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Industry committee I think the clause is good because it provides greater clarity. If we are going to stay with the regime of consent, you want something that is clearer rather than more vaguely worded. My broader concern about where Bill S-4 is right now in 2015 is that we have seen that all of th
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee If I understand the question correctly—and thank you for the question—it was asking what we need beyond the compliance agreements that are currently in the bill. I think what we need is the power, at the end, for the commissioner to make an order and instruct those companies to
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee If not in this iteration of the bill, certainly I would want to see it in regulation, because the bill in its current form is still under the old model. Make no mistake, while I'm stating these opinions as an individual, privacy commissioners will tell you how important consent i
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee Well, if you really wanted to contemplate that, I would introduce restrictions on how companies use and disclose information, so that it's not as if consent is the gateway to an agreement with you where you've agreed and anything goes. Rather, there would be only certain purposes
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee In terms of enforcement, part of the problem that we have concerns the role of the commissioner. The commissioner, who does not have the ability of other commissioners to issue orders to companies, is not viewed by companies, and typically by small businesses.... We see a lot of
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee Thank you very much for the question. I think the real issue is what has been happening with the digital economy and with services, as you can see. Certainly, since PIPEDA came into force, the idea of consent has changed. Instead of protecting us as individuals, it provides comp
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee It is leaving the decision to industry itself but I think the more important issue is that the standard has been set at a certain level. I know there has been a lot of debate over the appropriate wording and the standard had been set finally at a level that is fairly high. In my
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee As I understand this clause, it was at the request of businesses in terms of mergers and acquisitions where they felt that to go and technically request the consent of each customer when a merger is contemplated or something of the sort would be cumbersome and the customer's info
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee Thank you very much for the question. I will repeat what earlier witnesses have said and I'm in agreement with them. I think the clause as written is overly broad. I think it corrects something that, in fact as this committee heard from the bankers, does not actually need correc
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee The mandating of breach reporting is, of course, a useful step that has been called for by privacy advocates for many years. I see it as a necessary step that in fact will bring us in line with other jurisdictions. In the investigations of the House committee on access to informa
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee I think if it were possible to achieve that through legislation, then other places would have tried that. But I do think the committee might want to look at the obligations and responsibilities of major companies and major platform providers, which, in the United States, have alr
March 24th, 2015Committee meeting
Prof. Avner Levin
Industry committee Thank you, Mr. Chair. Thank you for the invitation to appear in front of the committee. I apologize that I'm not bilingual, so my comments will be in English. I'm an associate professor and the director of the Privacy and Cyber Crime Institute at Ryerson University and I'm appear
March 24th, 2015Committee meeting
Professor Avner Levin
Information & Ethics committee That's right. We've tried to launch research projects to investigate these questions exactly, and in order to do that we wanted to get access to the information from the banks. We were willing to sign whatever they required in terms of anonymity and confidentiality and all of tho
May 1st, 2014Committee meeting
Prof. Avner Levin
Information & Ethics committee Exactly. I have not been able to do that.
May 1st, 2014Committee meeting
Prof. Avner Levin
Information & Ethics committee I don't want to be glib, but I have absolutely no idea. They refuse to share anything about their practices or their policies with academics. I would be speculating if I were to tell you that they're doing okay in terms of the algorithms they are running, in terms of the credit c
May 1st, 2014Committee meeting
Prof. Avner Levin