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Industry committee  I agree with many of the other witnesses here today in supporting a change to the definition of anonymization to align more with Quebec's definition and maintain some interoperability there. Given the way it's drafted now, it's an impossible standard. The other—and I'll make reference to my opening remarks—would be to change the consent exception framework for public interest purposes.

November 9th, 2023Committee meeting

Alexander Jarvie

Industry committee  Yes. If we were to undertake the suggestion to combine or generalize proposed sections 35 and 39, to make it a bit more like the framework in Quebec's Law 25, which begins at section 21 of that law, then it would involve what is styled in that law as “privacy impact assessments”.

November 9th, 2023Committee meeting

Alexander Jarvie

Industry committee  Sure, I will. This was part of my opening statement. It's actually imperative that we have some independence from the ministry for the artificial intelligence and data commissioner. A parliamentary officer sounds like a good way to effect this, as long as it's at arm's length in some way, so that there is someone outside the ministry who is going to be looking after all these regulations and actually calling them on it.

November 9th, 2023Committee meeting

Alexander Jarvie

Industry committee  I don't want to overstate what I know would work or wouldn't work as a mechanic in terms of embedding it in the law. I think it would, but take that with a grain of salt, because I'd have to do my own legal analysis on that.

November 9th, 2023Committee meeting

Alexander Jarvie

Industry committee  I just want to add that this is one of the reasons I think AIDA should address the concerns of groups, the harms that could be effected against groups or communities. This is a great example.

November 9th, 2023Committee meeting

Alexander Jarvie

Industry committee  Thank you very much. Good afternoon, and thank you for the invitation to share my thoughts on Bill C-27 with the committee. I am a partner at Davies Ward Phillips & Vineberg LLP, practising as a lawyer in the firm’s technology group. I am appearing today in a personal capacity, presenting my own views.

November 9th, 2023Committee meeting

Alexander Jarvie