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Canada's proposed data privacy law an opportunity to re-think data architecture

Updated: Jun 27, 2022

Bill C-27 is the latest national legislation to require organizations to get control of the information they manage or face significant consequences

On June 16, 2022 Canada passed a first reading of Bill C-27 (aka Digital Charter Implementation Act, 2022) which was tabelled by Innovation Minister François-Philippe Champagne in the House of Commons.

The bill aims to build on the government’s previous attempts to revamp Canada’s private-sector privacy laws and better align with established laws such as California's CPRA and Europe's GDPR and other proposed legilsation such as the American Data Privacy and Protection Act.

Summary of 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" - view full text of Bill C-27.

Introduces 3 new acts:

Bill C-27 would create three new acts to regulate business’ use of personal data:

  • Consumer Privacy Protection Act (successor to PIPEDA)

  • Personal Information and Data Protection Tribunal Act (to enforce CPPA)

  • Artificial Intelligence and Data Act

Enhances rights for citizens and consumers:

  • Right to data deletion

  • Right to data custodianship (for parents)

  • Special status for children's data, including enhaced rights

Introduces an new AI and data commissioner:

  • Purpose is to identify, assess, and mitigate the risks of harm and bias related to algorithmic decision-making

  • Monitor compliance

  • Order 3rd party algorithm audits

  • Share information with other regulators and enforcers

Enhances powers of Privacy Commissioner:

  • Compel organizations to stop collecting and/or use of personal data

  • Issue fines up to $25 million or 5% of gross global revenue (whichever is greater) for:

    • Using de-identified information to identify an individual person

    • Implementing AI systems that cause harm, possessing

    • Using data that has been obtained in a way the contravenes the law

    • Failing to report or record breaches of the Act

  • Issue fines up to $10 million or 3% of gross global revenue (whichever is greater) for:

    • Failing to establish measures to manage and report on their use and monitoring of data, including failing to publicly report in plain language how AI systems are intended to be used and the outputs it generates

These are among the strongest fines among G7 countries - the EU’s GDPR carries a maximum fine of 10 million Euros (roughly $14 million CAD) or up to 2% of revenues.

Future-proofing for Bill C-27

A second reading of the bill is planned for the Fall 2022 session of parliament which provides a window of opportunity for organizations to evaluate their data management strategy.

The Data Collaboration Alliance advocates organizations wishing to take a long-term strategic view consider Zero-Copy Integration, an approach to digital solution development that eliminates the use of app-specific databases in favor of a connected, controlled, and collaborative data management ecosystem.

The primary purpose of Zero-Copy Integration is to help organizations avoid the fragmentation (aka 'data silos') and unrestricted copying (i.e. point-to-point data integration) that present fundamental challenges to compliance with increasingly strict data privcay laws, such those recommended in Bill C-27 and already enforced by Europe's GDPR and California's CPRA.

Now a draft national standard, this pioneering framework is currently open to review and comment by stakeholders, including data architects, app developers, and everyday citizens from Canadian and non-Canadian jurisdictions.

Access free data privacy resources

Members of our Data Collaboration Community can access a growng library of free professional tools related to Data Privacy, including:



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