PIAC recently commented on the Ontario Government’s “Public Consultation – Modernizing Privacy in Ontario”. Please find attached three documents:
1) Comments of the Public Interest Advocacy Centre on the above-noted consultation, entitled “Provincial Privacy Reform: A Path to Disorder?”;
2) PIAC’s comments from the 2020 Ontario “Consultations to Strengthen Privacy Protections of Personal Data;” and
3) PIAC’s comments from the Information and Privacy Commissioner of Ontario’s “Strategic Priority Setting Consultation.”

PIAC is strongly opposed to a fragmented privacy regime in which each province adopts their own private sector privacy laws. PIAC has already discussed this position in detail in our submission to the previous Ontario consultation, “Consultations to Strengthen Privacy Protections of Personal Data,” launched on August 13, 2020, and closed on October 15, 2020. For reference, PIAC’s 2020 submission is attached to our submission for this present Consultation. We stand by our position today.
Rather than pressing forward with new provincial legislation, Ontario should focus on strengthening the province’s privacy regime under its existing framework, to better leverage the IPC’s existing mandate to address current weaknesses in key priority areas. There is undoubtedly a great deal of work to be done. PIAC directs the MGCS to, firstly, our October 2020 submission which specifically called for private sector employment privacy reform (which is not done at the federal level and is a lacuna in Ontarians’ privacy protection) and also our attached submission from the IPC’s “Strategic Priority Setting Consultation,” which concluded in January of this year.
PIAC recommends that the Ontario government refrain from taking direction from the reform approach in Bill C-11.