I will start by saying that I don't think my office has looked at the question of open banking with any details. I think we're outside the scope of the PCMLTFA here. We're probably dealing with the interactions between consumers and an organization subject to PIPEDA, the federal private sector privacy legislation. There is a relationship, of course, between the individual whose personal information is collected by the bank, an organization; and the data, if it is personal information, needs to be handled according to PIPEDA.
On February 28th, 2018. See this statement in context.