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ARTICLE · 09 NOVEMBER 2026

The New Canadian Children's Privacy Code Could Impact Your Organization

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Canada's Office of the Privacy Commissioner has launched the country's first Children's Privacy Code, establishing comprehensive guidelines for how organizations must handle the personal information of minors online. The Code introduces strict requirements around consent, data minimization, and prohibits practices like behavioral profiling for marketing purposes, with expectations that organizations implement age-appropriate privacy protections now rather than waiting for upcoming legislative changes.

CanadaPrivacy
Caroline Poirier
Caroline Poirier
Ruth Promislow
Ruth Promislow
J. Sébastien Gittens
J. Sébastien Gittens
Matthew Flynn
Matthew Flynn
Stephen D. Burns
Stephen D. Burns
Alexia Armstrong
Alexia Armstrong
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On October 20, 2026, following an exploratory consultation that concluded in August 2025, the Office of the Privacy Commissioner of Canada (OPC) launched Canada's first Children's Privacy Code (the Code), aimed at creating a "safer, more transparent online environment for children and teens." This new Code builds on the Personal Information Protection and Electronic Documents Act (PIPEDA) to establish clear guidance on how organizations should collect, use, and disclose the personal information of children.

The OPC is accepting comments on the Code until January 20, 2027, after which the document may be updated.

The OPC states that the Code is intended to ensure that children’s personal information is collected, used and disclosed in ways that respect their rights, account for their evolving capacity and serve their best interests. Recognizing that children are not a homogenous group, the Code reinforces the OPC's expectation that organizations will apply measures that are

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