Share on LinkedInShare on LinkedIn

ARTICLE · 07 JULY 2026

Bill C-36’s PIPEDA To PPCDA Shift: The Rise Of Documented Privacy Compliance

Miller Thomson
Miller Thomson
Contributor

Miller Thomson

Miller Thomson LLP ("Miller Thomson") is a national business law firm with approximately 500...

View firm profile
Explore more from Miller Thomson

Canada's Bill C-36 proposes to replace PIPEDA with the Protecting Privacy and Consumer Data Act, fundamentally shifting privacy compliance from flexible principles to mandatory documentation and formal governance structures. Organizations would face new requirements for privacy management programs, legitimate interest assessments, and enhanced accountability under a powerful new regulator with significant penalty authority.

CanadaPrivacy

Introduction

Introduced on June 15, 2026, Bill C-361 would enact the Protecting Privacy and Consumer Data Act (“PPCDA“). PPCDA is the federal government’s latest attempt to modernize Canadian privacy law for today’s “data-driven economy.” It is the third major effort to reform the Personal Information Protection and Electronic Documents Act (“PIPEDA”), following the unsuccessful Bill C-11 in 2020 and Bill C-27 in 2022. Unlike Bill C-27, which combined privacy reform with a comprehensive AI regulatory framework, Bill C-36 is primarily focused on modernizing Canada’s privacy laws. Several of its provisions, including those relating to automated decision systems, will have important implications for organizations deploying AI technologies.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

See more popular content from