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Canada: OPC submits comments on Bill C-27 recommending further improvements

On May 11, 2023, the Office of the Privacy Commissioner of Canada (OPC) announced that it had submitted comments on Bill C-27 for the Digital Charter Implementation Act 2022 (DCIA) to the Standing Committee on Industry and Technology in the House of Commons. While the OPC welcomed the bill as a significant improvement compared to the Personal Information Protection and Electronic Documents Act 2000 (PIPEDA), it also included suggestions for further amendments and recommendations.

Specifically, the OPC highlighted 15 key recommendations to enhance and strengthen the bill, including to:

  • recognize privacy as a fundamental right;
  • protect children's privacy and the best interests of the child;
  • limit organizations' collection, use, and disclosure of personal information to specific and explicit purposes that take into account the relevant context;
  • expand the list of violations resulting in monetary penalties;
  • include a right to the disposal of personal information even when a retention policy is in place;
  • create a culture of privacy within organizations; and
  • strengthen the framework for de-identified and anonymized information.

You can read the announcement here, the submission here, and the recommendations here.