Hi everyone
we are investing in a new information system and have chosen a US based
company to design the software. As part of this process, they wish to
transfer the current data for the US to be manipulated and migrated on to
the new system.
The org is Safe Harbour registered, but I am unclear as to whether Safe
Harbour covers this type of situation. Guidance from elsewhere indicates
that Safe Harbour only covers Controller to Controller relationships rather
than Controller - Processor relationships.
Does Safe Harbour cover us in this situation as an adequate safeguard?
If not, what additional steps (i.e. contractual clauses) should we be
looking to put in place?
Thanks in advance
Dom
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