Add Your Comment by Prem Rose (CC BY-NC 2.0)

Add Your Comment by Prem Rose (CC BY-NC 2.0)


Tracking the Submissions: What the Government Heard in its Online Harms Consultation (Since It Refuses to Post Them)

The Canadian government’s consultation on online harms concluded earlier this week with a wide range of organizations and experts responding with harshly critical submissions that warn of the harm to freedom of expression, the undermining of Canada’s position in the world as a leader in human rights, and the risk that the proposed measures could hurt the very groups it is purportedly intended to help. I posted my submission and pulled together a Twitter stream of other submissions.

There has been some press coverage of the consultation response from the Globe and Mail and National Post, but Canadian Heritage officials have said they will not post the submissions they received, claiming some “may contain confidential business information.” Keeping the results of the consultation is secret is incredibly damaging, raising further questions about whether the government plans to incorporate the feedback or simply march ahead with an extreme, deeply flawed proposal.

I have filed an Access to Information request for the submissions, but in the meantime have posted links to all the publicly posted submissions I have found. I am happy to continue to update this post, so feel free to forward links to other submissions (I can also post the submission itself if preferred).

UPDATE: The Access to Information Act request has provided hundreds more submissions. It can be accessed here and a post on the results here.

Online Harms Consultations Submissions (Last Update: April 24, 2022)


Access Now
Canadian Association of Research Libraries
Canadian Association of University Teachers (CAUT)
Canadian Civil Liberties Association
Canadian Coalition for the Rights of Children
Canadian Internet Policy and Public Interest Clinic (CIPPIC)
Centre for Law and Democracy
Chinese Canadian Council for Social Justice
Citizen Lab (Cynthia Khoo, Lex Gill, Christopher Parsons)
Cybersecure Policy Exchange
Global Network Initiative
Global Partners Digital
Google Canada
Independent Press Gallery of Canada
International Civil Liberties Monitoring Group
Internet Archive Canada
Internet Society Canada Chapter
Joint Submission from Civil Liberties and Anti-Racism Groups
LEAF – Women’s Legal Education and Action Fund
News Media Canada
Public Interest Advocacy Centre
Ranking Digital Rights

Individual Experts

Blayne Haggart and Natasha Tusikov
Darryl Carmichael and Emily Laidlaw
Drew Wilson
Fenwick McKelvey
Michael Geist
Valerie Webber and Maggie MacDonald


  1. I suspect the Liberals are having a “marie Antoinette moment where they have decided this proposed bill is perfect and needs no input from the public. The arrogance of the Liberals is appalling and all Canadians should be mad as hell they will try to silence their free speech. We had a chance to ditch these turkeys and it didn’t happen.

    • Or we still expect to be able to “Section 2” this nonsense to the curb in court if it gets into actual statute books.

      For myself, I wonder about the NAFTA 2.0 or Harper-Xi FIPPA deals having hidden clauses requiring the denial of Section 2 of the Charter. I’m just paranoid enough for that right now.

  2. Nobody should be surprised. This is not the first time around for this:

    1. Hold a consultation-theatre
    2. Ignore submissions
    3. Go ahead and do what you were going to do anyway


    • I should have added a step:

      2b. Hold back the most damning submissions

      So that there is a least a thin veil of deniability.

  3. YourReader says:

    Retroactively secret submissions. Submissions to the public consultation are supposed to literally be public. That’s what it’s for. Secrecy undercuts any argument to enact legislation. How can they think they could use this meaningless doubletalk to justify any action? Who are they trying to impress, Franz Kafka?

    Thank you Mr. Geist for collecting and presenting the open-letter submissions. You just did more work than the government has done on this.

  4. Here’s my response:

    I’m basically responding in an effort to protect my website. This helps in offering a perspective from a website owner. One thing that did concern me is the fact that the paper recommends regular reports to the Digital Commission superstructure. Specifically, they are asking for what harmful content exists on the site, how the site “profits” off of it, the quantity of harmful content on the site, etc. While this is a comparatively boring aspect of the consultation, the thing is, it is demanding that a site admin like myself would quantify something that is subjective. What we count as “harmful” can, as widely noted, change. This is an impossible thing for someone like myself to follow through and deliver in the first place.

    This is not to say that other aspects of this proposal are not dangerous. They are. I just thought that this aspect of the paper may not be discussed enough.

    Anyway, I’ve been trying to track these submissions and publishing reports as I find them. This is certainly helpful.

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  9. Matthew Marinett says:

    Hi, I’m an SJD Candidate at U of T. These are the comments I sent in on the 25th. I didn’t get to publicly posting them until today, however. Feel free to include in the list.

  10. ROBERT S SCIUK says:

    As with their firearms legislation “consultation”, they will ignore everything, and do as they please. Trudeau must go!

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