally equivalent to their paper counterparts provided that, among other matters, the electronic documents are kept adequately secure PIPEDA and the various provincial and territorial e- commerce acts set out legal requirements for documents to be retained electronically

17 Recent Developments in e-commerce Under PIPEDA, new Secure Electronic Signature Regulations that define a digital signature and what is required, were passed in February 2005 Canadian General Standards Board is currently developing a new standard entitled Electronic Records as Documentary Evidence (the Electronic Records Standard ) that establishes guidelines for developing, maintaining and operating programs to create, receive, capture, store, retrieve, deliver and dispose of electronic information including security measures for electronic documents, in order to maximize the likelihood of admissibility as evidence in legal proceedings

18 Recent Developments in e-commerce In the outsourcing contract, ensure service provider: Implements required measures to ensure the integrity of electronic records, such that they will be considered functionally equivalent to their paper counterparts and therefore, sufficient to satisfy the customer s legal document retention requirements Uses secure electronic signatures, as defined by any regulations as applicable, in documents that need to be kept in their original form Uses reliable encryption techniques to support the integrity of the electronic record

19 Recent Developments in e-commerce In the outsourcing contract, ensure service provider: Complies with standards, to ensure admissibility into evidence, e.g. the Canadian General Standards Board s ( CGSB s ) National Standard for Microfilm and Electronic Images as Documentary Evidence (the Microfilm Standard ), which provides guidelines for, among other things, the use of scanned images of paper documents as evidence in legal proceedings

20 Recent Developments under Securities Laws, Stock Exchange Rules and Regulatory Guidelines Designed to protect investors and improve corporate governance Increased requirements to assess and disclose corporate governance practices and business risks and to certify internal controls

21 Recent Developments under Securities Laws, Stock Exchange Rules and Regulatory Guidelines CSA Multilateral Instrument (similar to US Sarbanes-Oxley Act of 2002 (SOX), discussed below) requires CEO and CFO certification of certain annual and interim filings re design and evaluation of disclosure controls and procedures, and design of internal controls over financial reporting, to provide reasonable assurances as to knowledge of material info and reliability of financial reporting applies to all Canadian reporting issuers other than investment funds adopted in all Canadian jurisdictions except British Columbia

22 Recent Developments under Securities Laws, Stock Exchange Rules and Regulatory Guidelines In contrast to SOX, MI does not: prescribe any specific policies or procedures that should comprise disclosure controls and procedures (DCP) currently left to management s judgment and will vary depending on the issuer; and require certifying officers to specify the contents of their evaluation of DCP, does not require officers to assess or report on the effectiveness of internal control over financial reporting (ICOFR) and does not require auditors to attest to or report on the certifying officers report

23 Recent Developments under Securities Laws, Stock Exchange Rules and Regulatory Guidelines CSA has recently proposed a new MI Reporting on Internal Control over Financial Reporting and revisions to MI in order to align Canadian requirements with SOX requires further disclosure of deficiencies and weaknesses in ICOFR MI will apply to all issuers except investment funds and venture issuers, and those issuers exempt from MI

24 Recent Developments under Securities Laws, Stock Exchange Rules and Regulatory Guidelines Consider whether outsourcing functions or systems could impact financial reporting or controls of a Canadian reporting issuer If so, CEO and CFO should be involved in the design and evaluation of such functions or systems and ensure that the appropriate processes are in place to support their certification of the information derived from the outsourced functions or systems

25 Recent Developments under Securities Laws, Stock Exchange Rules and Regulatory Guidelines In the outsourcing contract: design, development, testing and audit procedures, governance processes, meetings, reporting and dispute resolution processes should permit Customer CEO and CFO involvement and decision-making control

26 Recent Cross-Border Developments OSFI Guideline B-10 Outsourcing of FRFIs business activities, functions and processes Completion of a risk assessment Development of a process for determining the materiality of the arrangement Implementation of a program for managing and monitoring risks, depending on the materiality Ensuring the board of directors or principal officer receive sufficient information to enable them to meet their duties under the guideline

