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ARTICLE · 01 OCTOBER 2020

Don't Rush When Assessing RROSH: Record Keeping And Breach Notification Obligations Under PIPEDA

In light of a recent Office of the Privacy Commissioner publication, companies should note the importance of sometimes-overlooked breach compliance activities, including documenting a data...

CanadaPrivacy

In light of a recent Office of the Privacy Commissioner publication, companies should note the importance of sometimes-overlooked breach compliance activities, including documenting a data breach and how implementing an effective breach management system can be an important compliance tool.  

The federal Office of the Privacy Commissioner (OPC) recently published the 2019 Breach Record Inspection report (report)1 on how organizations are addressing personal information breach record keeping and notification obligations under the Personal Information Protection and Electronic Documents Act (PIPEDA).2 The report provides guidance for organizations on assessing and documenting a ?real risk of significant harm" (RROSH), which triggers notification to the regulators and individuals. 

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