Canadian Media Directors’ Council, Institute of Communication Agencies, Conseil des directeurs médias du Québec inc., and Association of Quebec Advertising Agencies

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9 December, 2010

Office of the Privacy Commissioner of Canada,
112 Kent Street,
Ottawa, ON K1A 1H3

In Reference to: Draft Report on the OPC 2010 Consultations

This letter is written on behalf of 4 organizations which represent the majority of advertising and communications service companies in English and French Canada.

We would like to congratulate the Commission for organizing the consultations and for including us at this stage of your observations. Our remarks are directed exclusively towards privacy implications of online tracking, profiling and targeting. That said, we strongly support your initiative to explore the changing perceptions of public and private spaces with a view to developing better practices in this area.

Our three key issues which we identify with in your report are transparency, respect for the consumer and self-regulation. All of them are cornerstones of responsible advertising.

As has often been noted, Canadian policy in the form of PIPEDA and the profile of the Privacy Commission in this Country, has been seen as progressive and much further advanced over many other countries. Although our impetus is partially due to high internet usage, Canada has been proactive in an area which is receiving increasing scrutiny worldwide, leading to hasty and less measured decisions made without extensive public and business input. This makes us even more grateful for the breadth of consultation here in Canada.

There is much to learn about privacy issues and infringements, but as we pointed out to you in our letter of March 15, 2010 we, along with other advertising related organizations have endorsed a set of principles for self-regulation and activities within Canada, to ensure that through our actions:

• We are not in contravention of the basic trust between advertisers and their consumers
• We are up front with the consumer as to their opt out options
• We provide an information service to give the public full transparency on their rights to privacy

I would like to remind you of our organizations to give you context for our remarks:

1. The Canadian Media Directors' Council (CMDC) is a not-for-profit industry association of media advertising and communication agency Presidents and Managing Directors working to enhance the effectiveness of media advertising in Canada. We also exist to raise the profile of and ensure that best practices are applied to all elements of our industry in Canada. On behalf of our client marketers, our members are responsible for the placement of over 80% of advertising expenditure in Canada.
2. The Conseil des directeurs médias du Quebec (CDMQ) founded in 1981 is a non-profit organization that regroups more than twenty media agency professionals in the Quebec marketplace. The CDMQ mission is to be a convergence point for opinions and information, to defend the interest of advertisers and agencies and to promote and stimulate the media in Quebec.
3. The Institute of Communication Agencies (ICA) represents Canada's communications and advertising agencies and was founded in 1905 under a national charter to promote higher standards and best practices. ICA members collectively account for over three quarters of all national advertising in Canada, with an economic impact worth more than $20 billion annually. These member agencies employ over 7,000 persons. ICA serves as a leading source of information, advice and industry education, promoting thought leadership, best practices and the elevation of professional standards.
4. Association des agences de publicité du Québec (AAPQ) is a non-profit organisation with a membership of more than 60 advertising agencies that generate more than 80% of the industry's revenues in Quebec. Its mission is to serve the interest of its members and partake in the recognition of the industry through rallying projects.

We have been pleased with the collaborative nature of this important project, to hear from business as well as the consumer, in order to get a 360 degree perspective on a valued quality of life issue which is what privacy represents.

We look forward to more open and productive discussions on this important topic.

Respectfully submitted

Signed
Janet Callaghan
Executive Director
Canadian Media Directors' Council
416-921-4049
416-921-4050

Signed
Jani Yates
President
Institute of Canadian Advertisers
416-482-1396 Ext. #230

Signed
Alain Tardy
Président
The Conseil des directeurs medias du Québec

Signed
Alain Tardy
Président & CEO
Association des agences de publicité du Québec