Office of the Saskatchewan Information and Privacy Commissioner. Best Practices for Information Sharing Agreements. 23 March 2018. 3 Why is an Information Sharing Agreement Important? Tom Wright, a former Ontario Information and Privacy Commissioner, pointed out in his paper Model Information Sharing Agreement that: Sharing personal information between two organizations runs counter to two of the most fundamental principles of data protection – that personal information should be collected directly from the individual to whom it pertains, and should only be used for the purpose for which it was collected (with limited exceptions). Therefore, where possible, sharing should not occur without exploring less privacy-invasive means of meeting a specific objective. What are Best Practices for Creating Information Sharing Agreements? The Institute for Citizen-Centered Service (ICCS) produced a set of Guidelines for Best Practice as they relate to Government-to-Government personal information sharing agreements. This tool highlights six best practices and is intended to address the need to better manage privacy risks and to achieve greater transparency, control and accountability. The following are the recommended six best practices covering the lifecycle of an information sharing agreement (ISA). The first three steps contain best practices recommended before proceeding with an ISA: Step One: Identify Need and Determine Risk Factors Essential Requirements: Sharing personal information under your care should only be considered when both the following circumstances exist: • You have legal authority. • There is a clear justifiable need in the current period of time. Other important requirements include: • Security measures taken to safeguard information such as the location of databases and the method of transfer. • Consultation with your legal and privacy experts covering the framing of the ISA to the implementation and follow-up of the agreement.
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