On October 20, 2021 the government of the province of British
Columbia (BC) in Canada introduced proposed amendments to the BC
Freedom of Information and Protection of Privacy Act
(FIPPA), which governs data collection and use by public bodies in
the province. The amendments found in Bill 22 range from relatively
minor grammatical changes to more substantive changes summarized
below, as well as consequential amendments to various acts
including the E-Health (Personal Health Information Access and
Protection of Privacy) Act, Income Tax Act and the Secure
Care Act.
Likely the most material proposed amendment relates to
FIPPA's data residency provisions where personal information is
required to be maintained in Canada and not accessible from outside
of Canada except under specific circumstances. Bill 22 contemplates
the repeal of FIPPA's existing section 33.1 with a section that
permits a public body to disclose personal information outside of
Canada only if the
