Study on “Emerging Digital Payments Systems”

Submission to the Standing Committee on Finance (FINA)

February 7, 2014

Mr. James Rajotte, Member of Parliament for Edmonton – Leduc
Chair of the Standing Committee on Finance
Sixth Floor, 131 Queen Street
House of Commons
Ottawa ON K1A 0A6

Dear Mr. Rajotte:

The Office of the Privacy Commissioner of Canada (OPC), pursuant to its legislative mandate to protect the privacy rights of individuals and promote the privacy protections available to Canadians,^{Footnote 1} is providing the following comments to The Standing Committee on Finance (FINA) for its study on “Emerging Digital Payments Systems”.

The nature of payments, in Canada and internationally, is changing due to innovations in technology and the increasing use of mobile devices and applications used to make payments by individuals and by businesses. While new payment methods are being developed to provide convenience to consumers and efficiencies for businesses, these new technologies and payment methods are not without privacy challenges that need to be addressed.

For example, media reports of payment system data breaches, including that of sensitive information such as personal financial information, are increasingly making headlines. These incidents involve companies of all sizes, including large transnational corporations, and can have global implications.

As an interested party, our Office has undertaken several initiatives to promote the strengthening of privacy and security in the transformation of the Canadian payments system landscape that may be of use. For example, we have attached for your interest:

1. our submission to the Task Force for the Payments System Review outlining how privacy and security are integral factors to support the changing payments landscape in Canada (Annex A);^{Footnote 2} and
2. academic research by Dr. Carlisle Adams on mobile payments that our Office supported (Annex B).^{Footnote 3}

In addition, our Office participates in the Financial Consumer Agency of Canada’s (FCAC’s) Interdepartmental Committee on Financial Literacy, and is developing a submission to Finance Canada on the benefits of addressing privacy as a component to support comprehensive consumer financial protection.                      

We encourage the Committee’s study on emerging digital payments systems to examine the full range of potential privacy and security issues, especially considering the importance of protecting personal information within the payments ecosystem.

If it could be helpful to the Committee, the OPC would be pleased to discuss these views and the role of privacy in the study on emerging digital payments systems.

Sincerely,