Bottom Line
On November 17, 2020, the Federal Government introduced Bill
C-11, the Digital Charter Implementation Act, 2020
("Bill C-11"). While Bill C-11 has only passed First
Reading at the time of writing this update, it proposes a number of
changes that would impact the way that organizations handle
personal information. Significantly, Bill C-11 would replace Part 1
of the Personal Information and Electronic Documents Act
("PIPEDA") with the new Consumer Privacy
Protection Act ("CPPA").
If Bill C-11 passes, much like under PIPEDA, federally
regulated employers would be subject to the CPPA with
respect to the personal information of their employees. An employer
is considered to be federally regulated where they are involved in
a federal work, undertaking or business. This includes, but is not
limited to, organizations involved in air transportation, radio
broadcasting, banking and inter-provincial or international
transportation.
