Industry committee  We would also support the bill. We've heard, even today, some suggestions that are useful—for example, the one about extending fraud to crime and so on. But I think the bill is a very good one and should proceed as it is.

Industry committee  One of our themes, as I said, is harmonization within Canada, but clearly, also for our regulators who deal with other privacy commissioners internationally and do a lot of work together this is very useful, because it creates similar rules—to some degree, at least—across various

Industry committee  We have a concern where the breach might be of a minor nature but it would still be subject to very serious penalties, as was being referred to earlier. Including those as part of the requirement for record-keeping would be inappropriate. I mean, think of an example where you st

Industry committee  Finally, Chairman, we would like to touch on a provision that has already received a lot of attention by other witnesses: proposed PIPEDA section 6.1, in clause 5 of the bill, describing when consent is valid. We believe a clear and consistent understanding of consent for the p

Industry committee  We will both be making a presentation, Mr. Chair. My name is Frank Zinatelli. I'm vice-president and general counsel with the Canadian Life and Health Insurance Association. I'm accompanied today by my colleague Anny Duval, who is counsel with the CLHIA. The CLHIA represents l

Finance committee  That is certainly another very important question that will have to be discussed and that has been discussed to a great degree. I believe this LTD initiative we have started is very positive. We are hoping that the provinces will also come on board with similar initiatives to add

Finance committee  Thank you for the question. I think the budget and the subsequent bill address that in a very technical manner. I believe that if one were to look at the existing legislation, I would certainly interpret it as having established that separation, I believe, way back at the begin

Finance committee  It addresses this for private sector federal companies.

Finance committee  Bill C-38 addresses very much a specific subset of that issue. It doesn't address the pension issue, for example, in terms of creating new priorities, etc. What it addresses is long-term disability benefits that are effectively being paid in situations where an employer self-insu

Finance committee  Thank you, Mr. Chairman. I am Frank Zinatelli, vice-president and general counsel of the Canadian Life and Health Insurance Association Inc. I would like to thank the committee very much for this opportunity to contribute to your review of part 4 of Bill C-38, An Act to impleme