I spent Wednesday afternoon this week delivering privacy training to a group of people who work at the Office of the Superintendent of Financial Institutions. It was a little different because, of course, we were all at home and connected through video technology. That said, I was heartened by their decision to proceed with the training because even in these strange times, life has to go on, and privacy is still important.
OSFI is a unique organization because it is subject to the federal Privacy Act but it oversees financial institutions, the vast majority of which are governed by the Personal Information Protection and Electronic Documents Act. We looked at the ins and outs of both laws and, of course, spoke about where these laws required modernization.
This brings me to another thing that happened this week. Several of you reached out to me to see if I’ve heard anything about the government’s agenda to modernize privacy laws considering the hyper-focus on COVID-19. I haven’t heard anything, but I can only imagine the timetable on this is going to change — and probably continue to change for the next little while. That being said, it’s also very clear that work continues on this front with some very good policy thinking being put out from Marty Abrams and the Information Accountability Foundation in collaboration with Innovation, Science and Economic Development Canada. Marty’s blog post is here, and the actual report they produced is here.
One of the IAF’s recommendations to ISED is to explore the concept of people-beneficial data activities. I’ve long suggested we needed to work in some sort of ethics framework when it comes to personal information processing, and the IAF builds on this idea. The concept of having legitimate purposes certainly isn’t new. Time will tell if the policy people at ISED will adopt the proposed approach, but, if they do, one thing is for sure: Canada’s approach to personal information processing will be unique and forward-thinking.
Ethical approaches to processing personal information … I’m sure I’m not alone that this came to mind when reading the other news story of this week: that the government isn’t ruling out obtaining cellphone geo-data to try and track (and prevent) the spread of COVID-19. The story is summarized below, so please take some of your self-isolation time and read up on current events that don’t start with the word pandemic. As mentioned above, life needs to keep moving forward, and we won’t always be working from home. It certainly makes for an interesting workday when I am privacy training a dozen people by video, my partner is hosting a fed-prov meeting via Zoom, and the kids are on video calls with their teachers and classmates. Oh yeah, and the dog is barking.
Stay safe, everyone. We’ll get through this!
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