I'd like to build on the “right to be forgotten” concept. We have to deal with that very carefully going into the future so that it does not result in unintended consequences.
I have concerns on two fronts.
Insurance fraud is a big issue in our industry. It's a concern. If someone demands the right to be forgotten as a means to perpetuate an insurance fraud, that would be a tragic outcome. We'll have to address it when we go forward with PIPEDA to make sure we don't have any of those unintended consequences.
In addition, with the right to be forgotten, we want to make sure that if the person seeking the right to be forgotten—I'm talking in the insurance context—perhaps approaches their insurer and says they don't want to have any of their records in their files.... They may have had a liability policy with this particular insurer, which 15 or 20 years later, say, might be called upon and is needed by that particular customer. It would be very tragic for that customer if, in seeking the right to be forgotten by this insurer, they would forgo some rights to claim it against that insurance policy when it's needed most.