27 Recent Cross-Border Developments To the extent that a FRFI s outsourcing relationship involves the processing of certain information or data outside of Canada, a formal application may need to be made to OSFI to obtain an order permitting such data processing Health privacy laws and the recently-amended BC public sector privacy statute also contain restrictions on the transfer of personal information outside of the country

28 Recent Cross-Border Developments In the outsourcing contract: Consider retention of personal information in Canada Segregate any personal info from non-personal data Allow for involvement of board of directors or principal officers in the design, development and testing of outsourced systems and audit procedures, governance processes, meetings, reporting and dispute resolution processes, to permit assessment, management and monitoring of risks

29 Recent Cross-Border Developments US Sarbanes-Oxley Act of 2002 Since 2002, Canadian companies that are SEC registrants have been required to provide certification of financial statements filed with the SEC, similar to CSA MI , discussed earlier Consider whether outsourcing functions or systems could impact financial reporting or controls of an SEC registrant If so, CEO and CFO should be involved in the design and evaluation of such functions or systems and ensure that the appropriate processes are in place to support their certification of the information derived from the outsourced functions or systems

30 Recent Cross-Border Developments In the outsourcing contract: design, development, testing and audit procedures, governance processes, meetings, reporting and dispute resolution processes should permit Customer CEO and CFO involvement and decision-making control

31 Recent Cross-Border Developments U.S. Patriot Act May be disclosure of personal information to the FBI Orders may require corporation to disclose data held in US US corporation may reach into Canadian subsidiary to obtain records May not be any disclosure that such an order exists or has been complied with) Databases potentially subject to US secret searches Could compromise Canadian privacy rights and violate Canadian privacy laws

32 Recent Cross-Border Developments Practical Guidelines for dealing with U.S. Patriot Act: Obtain consent to personal information being stored or accessed from another jurisdiction, in order to minimize risk of violation of Canadian privacy laws in complying with US Patriot Act Consider retention of sensitive personal information in Canada Segregate any data that may be subject to disclosure In the outsourcing contract: Deal with potential conflicts with Canadian privacy laws Restrict cross-border data flow, require storage and processing in Canada Require outsourcer to isolate any data that may be subject to disclosure

33 Recent Cross-Border Developments U.S. Bureau of Industry and Security s regulation of exports and prohibited transactions, e.g. with persons on the Denied Persons List (DPL) Other lists that raise red flags or require licenses from US government In the outsourcing contract specify: Which party is responsible for screening or obtaining licenses, if applicable When and how often? Implications of replacing personnel that don t pass screening, e.g. cost, timing, knowledge transfer, training, qualifications, approvals of replacement personnel, etc.

34 Part II Implications of Data Management on Choosing the Right Service Provider/Outsourcer

35 Choosing the Right Service Provider Due Diligence Certified in accordance with one or more accepted information technology standard(s) Security practices HR security checks, training, enforcement of policies Privacy and confidentiality management practices Retention and destruction of data Physical and logical security of data Co-mingling with other persons data or sensitive personal data

36 Choosing the Right Service Provider Technology functionality levels of encryption, independent/dedicated servers, firewalls, organization Who owns the data servers, server farms and facilities Location of databases and processing facilities Back-up, disaster recovery Contractual arrangements with subcontractors Open/willingness to giving customer control

37 Conclusions Clear contractual terms can help reduce the risks of data management and legal compliance Data management is a joint responsibility Customer should have control of data management requirements and processes Include requirements in RFP process Parties should agree to policies and procedures and attach same as schedules to the outsourcing agreement

38 Conclusions Blanket general provisions, e.g. that outsourcer shall implement general industry standard security, confidentiality and privacy practices, are no longer sufficient Don t rely on governing law and without regards to conflicts of laws principles to solve problems raised by cross-border data transfer Data management touches on many terms throughout the outsourcing contract Get early involvement of experienced outsourcing counsel

39 Lisa K. Abe (416) Information Technology Practice Group (Toronto) This presentation contains statements of general principles and not legal opinions and should not be acted upon without first consulting a lawyer who will provide analysis and advice on a specific matter. Fasken Martineau DuMoulin LLP is a limited liability partnership under the laws of Ontario and includes law corporations.

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