The Data Privacy Compliance Cloud Privacy Check (CPC/DPC) is an
initiative by a group of 44 lawyers from 32 different countries.
The project aims to clarify the requirements under the increasingly
Data Protection laws which may vary between Member States. The
CPC/DPC also makes it possible to compare and extract the
differences between every Member State's data privacy
requirements. The CPC/DPC also includes country by country
The Cloud Privacy Check process is simple and straightforward:
the check is made up of four steps which outline certain
requirements depending on the answer to the questions. The
questions posed are the following:
Does the transaction include any personally identifiable
Does a third party involved in the setup of the cloud process
have access to personal data?
Does the data leave the jurisdiction of the customer?
Is the cloud provider using subcontractors in the setup?
In the first two questions of the Cloud Privacy Check it can be
ascertained whether the setup in question leads to any
data protection obligations. In questions three and four, the
compliance obligations will be outlined.
Miroslav Chlipala, one of the lawyers who contributed to this
project, commented on the incoming General Data Protection
Regulation, which will change the current data privacy
requirements: "We will integrate the new European Data
Protection Regulation, answer the most common questions asked by
companies, and continue to inform about the most important topics
comprehensibly and free of charge."
Earlier this month, on 3 February 2017, the Government of Bermuda confirmed its resolve to appoint a Privacy Commissioner to ensure that guidance to organisations can be provided prior to the legislation being fully implemented.
Given the private nature of banking services and as banks serve the vast majority of the public, the banking industry is one of the private sectors in Hong Kong for which the Hong Kong Privacy Commissioner receives most complaints.
A Bill to protect the personal information of Bermuda residents – the Personal Information Protection Act (PIPA) – has been passed in the House of Assembly.
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