The Federation of University Students of Quebec represents 15 member associations and roughly 125,000 students in Quebec.  In its submission on Bill C-32, it added its voice to the criticism of digital lock rules, noting that the regulation making process for new exceptions is insufficient and that new exceptions should be included within the law from the start:

Another element that seems inopportune in the current bill is article 41 on digital locks, better known under the acronym DRM (Digital rights management). These technologies lock certain digital contents so that they cannot be reproduced. This article includes a series of exceptions that can apply, but the academic exception and fair use seem once again absent in this regard. As an example, we allow people with a “perceptual impairment” to be excluded from the provisions of clause 41.1(1)a).

On the other hand, article 41.21(1) specifies that the “governor in council can, by regulation, exempt from application of article 41.1 all technical protection measures of the work (…).” Among the categories that could eventually make use of this modality are educational institutions and those that act under their authority. According to the FEUQ, it is preferable to limit the problems at the source and include educational institutions in the exception set out for other categories rather than wait for a law suit to occur, which would lead to acting in a regulatory manner and ad hoc.

Previous Daily Digital Locks: Provincial Resource Centre for the Visually Impaired (PRCVI) BC, Canadian Consumer Initiative, Retail Council of Canada, Canadian Council of Archives, Canadian Teachers’ Federation, Canadian Federation of Students, Canadian Civil Liberties Association, Documentary Organization of Canada, Canadian Library Association, Council of Ministers of Education Canada, Business Coalition for Balanced Copyright, Canadian Association of Research Libraries, Canadian Historical Association, Canadian National Institute for the Blind, Canadian Bookseller Association, Canadian Home and School Federation, Film Studies Association of Canada, Canadian Bar Association, Canadian Federation for the Humanities and Social Sciences, Appropriation Art, Privacy Commissioner of Canada, Association of Newfoundland and Labrador Archives, Canadian Association of Law Libraries