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Bill C-27 Business Insights Series: Navigating Canada’s Evolving Privacy Regime

The federal privacy regulatory landscape in Canada is undergoing a seismic shift that will have major implications for business across Canada. The introduction of Bill C-27: Digital Charter Implementation Act, 2022 (“Bill C-27”) is the second attempt at overhauling Canada’s federal privacy regime and aims to create three new pieces of legislation that could affect your day-to-day operations:

  • The Consumer Privacy Protection Act(“CPPA”);
  • The Personal Information and Data Protection Tribunal Act(“PIDPTA”); and
  • The Artificial Intelligence and Data Act(“AIDA”).

McCarthy Tétrault’s Bill C-27 Business Insights Series provides you with a comprehensive overview of Bill C-27 and its implications, through the lens of your business interests. The series will discuss CPPA and PIDPTA, which are updated versions of legislation that the government introduced in November 2020 (the “2020 Bill”) and which ultimately died when Parliament was dissolved for the 2021 Canadian federal election. You’ll also learn about AIDA, which is an entirely new piece of legislation. As a consequential amendment, the Personal Information Protection and Electronic Documents Act (“PIPEDA”) will become the Electronic Documents Act, losing the privacy provisions but retaining the provisions regarding electronic documents.

So what has not changed since the 2020 Bill? What has changed since the 2020 bill? What should my organization do now? How do I adequately prepare for the pending changes? This series will answer these burning questions and explore other topics in-depth including the Bill’s effect on Canada’s AI regulatory landscape, regulating dark patterns, new constraints on processing personal information, and much more. We’ll continue to update this page with the latest content so be sure to bookmark it.

McCarthy Tétrault’s Cyber/Data Group has extensive regional and national experience in privacy, data protection and cybersecurity and a track record in advising key sectors on critical issues in novel and complex areas of law. Our team can help you navigate the privacy and data landscape so you can leverage the value of data, develop responsible AI practices, protect your organization’s assets and cement customers’ and clients’ digital trust.

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Have a question?

To learn more about how our Cyber/Data Group can help you navigate the privacy and data landscape, please contact national co-leaders Charles Morgan and Daniel Glover.

Bill C-27 Business Insights Series

An Evolving Digital Privacy Landscape—Comparing the Federal Bill C-27’s CPPA to Quebec’s Bill 64

An Evolving Digital Privacy Landscape—Comparing the Federal Bill C-27’s CPPA to Quebec’s Bill 64

The Act to modernize legislative provisions as regards the protection of personal information[1] (“Bill 64”) received royal assent on September 22, 2021, introducing amendments to the privacy regime and the framework governing the use and collection of personal information (“PI”) by public and private sector privacy laws in Quebec. Meanwhile, on June 16, 2022, the federal government introduced three new acts under Bill C-27, An Act to enact the Consumer Privacy Protection Act, the Personal Information and Data Protection Tribunal Act and the Artificial Intelligence and Data Act and to make consequential and related amendments to other Acts (or Digital Charter Implementation Act, 2022) (“Bill C-27”).

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The End No Longer Justifies the Means: Bill C-27’s new Constraints on Processing Personal Information

The End No Longer Justifies the Means: Bill C-27’s new Constraints on Processing Personal Information

On June 16, 2022, the Canadian Minister of Innovation, Science and Industry introduced Bill C-27, which will enact the Consumer Privacy Protection Act (“CPPA”) and repeal Part 1 of the current Personal Information Protection and Electronic Documents Act (“PIPEDA”). This article is part of our Bill C-27 Blog Series, which provides a comprehensive overview of the privacy reform launched by the Canadian government.

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A Canadian Perspective on Regulating Dark Patterns

A Canadian Perspective on Regulating Dark Patterns

When do commonplace Internet advertising “nudge” techniques cross the line into inappropriate manipulation?

Regulators now have a new source of Internet harm in their crosshairs: so called “dark patterns”. Generally speaking, the expression “dark patterns” refers to manipulative or deceptive user interface design choices engineered by developers to nudge individuals towards decisions they might not otherwise make, including unintended and potentially harmful decisions. Dark patterns have been a recent area of focus for regulatory authorities.

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The Dawn of AI Law: The Canadian Government Introduces Legislation to Regulate Artificial Intelligence in Canada

The Dawn of AI Law: The Canadian Government Introduces Legislation to Regulate Artificial Intelligence in Canada

Following a global trend in artificial intelligence (“AI”) regulation, which has taken momentum in the U.S. and the EU, Canadian legislators appear to be poised to move beyond policy frameworks, developed by both private and public bodies, and adopt hard law. On June 16, 2022, Bill C-27 was introduced in Parliament for its first reading. Titled The Digital Charter Implementation Act, 2022, Bill C-27 is the second attempt at reforming federal privacy law in Canada. It follows Bill C-11, which died on the order paper when the 2021 election was called.

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Privacy Legislation Overhaul: Canada Takes a Second Shot at the CPPA

Privacy Legislation Overhaul: Canada Takes a Second Shot at the CPPA

In a second attempt at overhauling Canada’s federal privacy legislation, today Canada’s Minister of Innovation, Science and Industry François-Philippe Champagne introduced Bill C-27: Digital Charter Implementation Act, 2022 (“Bill C-27”). It aims to create three new pieces of legislation:

  • The Consumer Privacy Protection Act (“CPPA”);
  • The Personal Information and Data Protection Tribunal Act (“PIDPTA”); and
  • The Artificial Intelligence and Data Act (“AIDA”).

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Bill C-27 and Managing Information Legitimate Interest, AI and Other Implications for Data Governance

Bill C-27 and Managing Information: Legitimate Interest, AI and Other Implications for Data Governance

Introduced on June 16, 2022, Bill C-27: Digital Charter Implementation Act, 2022 (“Bill C-27”) is the second attempt by Parliament at a modernized Canadian privacy regime, through both the Consumer Privacy Protection Act (“CPPA”) and the Artificial Intelligence and Data Act (“AIDA”).

In this blog post, we will consider Bill C-27’s new policies as they relate to data governance, including how its proposed requirements impact data use, data management, and record keeping.

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CPPA: problems and criticisms – anonymization and pseudonymization of personal information

CPPA: problems and criticisms – anonymization and pseudonymization of personal information

Canada is planning to revamp its comprehensive privacy law by repealing the existing comprehensive privacy law, PIPEDA, and by enacting Bill C-27, the Digital Implementation Act (“DIA”) to enact the Consumer Privacy Protection Act (CPPA), Personal Information and Data Protection Tribunal Act (PIDTA), and Artificial Intelligence and Data Act (AIDA). Bill C-27 replaced Bill C-11 (the former drafts of the CPPA and PIDTA). While the DIA attempts to rectify some of the criticisms with Bill C-11, many of the problems remain and problems have emerged in the new Bill.

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