Information & Ethics committee  We currently have a very good relationship with the Privacy Commissioner. We meet with them regularly to discuss issues. I think their role is to encourage compliance with PIPEDA and to facilitate that and to help give us the tools to allow us to comply with PIPEDA. The evidence is there.

Information & Ethics committee  As Mr. Elder just suggested, some of it is very paper-based. To amend it to allow for publication, not only with regard to blogs but if somebody is voluntarily putting information someplace else, would be helpful.

Information & Ethics committee  When the publicly available information regulations were promulgated, they talked about telephone books, professional directories, and so on, with that type of information being considered publicly available. Now people voluntarily put their information online and in any other media.

Information & Ethics committee  The regulations set out, I think, five or six categories for the exact type of information that can be considered publicly available.

Information & Ethics committee  I would favour a broader definition that would be more technologically neutral.

Information & Ethics committee  In PIPEDA there are exceptions regarding disclosure without consent, under which banks can disclose to other organizations only in instances of fraud.

Information & Ethics committee  It does certainly restrict us, because it's restricting it to fraud. There are other things like bank robberies, money laundering, and so on, that certainly aren't fraud but they are definitely criminal activities. We would like to have the definition broadened or the concept broadened so that for the rest of these types of crimes, the banks can share information with other organizations and other banks.

Information & Ethics committee  Actually, before PIPEDA was amended, we had the bank crime prevention and investigation body. It facilitated the exchange of this type of information among the banks, but with the most recent change to PIPEDA, we've taken away investigative bodies and now we have these two exemptions from disclosure.

Information & Ethics committee  I can ask my legal counsel to opine on that one, if you'd like.

Information & Ethics committee  Thank you very much, Mr. Chair, and good afternoon. My name is Linda Routledge, and I'm the director of consumer affairs with the Canadian Bankers Association. With me today is Charles Docherty, our senior counsel. We are pleased to be here today to discuss the Personal Information Protection and Electronic Documents Act.

Industry committee  The banks' compliance divisions have a very close relationship with the Privacy Commissioner's office. Many times, when they have a question about compliance, they will talk to that office. As an association, we host an annual meeting with the regulator so that we have the opportunity to exchange information with them.

Industry committee  There is a specific provision in the Bank Act prohibiting it.

Industry committee  The banks generally speaking would see potential or suspected financial abuse in the branches. It could be a client coming in with a caregiver or whoever and there being some kind of suspicious transaction. Right now, the first step of the bank would be to try to take that client aside so that they get them away from the suspected abuser, so that they can determine what the client wants to do.

Industry committee  Absolutely.

Industry committee  Yes, it would.