Submission to the OPC’s Consultation on Consent under PIPEDA (CIPS)

Canadian Information Processing Society

October 2016

Note: This submission was contributed by the author to the Office of the Privacy Commissioner of Canada’s Consultation on Consent under PIPEDA.

Disclaimer: The opinions expressed in this document are those of the author(s) and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada.

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Summary

Culture and society are changing, along with rapid advancements in information and communications technology.  CIPS members are proud to be key contributors to these advancements across Canada and internationally.  Our members recognize roles are shifting to further include global thinking, data provenance, social policy, and legal and ethical concerns.  As the boundaries of our members’ roles change, the need for the boundaries of the Office of the Privacy Commissioner of Canada (the “OPC”) also needs to change.

Our response outlines the issues and opportunities CIPS would like to see as priorities for your work in privacy and consent. We believe:

• a framework is required that establishes a holistic privacy and consent solution; Privacy by Design must be an integral part.
• there is a need for all IT practitioners … a vital part of Canadian business and the day-to-day lives of Canadians… to uphold professional standards that incorporate certification, legal education and ethical standards, overseen by an independent body. [CIPS has had this kind of mechanism in place since 1989. Our professional designation, the I.S.P., provides a model for your consideration, with the potential to establish IT practitioners as fundamental to upholding privacy and consent legislation. The hard work of securing recognition in law for the I.S.P. by six provinces across Canada has been already accomplished by CIPS.]
• a governance model is necessary that holds senior decision–makers in organizations accountable for standards that rigorously safeguard privacy rights of all Canadians
• there is a need for legislative change to provide the OPC with greater powers to help ensure Canadians’ privacy is protected in our increasingly complex world.

We thank you for your efforts to-date. We hope our input is influential on your next steps. We are confident in the ability of our members to contribute, in a highly meaningful way, to the continuing conversation:

---shaping the rules for collection, use and disclosure of personal information in Canada.

The full submission is available in the following language(s):

English (PDF document)

Note: As this submission was provided by an entity not subject to the Official Languages Act, the full document is only available in the language provided.