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Can I use third-party cloud storage services that collect personal information in Virginia? What are the requirements?
Using Third-Party Cloud Storage Services in Virginia
Based on the information provided in the context documents, there are no specific requirements for using third-party cloud storage services that collect personal information in Virginia. However, if you are a Virginia agency maintaining an information system that includes personal information, you must collect, maintain, use, and disseminate only that personal information permitted or required by law to be so collected, maintained, used, or disseminated, or necessary to accomplish a proper purpose of the agency. You must also establish appropriate safeguards to secure the system from any reasonably foreseeable threat to its security [1.1].
It is important to note that if you are an energy storage aggregator seeking to conduct business in Virginia, you must obtain a license from the commission prior to commencing operations [2.3]. Additionally, if you are an energy storage aggregator, you must submit proof of licensure from the commission to the utility in whose certificated service territory you intend to operate [2.1].
If you are an energy storage aggregator, you must provide accurate, understandable information in any advertisements, solicitations, marketing materials, or customer service contracts in a manner that is not misleading [2.2].
If you are a Virginia agency, you must inform clients in writing that client information shall be confidential pursuant to federal and state laws [4.1].
Confidentiality of client information of social services programs is assured by §§ 63.2-104 and 63.2-105 of the Code of Virginia. Social services client records must be confidential and can only be released to persons having a legitimate interest in accordance with federal and state laws and regulations pursuant to § 63.2-104 of the Code of Virginia [4.2].
Therefore, based on the information provided in the context documents, there are no specific requirements for using third-party cloud storage services that collect personal information in Virginia. However, if you are a Virginia agency maintaining an information system that includes personal information, you must collect, maintain, use, and disseminate only that personal information permitted or required by law to be so collected, maintained, used, or disseminated, or necessary to accomplish a proper purpose of the agency. You must also establish appropriate safeguards to secure the system from any reasonably foreseeable threat to its security.
Source(s):
- [1.1] Administration of systems including personal information; Internet privacy policy; exceptions
- [2.1] Energy storage aggregator registration with utility
- [2.2] Marketing by energy storage aggregators
- [2.3] Licensing of energy storage aggregators
- [4.1] Publicizing safeguarding requirements
- [4.2] Confidential client information pertaining to social services programs
Jurisdiction
Virginia