Moving right along to the employer-employee relationship, it has become clear to us over the past six years that the consent model doesn't work very well in that context. We would propose that you consider the wording from the Alberta law, which establishes a reasonableness test, and temper it with the added notion of dignity of the person, from the Quebec law.
While we say that the consent model doesn't work very well, we are still concerned about the imbalance of power between employers and employees. We always need to consider that things employers are trying to do may not always sit very well with employees.
Business contact information is a relatively simple fix. There's already an exception to personal information. We would suggest it be broadened somewhat to include all business contact information, but that the exception be limited to the purposes of contacting an individual in their business capacity.
Solicitor-client privilege for us is a huge issue, as a result of decisions by the Federal Court. Individuals under PIPEDA have a right of access to their personal information. There are exceptions to that right of access. One of those exceptions is that the information is privileged.
We are not suggesting that privileged information be turned over to individuals. What we would like to be able to do is see that information, to ensure that the privilege is correctly being invoked. That's a very narrow focus, and it's all we're really asking for.