Like Professor Scassa, I think PIPEDA should clearly provide for the right to erase inaccurate and erroneous data so that it is not just a recommendation.
I would also like to point out that the second paragraph of article 45, which talks about adequacy, does not mean just doing a cut-and-paste; it means considering effective and enforceable rights. Direct rights would therefore be appropriate. In terms of data protection, it does not directly relate to any right to erasure, but indicates that the country’s rules on human rights and fundamental freedoms will be taken into account. In this case, we are talking about the Canadian Charter of Rights and Freedoms.