Finally, Chairman, we would like to touch on a provision that has already received a lot of attention by other witnesses: proposed PIPEDA section 6.1, in clause 5 of the bill, describing when consent is valid.
We believe a clear and consistent understanding of consent for the purposes of privacy legislation has developed across Canada during the last decade or so. We are concerned, therefore, that the attempt at clarification may well create more confusion than fulfill the purpose for which it was created. We understand that this amendment is aimed at supplementing the test for informed consent in the context of, for example, minors in their online interactions. But proposed section 6.1 is not limited to the areas of concern expressed. Without clarification in the bill, in regulations, or by some other formal means, it raises questions for organizations as to what is expected of them and how it would be applied and interpreted. We suggest that such clarification is necessary and can be achieved through guidelines or regulations.
Chairman, the goal of our industry is to improve the workability of personal information privacy rules by promoting the adoption of provisions that are practical, predictable, and harmonized across the country as much as possible.
The industry greatly appreciates this opportunity to participate in the committee's review of Bill S-4. We would be pleased to answer any questions you may have.
Thank you.