Our second concern relates to flaws in relation to children's privacy. Those flaws are still present despite the amendments announced at the start of the consultations.
Although Bill C-27 recognizes the sensitive nature of minors' personal information, we believe it does not go far enough to really protect children's privacy. We propose that the protection provided by this bill be strengthened by incorporating the best practices recognized in international law.
First, the bill has to offer stronger protection for children in the digital universe, by protecting them from commercial exploitation of their personal information. The web applications that children use may collect countless pieces of data about them. That data may then be used for profiling or targeting the children for commercial purposes. There is nothing in Bill C-27 that prohibits those practices.
Second, the act should provide that decisions concerning a child's personal information must be made in the child's best interests. The concept of the best interests of the child provides for a more comprehensive vision of privacy than mere recognition of the sensitive nature of the child's personal information. For example, it allows for an assessment of whether the use of the child's personal information by a business promotes his or her overall development and whether the child's rights are being exercised for his or her benefit.
For example, it might not be in the child's interest to give the child's parents or guardians access to his or her personal information where the child is being abused by them. An analysis based solely on the sensitive nature of the personal information would not limit access of that kind.
We will be pleased to answer your questions.