The Office of the Privacy Commissioner of Canada is on a roll. It seems that hardly a week goes by lately where they don't make some form of topical announcement.
Last week, along with its provincial and territorial counterparts, the OPC passed resolutions on youth and workplace privacy. And just this week, it released draft guidance on biometrics, both for the private and public sectors. These new guidelines will eventually replace the OPC's 2011 guidance on the subject.
I have to admit, what I have seen so far is encouraging. On the biometric piece, the OPC clearly took time to learn about and think through common issues. The office clearly articulated its expectations and provide concrete examples, including through its own investigatory findings.
While all OPC guidance is welcome and instructive, in some past cases, it's come at such a high level that one can't help but think organizations and public bodies would benefit from more specifics.
In both their level of detail and through the many examples they contain, these new guidelines stand out from previous guidance. They also present the material in a way that's easier to navigate and digest, such as by using tables to separate requirements from recommendations.
Of course, and as to be expected, the draft guidelines are not perfect. But they are certainly a good first step. And what better way to get closer to perfection than by crowd-sourcing among Canada's privacy community.
The OPC is seeking input on the guidance, which can be submitted by members of the public until 12 Jan. 2024, here. No doubt IAPP members have an important role to play in helping improve these guidelines to ensure they are rooted in law, state-of-the-art, and best practice.
What are your thoughts on the guidance? Will you heed the call and provide input?
In other OPC news, Privacy Commissioner Philippe Dufresne and his colleagues are scheduled to return before the House of Commons Standing Committee on Innovation and Technology next week as it continues to study Bill C-27.
As Kris Klein discussed last week, the committee was thrown off course by surprise revelations the government planned to amend the bill without first providing the amendments to the committee studying it. As a result, Dufresne's comments during his first appearance were limited to his opening statement. The rest of the meeting was dedicated to procedural matters.
Let's hope the commissioner and his staff are now given the opportunity to answer members' questions and provide their own input on this important bill when they return.