Compliance With Bermuda's Privacy Laws By Fund Entities

In short, PIPA applies to "every organisation that uses personal information in Bermuda". An "organisation" means any individual, entity or public authority that uses personal information, and is widely accepted to include: trusts, corporations, partnerships of all kinds; trade and other commercial associations, organisations or societies; proprietorships, and, branch offices of foreign corporations that carry on business in Bermuda.

The word "use" is defined by PIPA to mean, "... carrying out any operation on personal information, including collecting, obtaining, recording, holding, storing, organising, adapting, altering, retrieving, transferring, consulting, disclosing, disseminating or otherwise making available, combining, blocking, erasing or destroying it". The use of personal information ("PI") in Bermuda, would, as a matter of common law, also include any digital access to and use from within Bermuda of PI that is stored or located on a server that is