Good afternoon, everyone.
Yes, indeed, we have received a long list of Bill C-27 recommendations from our members. A detailed brief was submitted to INDU in September and is available on the committee page, just so you're all aware. Please note that our analysis of the bill is ongoing as new material becomes available, such as the eight government amendments. Therefore, we are working with members to produce additional feedback to complement our earlier submission.
I’d like to take the opportunity to underscore a few key recommendations. First, a core position of the Canadian Chamber of Commerce is that there need to be amendments to better define many of the principles and concepts in Bill C-27 and to harmonize the bill with the norms and standards found in existing provincial and international law. Interoperability is paramount.
Among our recommendations on the CPPA, we are suggesting that the following elements align with Quebec’s law 25: that the term “minor” be defined to include an age, that the definition of “anonymize” be in line with industry standards, and that the scope of the private right of action be narrowed. We also want to underscore the importance of legitimate interest exceptions in the current bill.
On AIDA, we were encouraged to see that government amendments would be forthcoming with respect to defining high-impact systems, creating clearer obligations along the AI value chain, and ensuring alignment with the EU AI act and those in other advanced economies. We look forward to seeing the text of these amendments to provide more specific feedback.
However, other matters remain unaddressed thus far, such as better defining the use of the term “harm”. Our members have also raised serious concerns around the criminal liability element of AIDA, noting that Canada is the only jurisdiction in the world with such penalties. There is a belief that this provision might discourage businesses developing or deploying AI from setting up operations in Canada or even force some to leave, based on risk assessment.
Finally, in terms of coming into force, it’s important that our businesses, especially SMEs—because small business is big business in Canada—have adequate time to adapt to new environments and requirements. We therefore recommend a phased implementation of CPPA and AIDA over a period of 36 months.
Thank you very much.