The IIAC (Investment Industry Association of Canada) provided input on Innovation, Science and Economic Development Canada (ISED)’s proposals to modernize the Personal Information Protection and Electronic Documents Act (PIPEDA).
IIAC noted it was pleased with the government’s goal to respect individuals and their privacy by providing them with meaningful control without creating onerous or redundant restrictions for business; enable responsible innovation on the part of organizations; and ensure an enhanced, reasoned enforcement model.
PIPEDA should maintain its principles-based and technology-neutral approach, allowing it to evolve with technology without requiring ongoing amendments, the IIAC said in its comment letter.
“In addition, it is important that PIPEDA continue to be based on the accountability principle to avoid complex, prescriptive requirements that result in regulatory loopholes and the need to constantly update the regulation to keep up with new developments. The accountability principle should, however, include clear requirements for accountability for processors and other third parties that use, store or otherwise come into contact with the data,” according to IIAC letter.