A couple of things done by our regulators are worth mentioning this week.
If you’ve been curious to know the Office of the Privacy Commissioner of Canada's position on Bill C-27, now is your chance. They tabled their submission to the House of Commons Standing Committee on Industry, Science and Technology, the Parliamentary committee studying the Bill. It contains 15 recommendations, a handful of which I’ve highlighted below:
- Recognize privacy as a fundamental right.
- Protect children’s privacy and the best interests of the child.
- Expand the list of violations qualifying for financial penalties to include, at a minimum, appropriate purposes violations.
- Create a culture of privacy by requiring organizations to build privacy into the design of products and services and to conduct privacy impact assessments for high-risk initiatives.
- Strengthen the framework for deidentified and anonymized information.
- Require organizations to explain, on request, all predictions, recommendations, decisions and profiling made using automated decision systems.
- Limit the government’s ability to make exceptions to the law by way of regulations.
- Provide that the exception for disclosure of personal information without consent for research purposes only applies to scholarly research.
- Make the complaints process more expeditious and economical by streamlining the review of the commissioner’s decisions.
You’ll recall, with the previous iteration, the OPC made more than 50 recommendations in a rather lengthy submission, so it is interesting to see what the OPC has focused on for this one. I suggest you read the 25-page document, where they explain the reasoning behind each item on their wish list.
The other regulator making some news this week is from Ontario. Information and Privacy Commissioner of Ontario Patricia Kosseim unveiled a neat showcase where she highlights positive examples of openness and transparency in government. It’s like walking through a virtual art gallery, with lots of great, illustrative examples of how being open and transparent with data can actually improve our day-to-day lives and democracy in general. It’s worth checking out. I think regulators have to use all the different tools in their regulatory toolbox to bring about change and I like the idea of encouraging compliance by illustrating best practices in a creative way. I’m hoping she will share a little bit more about this unique approach onstage at the IAPP Canada Privacy Symposium — we’ll see!
And with that, it’s getting close — less than two weeks away. Our numbers are looking great, the program looks stellar and I look forward to seeing everyone soon!