You need to put suitable mitigations in place concerning the risks to information outside of the EU and also ensure that the FPN does not mislead in anyway.
You will need to ensure that the supplier/processor has suitable controls in place via Safe Harbour and maybe Binding Corporate Rules
Read up here - http://ico.org.uk/for_organisations/data_protection/overseas
Of course, there is a school of thought that asks the question - does information REALLY have to go to the States?
Simon Howarth.
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Teresa Gudge
Sent: 03 November 2014 11:20
To: [log in to unmask]
Subject: [data-protection] Collection / Transfer / Storage of data
Hello all,
I've been on the periphery of data protection for a couple of years - but have recently changed jobs and would just like some reassurance from jismailers if possible :-)
I have been asked a question about an IT solution to a situation where completed web forms are submitted and subscriptions requested. The solution is for the webforms to be held in a cloud - and of course that cloud is in the states (signed up to safe harbour).
My first response is that if the fair processing notice states categorically that the data will be held in a cloud, in the states and the subscriber agrees to that then all is well.
Obviously existing data has the issue of transferring securely - and again retrospective consent from the contributors.
Am I missing anything ? I know that these two statements sounds pretty simple and obviously there are issues such as risk assessments, agreement from management etc. etc. but I just want to be sure.
Thanks for your help
Teresa
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