Thank you for the question.
Commissioner Dufresne made some excellent recommendations around harmonization and so on.
As for anonymized and de‑identified information, I know that many stakeholders have told you that the definition of anonymization was very restrictive in Bill C‑27. In Quebec, following discussions and exchanges with stakeholders, parliamentarians included some flexibility in the legislation. According to Quebec law, information is anonymized “if it is, at all times, reasonably foreseeable … [for] the person to be identified directly or indirectly”.
However, they were concerned that this might open up too big a loophole. At the same time, it was stipulated that government regulations could impose terms and criteria on how anonymization is done.
De‑identification is also an important issue because of the potential for the use of de‑identified information. Bill C‑27 provides that, at times, de‑identified information is no longer personal information, which means that protection for that information is lost. That is a concern.
My colleague Mr. McEvoy did a good job of presenting the concern about administrative monetary penalties, but also the scope of the penalties. The situations in which the federal commissioner can recommend to the tribunal the imposition of administrative monetary penalties are very limited in Bill C‑27.