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PIAC Submission to the Government Consultation on A Digital Economy Strategy for Canada
PIAC is grateful for the opportunity to comment on the important issues raised in the Consultation Document issued by the Government on Canada on the digital economy. Our comments are based on our work in previous consumer consultations on telecommunications matters before the Canadian Radio-television Telecommunications Commission and previous legal and policy work on electronic commerce, electronic payments and privacy issues.[FN1]
Canada lacks a digital strategy, in comparison to other countries that have spent considerable time contemplating and formulating their digital strategy. Over twenty countries in the world have comprehensive digital strategies, such as the United States’ National Broadband Plan,[FN2] the European Union’s i2010 and Europe 2020: A European Strategy for Smart, Sustainable and Inclusive Growth,[FN3] the United Kingdom’s Digital Britain[FN4] and France’s francenumerique 2012.[FN5]
Most recently, the Standing Senate Committee on Transport and Communications published a report entitled “Plan for a Digital Canada” in June 2010. The Committee initially focused their study on issues with the wireless sector in Canada, but then broadened their study to the digital society after noting that several other countries had comprehensive digital plans, which Canada lacked, and that wireless issues cannot be easily separated from other telecommunications services and broader digital issues. Indeed, the Committee’s first recommendation was that Canada should present a strategy for an inclusive digital society.[FN6]
The scope of PIAC’s submission here is to address the questions asked in the Digital Economy Consultation Paper.[FN7] The intent of our submission is to focus on legislative and regulatory elements that are lacking to provide sufficient consumer protection in the digital economy. The structure of the industry will determine how our future evolves and the progress of Canada’s digital economy. Structural problems with competition and consumer protection will only continue in the framework unless proper and balanced legislation and regulations are put in place to promote competition and protect consumers who use digital technologies.
PIAC notes that the Consultation Paper’s questions are limited to the shaping of a digital economy based on a framework that assumes that a competitive, market-driven model will best address ICTs and digital technologies in Canada’s future. While these are important issues, we are concerned that this limited scope may not achieve what is critically needed at this time: a holistic digital strategy for society as a whole. Thus, we hope that Canada will pursue a comprehensive digital strategy, one aspect of which is a strong digital economy.
FN1 PIAC participated in the roundtable convened by Andrew Clement and Karen Louise Smith supported by the Faculty of Information, Identity, Privacy and Security Institute (IPSI) and Knowledge Media Design Institute (KMDI) at the University of Toronto and endorses the consensus submission. See submission online: The intent of our submission is to focus on legislative and regulatory elements that are lacking to provide sufficient consumer protection in the digital economy. The structure of the industry will determine how our future evolves and the progress of Canada’s digital economy. Structural problems with competition and
http://ipsi2010.pbworks.com/f/2010July9_DigEconSubmissionFinal.pdf. However, PIAC wishes to provide our more detailed view on the issues outlined in this submission.
FN2 United States, Federal Communications Commission, “National Broadband Plan: Connecting America” (2010), online: http://www.broadband.gov.
FN3 European Commission, “Europe 2020: A Strategy for smart, sustainable and inclusive growth” (25-26 March 2010), online: http://ec.europa.eu/eu2020/index_en.html.
FN4 Britain, Department for Business Innovation & Skills, “Digital Britain” (9 April 2010), online: http://interactive.bis.gov.uk/digitalbritain/.
FN5 France, “France numerique 2012 – Plan de developpement de l’economie numerique” (October 2008), online: http://www.ladocumentationfrancaise.fr/rapports-public/084000664/index.shtml.
FN6 Senate Standing Committee on Transport and Communications, “Plan for a Digital Canada” (June 2010), online: http://www.planforadigitalcanada.ca at Recommendation 1 on p. 12.
FN7 Minister of Industry, Minister of Human Resources and Skills Development and Minister of Canadian Heritage and Official Languages, “Improving Canada’s Digital Advantage: Strategies for Sustainable Prosperity, Consultation Paper on a Digital Economy Strategy for Canada” (10 May 2010).
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