An organization is sharing personal information that is defined in its privacy policy with a trusted third party. What else should the organization…

When an organization (the data controller) shares personal information with a third party (the data processor), it retains accountability for the protection of that data. To fulfill this responsibility, the organization must provide the third party with clear, explicit instructions on how the data is to be handled. This is accomplished by sharing its privacy policy and associated handling practices. This communication ensures the third party understands the specific requirements for data processing, storage, security, and disposal, thereby contractually obligating them to uphold the same privacy commitments the organization has made to its users.

A. Audit results reflect the organization's past compliance status; they do not provide the specific, forward-looking handling instructions required for the data being shared.

B. Sharing data when contractual obligations and privacy policies are misaligned is a serious compliance violation. This issue must be resolved before sharing, not simply communicated.

C. While the third party must comply with federal laws, the organization is responsible for communicating its own, potentially more stringent, policies and specific handling requirements.

1. NIST Special Publication 800-53 Revision 5

Security and Privacy Controls for Information Systems and Organizations. Control PT-7

"Third-Party Use

" requires organizations to "Establish and enforce agreements with third parties that require the protection of PII." The discussion section elaborates that these agreements must specify the authorized uses and disclosures of PII

which are derived from the organization's policies and practices.

2. General Data Protection Regulation (GDPR)

Article 28

"Processor." As a foundational framework for modern privacy taught in university curricula

GDPR mandates that a contract must govern processing by a third party. This contract must stipulate the "nature and purpose of the processing" and the "obligations and rights of the controller

" which directly translates to communicating the organization's policies and handling practices.

3. Solove

D. J.

& Schwartz

P. M. (2021). Information Privacy Law (7th ed.). Wolters Kluwer. In discussions on information sharing with third parties (Chapter 7

Section C)

the text emphasizes the necessity of contracts that limit the use and disclosure of personal information according to the primary organization's privacy policy.