In April of this year, as discussed in our
previous blog posts, the Office of the Privacy Commissioner of
Canada ("OPC") called for changes to the
way Canadian privacy law treats transborder personal data
transfers, and commenced a consultation process.
This process was first supplemented (in a supplemental document
released April 23, 2019), then suspended (as announced by
Commissioner Therrien during the 2019 Canadian Privacy Symposium on
May 23, 2019), and now reframed (on June 11, 2019,
the OPC released a document entitled "Consultation
on transfers for processing – Reframed discussion
document"). This document builds on the previous
position statement from April 9, 2019 and the supplemental document
released shortly thereafter, to restate its position on the current
law as well as potential amendments to the Personal Information
Protection and Electronic Documents Act
("PIPEDA") and request for public
feedback. This was necessary after the federal government