Information & Ethics committee  Good afternoon and thank you for inviting me here to contribute to your study on PIPEDA. The task facing this committee is challenging but extremely important. Unlike Mr. Cameron and Ms. Reynolds, I'm a corporate lawyer. Among the three of us, there are two litigators and a cor

Information & Ethics committee  Sure. My apologies.

Information & Ethics committee  If anybody missed words of wisdom, let me know.

Information & Ethics committee  For each instance where express consent is required, a copy of the privacy policy should be provided to the individual who provided express consent in a form that can be retained by the individual. This is consistent with consumer protection legislation across Canada. The second

Information & Ethics committee  Sure, and let's be clear about this. If someone's going to commit fraud, it's tough to guard against that, so let me address two points: one, how to do that, and two, the age of 16. I think the age of 16 is consistent with laws across Canada. It's also consistent with the GDPR.

Information & Ethics committee  Yes.

Information & Ethics committee  Let's look through this. Absolutely, there are practical challenges. I'm sure that some of the businesses, including some of my clients, may not be thrilled with your suggestion, but I'm looking at these statistics. These are children. They're not sophisticated youth, no matter h

Information & Ethics committee  Yes.

Information & Ethics committee  Yes, I do, up to the age of 18. I'm not suggesting that the right to be forgotten shouldn't be applicable to adults. I get calls where adults have been slammed on the Internet and have material on the Internet that they reasonably should have removed. For children, this is some

Information & Ethics committee  Sure.

Information & Ethics committee  Thank you. I'll take maybe just a minute or two, and then Ms. Reynolds can respond. It's a good question. It is a struggle to deal with that, which is one of the reasons that I limited my submission to it being applicable to minors. Let's think of the instances in which this ma

Information & Ethics committee  Sure.

Information & Ethics committee  It is, but I think the line in the sand is that until you are an adult, we're going to give you some leeway here. Let's keep in mind that this is in the course of commercial activity. Someone is making a profit off this information.

Information & Ethics committee  This is not a news report. This is not for journalistic purposes. This is in the context of someone making money off this information. I think that whether in my view it's inappropriate or in your view or in the view of the 50 other people here, the minor or the minor's parent s

Information & Ethics committee  First of all, there is uncertainty about on what basis an organization can rely on implied consent. I think that needs to be clarified. That can be included in a model code that's simply attached to PIPEDA, and organizations can simply refer to that. That would shorten the privac