Notice of consultation on online reputation

In May 2015, following meetings with stakeholders and engaging Canadians in focus groups, the Office of the Privacy Commissioner of Canada (OPC) released its strategic privacy priorities to guide its proactive work for the next five years. Reputation and Privacy is among the four chosen and as part of the resulting action plan, we set the goal of helping to create an online environment where individuals may use the Internet to explore their interests and develop as persons without fear that their digital trace will lead to unfair treatment.

Toward that goal, in the short term, we are launching a dialogue on reputation and privacy.  The first step was publishing a discussion paper. And now, we look to interested parties to help us take the next step, with an invitation to submit essays on the privacy issues related to online reputation, as a way of advancing the public debate on the issues raised in our discussion paper.

The purpose of asking for essays is to assemble a collection of potential solutions and bring clearer definition to the roles and responsibilities of the various players that could implement them. The goal is to enrich the public debate and ensure that OPC is in a better position to inform Parliament of a variety of solutions for addressing issues related to online reputation and to develop a policy position on this issue.

We are calling on individuals, organizations, academics, advocacy groups, information technologists, educators and other interested parties to propose new and innovative ways to protect reputational privacy as a follow-up to this discussion paper. We invite essays to answer one (or more) of these five questions:

1. We have highlighted some potential gaps in protections between the online and offline worlds. What other gaps exist?
2. What practical, technical, policy or legal solutions should be considered to mitigate online reputational risks?
3. Can the right to be forgotten find application in the Canadian context and, if so, how?
4. Should there be special measures for vulnerable groups?
5. Who are the key players and what are their roles and responsibilities?

Consultation Criteria and Procedures:

We will post your essay to the OPC web site provided that it meets the following criteria:

1. You must send your response to OPC-CPVPconsult2@priv.gc.ca by Thursday, April 28, 2016.
2. You must state that you have read and understood these consultation procedures.
3. Your essay must answer one (or more) of the five questions posed in the Online Reputation discussion paper.
4. You should clearly indicate which actor(s) (for example, industry, regulators, government) your comments are meant to implicate.
5. If your submission is five pages or longer, you must include a 1-page summary.
6. If your organization is subject to the Official Languages Act, you must submit your essay (and the summary, if it has been provided) in both official languages.  
7. If you provide a submission in your personal capacity that contains personal information other than your name and address (such as information related to a complaint), the submission will not be posted.
8. You must indicate your name, contact information and category which best represents your perspective (e.g. individual, organization, academic, advocacy group, information technologist, educator, etc.)
9. Any comments that violate Canadian law or violate our comment policy will not be posted and will either be deleted or dealt with in accordance with our legal authorities under the Privacy Act.

If your submission does not meet the criteria, OPC officials will advise you using the contact information you have provided. A confirmation email will be sent if your email address has been provided.

Please note that the OPC is not providing funding for any essays related to this call for comment.

All essays will be posted on the OPC web site with a disclaimer stating that “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.”

Information provided to the OPC for the purposes of this call for essays that is not subject to the Official Languages Act will be posted to the OPC web site in the language(s) in which you provide it. We encourage all essays to be provided in accessible formats (for example, text-based file formats that allow text to be enlarged or modified).

Please indicate whether you are submitting comments on behalf of an organization or as an individual. If you are submitting on behalf of an organization, we will publish your name, position and the name of your organization in addition to the submission. If you submit an essay as an individual, we will identify you by name. Your personal information will be available on our website but not findable by search engines.

All of the information that you provide as part of this call for essays becomes part of a publicly accessible file and will be posted on the OPC’s website. The personal information that you provide directly to the OPC is included in Personal Information Bank PSU 938 Outreach Activities. Please also see other the OPC’s Privacy Policy and other Important Notices and OPC’s comment policy for how we handle your information.

The Office of the Privacy Commissioner of Canada is subject to the Access to Information Act and the Privacy Act. The Access to Information Act provides a public right of access to government records. The Privacy Act provides individuals with a right of access to their own personal information and protects that information from unauthorized disclosure.  Some of the information you provide to us in this process may be accessible under the Access to Information Act; this does not include personal information as defined in the Privacy Act.

The personal information you provide will be used and may be disclosed for the purpose for which the information was obtained or compiled by the OPC, or for a use consistent with that purpose.

If you have a question unrelated to this call for essays, please use our Online Information Request form or contact our Information Centre. Essays submitted in response to this call will not be treated as privacy complaints under the Privacy Act or the Personal Information Protection and Electronic Documents Act. For further information on filing complaints under either Act, please see File a formal privacy complaint.

If you have any questions, please feel free to contact Melanie Millar-Chapman, who can be reached directly at melanie.millar-chapman@priv.gc.ca, by telephone at 819-994-6008, or toll free at 1-800-282-1376.