Privacy Commissioner Extends Deadline for Transborder Data Flow Consultation

The Office of the Privacy Commissioner of Canada (“OPC”) has announced it will now be accepting comments related to its consultation on transborder data flows until Friday, June 28, 2019.

The discussion document, which was released on April 9, 2019 (see our blog post here, and our blog post about the OPC’s supplemental consultation paper here) reflected a reversal in the OPC’s twenty-year-old policy position on transborder data flows under the Personal Information Protection and Electronic Documents Act (“PIPEDA“).

The OPC has indicated that it intends to provide guidance on disclosures for processing and related consent and accountability requirements.

In a move which may give some comfort to organizations which were surprised by the proposed reversal of the OPC’s position, the OPC further advised organizations that “[w]e are currently consulting and do not expect organizations to change their practices at this time.”

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For more information about Denton’s data expertise and how we can help, please see our Transformative Technologies and Data Strategy page and our unique Dentons Data suite of data solutions for every business, including data mapping, contractual review, and consent benchmarking.

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Kirsten Thompson

About Kirsten Thompson

Kirsten Thompson is a partner in our Corporate group in Toronto and is the national lead of the Transformative Technologies and Data Strategy group. She is also a key member of the Privacy and Cybersecurity group. She has both an advisory and advocacy practice, and provides privacy, data security and data management advice to clients in a wide variety of industries.

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