Retailers note with interest the section that grants the Office of the Privacy Commissioner seemingly unrestricted discretion in releasing any information under its control to the public when deemed to be in the public interest. Retailers would like to see some reasonable limitations around this disclosure clause as, understandably, releasing potentially sensitive business information without parameters risks causing serious and irrefutable reputational harm to businesses.
Our final comments relate to single window reporting and compliance. We note that Alberta has legislated in this area and that other provinces and jurisdictions are considering legislating in this area. We encourage the inclusion of a provision that would ensure single window breach reporting and single window compliance agreements, or any sort of other compliance, as other parties consider legislating in this area. An example might be that the Office of the Privacy Commissioner could be given the ability to waive reporting requirements when suitable notification has already been given in another jurisdiction and handled there. This would avoid unnecessary and potentially administratively onerous double reporting with different formats or multiple compliance requirements.
To conclude our comments, retailers support the bill but think it could be improved by some targeted amendments. We would of course be delighted to work with this committee, Industry Canada, and the Office of the Privacy Commissioner to help secure those improvements.
Thank you.