Industry committee  I would just reiterate my initial comments that I support a separate tribunal. Despite the misgivings of the Privacy Commissioner, I think that would be a useful forum and protection for the development of the law in this area.

Industry committee  That is correct.

Industry committee  I think your concern is correct, and I do worry about the wording, particularly in proposed subsection 18(3). The member of Parliament, Mr. Perkins, raised that issue. I think you should delete the word “internal” from that proposed subsection 21. I am concerned about the abilit

Industry committee  I think the privacy management program effectively does deal with privacy by design. It forces organizations to develop their policies. It forces organizations to consider privacy impacts. I think overall that achieves what you want. If we didn't have privacy management programs

Industry committee  I think that one thing that has been discussed at length and is an important discussion is bias. The legislation and the discussion have moved around issues of bias to ensure cultural protection. Bias in any way in that regard in the legislation should strive not to prejudice any

Industry committee  Are you speaking with respect to the privacy legislation or the artificial intelligence legislation?

Industry committee  I didn't get the translation for that, unfortunately.

Industry committee  Again, I think that the issues are issues of bias. I think that's where your concern should be in ensuring that French language rights are protected and that artificial intelligence isn't in any way biasing French as a common language of discourse in our country.

Industry committee  Innovation, as you saw from my remarks, and research and development are fundamental. We have to be very careful as we move forward with this legislation. My remarks were to carefully distinguish between research and development and artificial intelligence that's rolled out in a

Industry committee  I think you would have to get to the GDPR standard of a stand-alone right. If you don't have implied consent, you're going to go for a stand-alone right for that legitimate interest.

Industry committee  I'm fine with the structure as it is, with legitimate interest as an exception. I think that's a balancing. If you get rid of implied consent, I think you're heading down the path, then, of a stand-alone right.

Industry committee  I understand your concern, and my sympathies are with the interpretation of this legislation as consumer protection legislation. I think the status of the current law to date is that that's what it is, so courts and potentially a tribunal will look at the facts of any case from t

Industry committee  Sure, I'd be happy to do that.

Industry committee  Potentially it could be interpreted that way, and that's why I think there's an added reason to delete it.

Industry committee  Thank you, Mr. Chair and members of the committee, for having me here today on the important matter of reform of our privacy legislation and Bill C-27. I'm a partner at the law firm of Clark Wilson in Vancouver, and I'm called to the bar in Ontario and British Columbia. I've bee