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Industry committee  I'm sorry. I'm listening, but could the translator repeat it? It was at low volume.

November 9th, 2023Committee meeting

David Young

Industry committee  That's a good question. I think it sets, largely, an excellent standard. That would be the way I would characterize it. In comparison with this bill.... I think the bill could learn from Law 25 in a number of areas. Certainly, anonymization and de-identifying are one. There are others, and we haven't touched on those today, in which Quebec provides what I will call a higher standard, a more rigorous standard of privacy.

November 9th, 2023Committee meeting

David Young

Industry committee  I don't buy into that, actually. I heard it at a conference today—that if we don't get these rules right, nobody is going to come to Canada. That isn't going to happen. Marketers know that.

November 9th, 2023Committee meeting

David Young

Industry committee  No. I would phrase it this way, Mr. Masse. It will impact companies, because it will be more costly, more complicated or whatever to come up with the compliance mechanisms. That's the biggest impact on organizations' collecting data if we don't align the standards.

November 9th, 2023Committee meeting

David Young

Industry committee  Are you asking me? Okay. Yes, the commissioner should be independent, absolutely, and appointed by Parliament.

November 9th, 2023Committee meeting

David Young

Industry committee  No, not really. I'd just like to make one sort of general comment. My expertise hasn't focused on AIDA. I've read it. I'm familiar with the European legislation. People have mentioned that it has holes and that it's like part of the EU legislation—part of it. It has the framework, but what it doesn't have....

November 9th, 2023Committee meeting

David Young

Industry committee  Sure. The level of damage that I would address is confusion if we don't align them—confusion for Quebeckers, primarily, if we end up with some different standards. This actually applies elsewhere than the categories of de-identified information. Anonymized information is the main focus.

November 9th, 2023Committee meeting

David Young

Industry committee  I agree with it, yes, absolutely.

November 9th, 2023Committee meeting

David Young

Industry committee  That's right. Half of them in their language use the term “de-identified information”. You don't have to turn around and say it isn't “not personal information”. It just reads that way. That's really what I'm talking about.

November 9th, 2023Committee meeting

David Young

Industry committee  No. It is very confusing. There's a provision, I remember, in a proposed section of the bill, that says basically that de-identified information is not personal information except for these sections, and it's a laundry list of about 20. That's what I'm talking about.

November 9th, 2023Committee meeting

David Young

Industry committee  It's essentially the same point. I was just leading on from that point I just made. It goes back to Bill C-11, which really tried to suck and blow at the same time. It defined a term of “de-identified information”, which if you read it, inherently said it's outside the statute, because it's not personal information—it cannot reasonably identify an individual.

November 9th, 2023Committee meeting

David Young

Industry committee  It's personal information. That's the point. The point is that there are really three levels: personal information, de-identified information and anonymized information. There are different levels of identifiability, let's call it. Personal information is fully identifiable. De-identified information, consistent with both the GDPR and the law in Quebec, does not include a direct identifier, but it may be re-identified.

November 9th, 2023Committee meeting

David Young

Industry committee  Thank you for the invitation to appear before this committee for its important review of Bill C-27. This bill includes significant proposed amendments to Canada's privacy laws at the same time as it introduces a proposed oversight regime for artificial intelligence. The AIDA component warrants focused study by the committee.

November 9th, 2023Committee meeting

David Young