Michael Geist has analyzed the proposed Consumer Privacy Protection Act (or as he says, technically Bill C-11, the Digital Charter Implementation Act) and erases some of my original optimism. Some of the concerns: allowing data collection to support "an activity in the course of which obtaining the individual's consent would be impracticable because the organization does not have a direct relationship with the individual (though the same language is found in the Panel on Research Ethics, 5.5A, so it may be too late to object); a concern that "that complainants may find themselves largely shut out of the process should the Privacy Commissioner decline to conduct an inquiry". The main criticism, I think, is that the bill is being approached as a commercial privacy law, while as Geist notes, the Privacy Commissioner of Canada (and, I note, many others) have called on the government to take a human rights centered approach. Image: Innovation, Science and Industry Minister Navdeep Bains, CBC.
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