Canada systems desk / Data questionsTechnical discovery, not legal advice

Data-location and vendor-responsibility kit

Assign the questions before anyone assigns the architecture.

A remote software project can involve Canadian users, a US-based delivery partner, several software vendors, and infrastructure in more than one place. This checklist helps the client identify who must answer each question. It does not decide what Canadian privacy law requires.

Question set / five boundaries

Build a responsibility record.

Record the answer, the accountable person, the source used, and the date it was approved. If an answer changes the system design, keep it with the technical decision record.

Start with the Office of the Privacy Commissioner's PIPEDA overview.

01

Information boundary

What information is collected or created? Which fields can identify a person? What can be excluded, minimized, aggregated, or separated from the workflow?

02

Location boundary

Where do the application, backups, logs, analytics, support tools, and integrated vendors process or store information? Who has authority to accept those locations?

03

Access boundary

Which client roles, Faith Forge Labs personnel, vendor support teams, and automated services may access each class of information? How is access granted, reviewed, and removed?

04

Lifecycle boundary

How long is information needed? What is the retention trigger? How do correction, export, archive, deletion, backup expiry, and legal holds affect the technical design?

05

Incident boundary

Who monitors, triages, documents, contains, notifies, and approves recovery? What evidence can the system produce without collecting unnecessary sensitive detail?

Client responsibility

Decide the business and legal purpose

  • identify the accountable privacy, legal, security, and operational reviewers;
  • approve purposes, retention, vendor choices, disclosures, and user-facing notices;
  • decide which provincial, federal, sector, contract, or internal rules require qualified review.
Faith Forge Labs responsibility

Make the technical behaviour visible

  • document proposed data flows, vendors, access paths, storage, and failure behaviour;
  • implement approved controls that are inside the project scope;
  • test the agreed behaviour and explain what has and has not been verified.
Vendor responsibility

Supply current service facts

  • publish hosting, subprocessor, retention, support, and security information;
  • state available configuration and contractual controls;
  • notify customers when the service's relevant terms or architecture change.
Unresolved responsibility

Resolve important data questions before development

If nobody can approve a data location, retention period, vendor term, or access role, pause that part of the work until the right person can decide. Development should not turn an unanswered policy question into a permanent system rule.

Important boundary

Faith Forge Labs is not a Canadian law firm, privacy regulator, auditor, certification body, or local data-residency authority. The Office of the Privacy Commissioner explains that PIPEDA establishes privacy rules for covered commercial activities and addresses cross-border information handling. Applicability and obligations for a specific project require the organization's own qualified review.

Add the answers to the brief

Make data responsibility a design input.