Tim,
I assume that the users can then request to be removed from the database
Ricky
__________________
Ricky Rankin
Principal Analyst
Information Services
Queen's University Belfast
Tel: 02890 974824
Fax: 02890 976586
email: [log in to unmask]
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Tim Trent
Sent: Friday, June 23, 2006 4:51 PM
To: [log in to unmask]
Subject: Re: Personal data held in US
I think you will need a full Data Processor agreement in place with them,
part of which explicitly instructs them in your ownership of the data and
their obligations only to process it under your instructions, including
penalties if they process the data in any way without instructions.
Of course you do then need to instruct them :)
It would be wise to let the individual on the database know that the data
will be processed on servers which may not be in the EEA, too.
Tim Trent - Consultant
Direct: +44(0)1344 392644 Mobile:+44(0)7710 126618
email: [log in to unmask]
Marketing Improvement Limited, Abbey House, Grenville Place, Bracknell,
United Kingdom, RG12 1BP http://www.marketingimprovement.com
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-----Original Message-----
From: rrankin [mailto:[log in to unmask]]
Sent: 23 June 2006 16:46
To: 'Tim Trent'; [log in to unmask]
Subject: RE: Personal data held in US
Tim,
Is there any possibility that the company in the USA is a Data Controller of
your data? By which I mean do they make any decisions about the processing,
or do they work solely under your instructions?
> If we choose this option they will be hosting the data to make it
available through web application
Does the data ever leave their hands and get passed to anyone else outside
the EEA, or is it restricted to their company alone?
> It would be restricted to them
> Our concern is what type of agreements would we need in place to
> comply
with DPA
Ricky
__________________
Ricky Rankin
Principal Analyst
Information Services
Queen's University Belfast
Tel: 02890 974824
Fax: 02890 976586
email: [log in to unmask]
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