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ARTICLE · 28 OCTOBER 2025

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De-Identification Of Personal Information And The New IPC Ontario Guidelines

Borden Ladner Gervais LLP
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Under Canadian privacy law, "de-identified" data can be used for research, product development and other such "secondary purposes" without individual consent and without the normal protections that apply to personal information.

CanadaPrivacy
Daniel J. Michaluk
Daniel J. Michaluk
Marc Vani
Marc Vani
Avital Sternin
Avital Sternin
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Under Canadian privacy law, "de-identified" data can be used for research, product development and other such "secondary purposes" without individual consent and without the normal protections that apply to personal information. On October 15, 2025, the Information and Privacy Commissioner/Ontario updated its guidance on the de-identification of personal information. The new guidance is set out in a 96-page document entitled De-Identification Guidelines for Structured Data; Updated and Expanded. This new guidance updates and expands guidance first issued by the IPC in 2016 in setting out how to transform personal information into data that neither identifies individuals nor unacceptably risks their re-identification.

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