I would hesitate to comment on how the U.S. would interpret their practices in terms of border crossings.
What I can say is that data crosses borders all the time. That's why I'm flagging the importance of making sure Canadian privacy law takes this into consideration. It does to some extent, as I highlighted in my statement. Organizations have to ensure comparable treatment, but it's through contracts or other means. The problem with contracts or other means is that they are not going to bind the governments of other countries.
This is why one of my key recommendations for privacy law reform in Canada is that we should put in place transborder transfer rules that would require a more stringent consideration in these cases.
