When an organization responsible for a large number of records considers outsourcing the storage of those records, it is critical to ensure that there is a robust contractual agreement in place between the organization and the records storage company. This agreement should outline the responsibilities of the storage company, the security measures they must adhere to, and the conditions under which they handle the personal information stored on the records1.
A contractual agreement serves several important purposes:
It defines the scope of services provided by the storage company.
It sets forth the security standards and privacy protections that must be maintained.
It establishes the legal obligations of the storage company, including compliance with relevant privacy laws and regulations.
It provides a mechanism for accountability and recourse in the event of a breach or non-compliance.
While determining if the personal information will be used for data matching (option A) and ensuring that consent was informed and meaningful (option D) are important considerations, they do not directly address the relationship between the organization and the storage company. Conducting a Privacy Impact Assessment (PIA) (option C) is also a valuable step, but it is a preparatory measure that should inform the development of the contractual agreement rather than being the critical factor in the outsourcing decision.
Therefore, the verified answer is B, as establishing a contractual agreement is the most critical consideration to ensure that the outsourced storage of records is managed in a way that protects the personal information and complies with privacy laws and regulations
