Mr. Chair, I think this is one zone in which the devil will very much be in the details. I think we've had discussions at this committee before about exhaustive versus non-exhaustive lists, and where lists are indicative but not exclusive. Insofar as an amendment suggests what personal information is, we see that as actually limiting because right now the definition, including with this amendment, will still be quite broadly interpretable in the sense that it means information about an identifiable individual, and then the amendment would amend that definition to ensure that it expressly captures “inferred”. However, if it started to go into a list of potential technologies or zones, it would very much depend on the construction, because sometimes, due to the construction of some of those amendments, it actually becomes a definitive list, which means it's not further expandable over time. You have to word it appropriately to ensure that this is indicative and illustrative, not exhaustive. This is a zone in which OPC guidance and jurisprudence can often fill that gap—particularly as it could then keep up with the times and the technology—rather than hardwiring things into the legislation that might not stay current.
On April 29th, 2024. See this statement in context.