CCLA’s Submission on Bill C-27, the Digital Charter Implementation Act

Daniel Konikoff (Interim Director of the Privacy, Technology & Surveillance program) and Tashi Alford-Duguid (Staff Lawyer) made a written submission to the Standing Committee on Industry and Technology regarding Bill C-27, the Digital Charter Implementation Act. In this submission, CCLA speaks to the Bill’s three parts: the Consumer Privacy Protection Act (CPPA), an update to federal privacy legislation; the Personal Information and Data Protection Tribunal Act (PIDPTA), which would create a new tribunal for imposing penalties on organizations who violate key provisions of the CPPA; and the Artificial Intelligence and Data Act (AIDA), Canada’s first private sector legislation on artificial intelligence (AI).

Unfortunately, Bill C-27 inappropriately frames people’s privacy rights as something to be balanced against and placed below commercial interests. It also fails to capture the complexity of the harms and risks that AI can bring to bear on individuals, communities, and their fundamental rights. CCLA’s submission recommends amendments to the Bill that would prioritize individuals’ right to privacy, and which would better protect people’s human rights and civil liberties in the face of fast-paced technological change.

Stronger, rights-driven governance around AI is not only something that advocacy groups want; the public wants it, too. In July, CCLA launched a petition calling for AI governance that puts human rights first. The petition amassed over 7,000 signatures from individuals across the country. We appended the petition to this submission to show how much these issues resonate with the people upon which these technologies will have the most impact.

Bill C-27’s Preamble states its intent to “modernize Canada’s legislative framework so that it is suited to the digital age.” In its current form, however, the Bill is at risk of lagging behind the times before it can even meet the present.

See here for the complete written submission.