Approaches to Extra-jurisdictional data transfers in Canadian and European outsourcing: A comparative approach

This article begins by describing the key Approaches to the protection of personal data where the data is subject to extra-jurisdictional transfer. It then provides an overview of how the E. U. has adopted these Approaches, followed by a review of the emerging Approaches in Canada. The article concludes by evaluating the advantages and disadvantages of the two regimes, and suggests what should be the optimal Approach.