I suspect the Office of the Privacy Commissioner of Canada’s email servers were working overtime last week as everyone sent in their submissions with respect to the consultation on transborder data flows and the transfer of personal information for processing purposes.
We at nNovation made our own submission. It is here if you would like to read it, but I warn you it’s a little long. The Coles Notes version is that we believe the Personal Information Protection and Electronic Documents Act ought to be interpreted as not requiring some sort of additional explicit consent when an organization transfers personal information for processing.
Many other organizations have made their own submissions and some, like us, have made them public. Vance Lockton, a former employee at the OPC who now works at Waterfront Toronto, did all us a service and created a LinkedIn group so you can find all the submissions that have been made public.
Many of the ones I’ve read are consistent with our nNovation submission. It will be interesting to see if all these voices are heard and what the final outcome of this whole process will be.
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