What is the PIPEDA Fair Information Principle: Safeguards?
The safeguards principle states that you must protect the PII that you collect by implementing security measures appropriate relative to the sensitivity of that PII. You must protect all PII against loss, theft, or any unauthorized access, disclosure, copying, use or modification. Due to the rapid evolution of technology and its associated risks and threats, the law does not provide a specific list of security safeguards that you must implement, but instead provides guidance on how to determine the safeguards that are appropriate to your organization.
How to select the right safeguards
The PIPEDA Fair Information Principle: Safeguards states that the following factors should be taken into account when choosing what safeguards to implement:
- The sensitivity of the PII and the risk of harm to the individual;
- The amount of PII that you store;
- The extent of distribution;
- The format of the PII;
- The type of storage; and
- The types and levels of potential risk that your organization faces.
The above factors should be reviewed frequently as your practices and the technology that you use change as these changes will affect the safeguards that are appropriate for your organization.
Examples of measures under PIPEDA Fair Information Principle: Safeguards
Once you perform an assessment of the factors above, you will need to choose the safeguards for the PII that you control. Safeguards can include physical measures, up-to-date technological tools and organizational controls. The following is a list of examples of safeguards that you may want to consider:
- Using SSL or other secure connection technologies;
- Destroying the PII that you no longer need;
- Performing regular risk assessments;
- Screening all employees with access to PII;
- Training all employees;
- Encrypting laptops, USBs and other portable media;
- Maintaining up to date software; and
- Performing due diligence of vendors.
Donata is the Co-founder and President of Termageddon, an auto-updating generator of website and application policies. She is a licensed attorney and Certified Information Privacy Professional. She also serves as the Vice-Chair of the American Bar Association’s ePrivacy Committee and the Chair of the Chicago Chapter of the International Association of Privacy Professionals. In her free time, Donata enjoys beekeeping, hunting for morel mushrooms, and walks with her husband and two dogs.