Given our experiences, we have specific recommendations for how any federal commercial privacy legislation must be amended to better protect individuals from the predations and power of private organizations. In making our recommendations we have chosen to focus almost exclusively on the Openness and Transparency, Access to and Amendment of Personal Information, and Whistleblower sections of Bill C-11.

In order to contribute to the IPC’s deliberations in the triaging of its strategic priorities, this submission serves to provide particularized input with respect to the IPC’s public interest mandate in the oversight of law enforcement authorities when it comes to the use of algorithmic policing technology in Ontario.

Using the AMI approach, partners have launched projects around the world, including in Australia, Canada, Hong Kong, Indonesia, Malaysia, and South Korea. These projects focused on making data access requests to telecommunications companies in each country, led by a local researcher and a team of volunteers. Every country has specific laws, regulations, and corporate mechanisms that present unique challenges and opportunities in accessing data, but the results of each provide insights into the larger ecosystem of data access. 

The proposed rationales for weakening encryption would exchange marginal gains in limited investigative situations for significant loses with regards to Canadians’ abilities to exercise their rights and freedoms while simultaneously undermining cybersecurity, economic development, and foreign affairs. Minister Goodale should stop calling persons with well-considered policy positions on the importance of enabling the availability of strong encryption as supporters of child abusers, and get on with his job of trying to keep Canadians safe instead of endangering them with his irresponsible and dangerous encryption policy.