Bill C-11 includes the authority to make orders and, as you say, to recommend fines. Is it a step in the right direction? I think the overall goal should be to ensure that Canadian consumers have access to quick and effective remedies when their privacy rights are breached or violated, and as we tried to explain in our submission, in most cases we think that the imposition of administrative penalties would result, on average, seven years after the violation has occurred. Is that a step forward?
Personally, I don't think so, particularly when the list of violations that can result in fines is extremely limited, contrary to the laws of other countries, and excludes the most central provisions in privacy law, which are obtaining consent meaningfully and for organizations to be accountable in the way they handle information. The extreme narrowness of the scope for offences and violations and the extremely long period leading to the potential imposition of a fine makes me say that this needs to be reconsidered completely.