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ARTICLE · 02 OCTOBER 2025

TikTok Takeaways

McMillan LLP
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On Sept 23, 2025, the Office of the Privacy Commissioner of Canada ("OPC") and its provincial counterparts in Alberta, British Columbia (BC), and Quebec...

CanadaMedia, Telecoms, IT, Entertainment
Lyndsay Wasser
Lyndsay Wasser
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On Sept 23, 2025, the Office of the Privacy Commissioner of Canada ("OPC") and its provincial counterparts in Alberta, British Columbia (BC), and Quebec (together with the OPC, the "Privacy Regulators") released the results of their Joint Investigation into TikTok Pte. Ltd. (the "Joint Investigation"). The findings of the Privacy Regulators in this case provide helpful guidance and reminders for social media companies with users in Canada, as well as other organizations that process personal information about children and youth.

Some key takeaways from the Joint Investigation include the following:

  1. Age Assurance for Greater Assurance of Compliance
    Organizations should implement effective age assurance mechanisms to ensure that children are not accessing and using online services that are not intended for them. It will not be sufficient to simply state in the organization's terms of use (TOU) that persons under a certain age are not permitted to use

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The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.

© McMillan LLP 2025

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