The Office of the Privacy Commissioner of Canada has released a supplementary discussion document to explain its decision to revise its policy position on trans-border data flows. The OPC also lists out eight questions in order to better facilitate the consultation it launched. “Our change in position is based ultimately on our obligation to ensure that our policies reflect a correct interpretation of the current law,” the discussion document reads. “During the Equifax investigation, it became apparent that the position that a transfer ... is not a 'disclosure' is debatable and likely not correct as a matter of law.”
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