The Office of the Privacy Commissioner of Canada has released a consultation paper that signals a major shift in its position on data transfers, indicating that it now believes that cross-border disclosures of personal information require prior consent. The approach is a significant reversal of longstanding policy that relied upon the accountability principle to ensure that organizations transferring personal information to third parties are ultimately responsible for safeguarding that information. In fact, OPC guidelines from January 2009 explicitly stated that “assuming the information is being used for the purpose it was originally collected, additional consent for the transfer is not required.”
Archive for April 10th, 2019

Law Bytes
Episode 272: Build Canada’s Lucy Hargreaves on Canada’s AI Strategy and the Need to Shift From Being Users to Builders
byMichael Geist

May 25, 2026
Michael Geist
May 11, 2026
Michael Geist
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Michael Geist on Substack
Recent Posts
Government Moves to Shut Down Lawful Access Hearing In Order To Fast Track Passing the Bill This Week
Canada’s Digital Super-Regulator: Bill C-36 Pushes Out the Privacy Commissioner and Hands Private Sector Privacy to an Overloaded Commission
The Commission: How Bill C-34 Creates an Internet Super-Regulator That Will Touch the Lives of Millions of Canadians
The Law Bytes Podcast, Episode 272: Build Canada’s Lucy Hargreaves on Canada’s AI Strategy and the Need to Shift From Being Users to Builders
Privacy as a Fundamental Right? The Government’s Terrible Privacy Track Record Suggests Virtue Signalling Over a Genuine Commitment

