On November 9, I appeared before the parliamentary Standing Committee on Industry and Technology (INDU Committee) to provide comments in connection with the Committee’s review of Bill C-27, the Digital Charter Implementation Act, 2022.  The following are the speaking notes for my introductory comments, with certain additions.

Thank you for the invitation to appear before the Committee in its very important review of Bill C-27.

This Bill includes significant proposed amendments to Canada’s privacy laws at the same time as introducing a proposed oversight regime for artificial intelligence.  The AIDA (Artificial Intelligence and Data Act) component warrants focussed study by the Committee, separate and distinct from the needed focus on the privacy law amendments.  I will restrict my comments to the privacy components.

The proposed CPPA (Consumer Privacy Protection Act) represents a significant advance over the current privacy law – PIPEDA – which itself was introduced to respond to concerns with digital data.  However, as the Committee has heard from witnesses, there are significant areas of potential improvement that can make the Bill, and specifically the CPPA, better.

I am a privacy and regulatory lawyer.  My practice over the past 25 years has included advising private sector organizations, both for-profit and non-profit, as well as government and Crown agencies, addressing all relevant areas including individual privacy, employee privacy and health privacy.

In my introductory comments I will focus on one, very important, area of the Bill…

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