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Data Privacy Alert: Privacy Commissioner of Canada Announces Strategic Plan

Why This Announcement Is Important 

In the run up to Data Privacy Week, Privacy Commissioner of Canada Philippe Dufresne announced the three strategic priorities that his office will focus on for the next three years. These priorities clearly articulate some of the biggest challenges privacy regulators around the world are facing.


On January 22, 2024, the Office of the Privacy Commissioner of Canada (OPC) announced three priority initiatives for the next three years based on its interactions with key stakeholders:

  • Maximizing the impact of its work to promote and protect the fundamental right to privacy
  • Advocating for privacy in a time of tremendous technological change
  • Championing the privacy rights of children

In a statement, Commissioner Dufresne said, “The privacy issues and risks that we collectively face as a society, in both the public and private sectors, are vast and, at times, can seem challenging, however we face the situation with optimism. These strategic priorities are where I believe that my Office can have the greatest impact for Canadians and where the greatest risks lie if they are not addressed.”

The announcement was timed to the beginning of Data Privacy Week, which is held each year during the last week of January to call attention to the impact technology has on privacy rights.

What It Covers 

Further details on each of these initiatives are as follows:

  • Maximizing the impact of its privacy promotion and protection: This initiative will involve efforts to improve efficiency and increase adaptability and preparedness. The OPC will use data and partnerships to provide focused guidance and to address private and public sector compliance with privacy rules.
  • Advocating for privacy in a time of technological change: Recognizing the potential of revolutionary tactics, especially in terms of AI and generative AI, the OPC will attempt to encourage the use of privacy-by-design principles to encourage innovation that respects citizens’ fundamental right to privacy.
  • Protecting children’s privacy rights: The OPC recognizes childrens’ need to be able to experience their youth, including in the digital realm, safely and free from deceptive practices. OPC will push for laws explicitly acknowledging children’s special rights and compelling organizations to respect them. 

Commissioner Dufresne’s 2024 Strategic Plan indicates a clear change in tone from previous strategic documents. There is an emphasis on AI both in terms of the OPC’s role and capacity, and developing standards (such as privacy by design) around the use of emerging technologies, but also in the use of technology and information to assist the OPC in its functions, conducting research and leveraging business intelligence. The goals articulated in the plan include providing meaningful guidance for Canadian businesses, as well as cultivating strategic partnerships, not only with other Canadian regulators but other constituencies. And as in many jurisdictions, there is a focus on children’s privacy, mirroring concerns to ensure through collaboration and partnership, effective enforcement in this area.  

While the Plan looks forward to reform of Canada’s PIPEDA, it also articulates that should this not come to pass, an expectations to utilize the existing framework to address the goals of the OPC under current law. The OPC has traditionally issued many guidances, often in concert with provincial counterparts, which effectively shape the expectations and standards under which personal information has been governed, so this can be seen as a clear indication that this will continue and perhaps expand, in the absence of legislative reform.

Constantine Karbaliotis, Counsel, nNovation LLP

Data Privacy Tip 

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