Well, I think it's a step backwards from what we now have in PIPEDA. First of all, the first word is “consumer”—the consumer privacy protection act—labelling us all as consumers. We are commodities, with our information to be commoditized.
It provides a private right of action once we complain to the commissioner, who is—like most of them—chronically underfunded. Once they finally get around to assigning the file, investigating, deciding and determining, it will go to a new tribunal, which I expect will have to at least review this, if not provide a fulsome re-investigation. If the tribunal agrees with the commissioner that a fine is in order, then the offending company has the right to take it to court.
How many years will that take? Once they have exhausted their legal recourse, you and I get to advance our private right of action. We then pay another lawyer and go through another 7-10 years.