An Evolving Digital Privacy Landscape—Comparing The Federal Bill C-27's CPPA To Quebec's Bill 64

Introduction

The Act to modernize legislative provisions as regards the protection of personal information¹ ("Bill 64") received royal assent on September 22, 2021, introducing amendments to the privacy regime and the framework governing the use and collection of personal information ("PI") by public and private sector privacy laws in Quebec. Meanwhile, on June 16, 2022, the federal government introduced three new acts under Bill C-27, An Act to enact the Consumer Privacy Protection Act, the Personal Information and Data Protection Tribunal Act and the Artificial Intelligence and Data Act and to make consequential and related amendments to other Acts (or Digital Charter Implementation Act, 2022) ("Bill C-27").² Part 1 of Bill C-27 enacts the Consumer Privacy Protection Act ("CPPA"),³ which is the federal government's latest attempt to modernize the current federal private sector privacy law and a federal equivalent to Bill 64. Bill C-27's CPPA is the second