Bermuda's Personal Information Protection Act 2016 (PIPA)
will, when fully operative, represent a significant change in
informational privacy law in Bermuda. While it envisages a
comparatively "light regulatory environment" for
informational privacy, the act will require a number of practical
changes for many organisations.
At the time of writing, only those sections relating to the
establishment and operation of the office of the Privacy
Commissioner are in force. In many respects, Bermudian
organizations remain in suspense as they eagerly await guidance on
the interpretation and application PIPA.
Following the appointment of Bermuda's first Privacy
Commissioner in January 2020, the expectation was that PIPA would
be on track for roll-out by the end of 2020. COVID-19, not
surprisingly, is believed to have contributed to the delay in the
implementation of PIPA. There is a general expectation that there
will be movement within Q1 of 2021, including other
