We agree with the commissioner. It's not a replacement. Obtaining consent does not replace our obligations to have a PIA.
We have had a PIA since the program was created. We have updated it through some of the years. The PIA covers the data we collect. We ensure that all the data we collect is covered in our PIA and assessed against the privacy concerns.
After discussion with the office of the commissioner, we agree with the office that, based on where we're at, it would be a good idea to update that.
The tools don't make for a PIA. Just because you purchase a tool doesn't necessarily change the way you use the data. That's why it wasn't done as a PIA for the tool. However, certainly we believe it is appropriate at this time to update our PIAs, especially with some of the new directions that are coming out from the Treasury Board on this aspect.