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Assessing the Privacy Implications of Extra-National Outsourcing to the Cloud

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University of Toronto



Project Leader(s)

Heidi Bohaker (Principal Investigator), Associate Professor, Department of History, Faculty of Arts and Science


This project aimed to assist Canadian organizations considering the extra-national outsourcing of their electronic communications, through the creation of a web‐based suite of resources to assist these organizations in making informed decisions. Many Canadian companies and organizations have already outsourced electronic communications services to US corporations, particularly Microsoft and Google, while others are considering this option to both save money and enhance service. The research team sought answers to questions such as:

  • What are the privacy implications of outsourcing outside of Canada electronic communication?
  • What happens to the personal information of Canadians when their electronic data is stored on servers in the United States and in other international jurisdictions?
  • And what do Canadians need to know in order to make informed decisions about using cloud‐based outsourcing services?
  • Given what is now known about the extent of NSA surveillance, can extra‐national outsourcing be compliant with requirements under PIPEDA?
  • Under what conditions could the NSA violate the privacy of Canadians’ electronic data? Are the Patriot Act and other US statutes “red herrings?” Or do they pose significant threats to the privacy rights and expectations of Canadians?
  • What confidence can and should Canadians considering outsourcing place in the assertions of service providers that encryption strategies, for example, can protect user data from third party access?

In addition to an informational website, the project resulted in a literature review of key publications on the privacy implications of extra‐national outsourcing; an analysis of various perspectives on extra‐national outsourcing in industry, media and government communications; the development of a framework for assessing the risks of extra‐national outsourcing for use by Canadian organizations; the production of a report with recommendations for policy makers and legislators on changes needed to ensure the protection of Canadian electronic Communication; and the organization of a public forum where key stakeholders could share their perspectives.

This document is available in the following language(s):


OPC Funded Project

This project received funding support through the Office of the Privacy Commissioner of Canada’s Contributions Program. The opinions expressed in the summary and report(s) are those of the authors and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada. Summaries have been provided by the project authors. Please note that the projects appear in their language of origin.

Contact Information

University of Toronto
563 Spadina Crescent
Toronto, Ontario
M5S 2J7

Tel: 416-978-2011

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