Absolutely, it's important that this bill balance the need for police forces to have the tools they need with protecting Canadians' privacy, and we can do that. It's not a zero-sum game between privacy and security. We address this in our written brief in our first three recommendations.
Specifically, the first thing that should be done is to narrow the definition of “subscriber information”. Change it from what it is here, which includes broader concepts like “information that may be used to identify” individuals or “information relating to the services”, and narrow that to specific items such as the name, address, telephone number and email address. We specify that in our brief.
The second thing is to restrict the scope of who can get those orders to telecommunications service providers. That's already there for the warrantless requests on confirmation of service demand, but in terms of the subscriber information, it's open to “a person who provides services”. That in our view is too broad. It could capture medical offices and law offices, and capture any amount of sensitive information.
The last element is that you should provide more specificity in terms of what the judge's order will be. Right now, it says “any subscriber information” and “all the subscriber information” related to something, and that could be broad. We're suggesting a narrowing of that language.
I'll flag the last element in terms of the non-warrant search or confirmation of service demand. There's an exception for medical and privileged information, and that exception is also absent in terms of the subscriber information.
Those are the recommendations I would make.