ARTICLE · 12 NOVEMBER 2026

Canada’s First Children’s Privacy Code: What Does It Say?

Torkin Manes LLP

Explore more from Torkin Manes LLP

On October 20, 2026, the Office of the Privacy Commissioner of Canada (the “OPC”) launched Canada’s first Children’s Privacy Code (the “Code”), which guides how organizations should collect, use and disclose children’s personal information online.

GlobalPrivacy

Author LinkedIn connections

On October 20, 2026, the Office of the Privacy Commissioner of Canada (the “OPC”) launched Canada’s first Children’s Privacy Code (the “Code”), which guides how organizations should collect, use and disclose children’s personal information online. The Code interprets how the Personal Information Protection and Electronic Documents Act (“PIPEDA”) applies to children, whom the OPC recognizes as privacy rights-holders deserving of enhanced protection. Critically, it applies to any organization subject to PIPEDA whose online services are directed at children or are likely to be accessed by children. If your organization operates a website, app, platform or digital tool that children use, or may use, read ahead.

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.

Register for freeORLog in

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.

Related Articles

Privacy Reform Hits The M&A Deal Table: What Bill C-36 Means For Buyers, Sellers And Boards

Pallett Valo LLP

A Comparison Of The PPCDA, PIPEDA, Quebec's Privacy Act And PIPA: Part 2

Bennett Jones LLP

Canada’s New Children’s Privacy Code Signals Regulatory Expectations Of Online Services

PHP Security Vulnerabilities: Legal Considerations For Your Organization

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

Bennett Jones LLP

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

Comparative Guide

Data Protection & Cybersecurity

See more popular content from

Privacy

Implications Of Bill C-34, Canada’s Proposed Online Safety Framework, For Organizations

Canada's proposed Digital Safety Act introduces sweeping new obligations for social media platforms, AI chatbots, and interactive online services, requiring operators to protect children, mitigate harmful content, and implement age-verification measures. Organizations face substantial penalties of up to 5% of global revenue for non-compliance, backed by a new federal regulator with broad enforcement powers. What steps should your organization take now to prepare for this emerging regulatory framework?

Draft Canadian Security Breach Regulations Finally Unveiled

Affected U.S. businesses should review their current practices and consider establishing the safeguards set forth in the proposed regulations to avoid monetary penalties.

Torkin Manes LLP

The Price Of A Data Breach: Target Reaches $10M Settlement In U.S. Privacy Class Action

On March 19, 2015, the United States District Court in the District of Minnesota gave preliminary approval to a proposed settlement for the December 2013 data breach suffered by Target Corporation.

Canada’s Children’s Privacy Code: What It Means For Your Organization

On October 20, 2026, the Office of the Privacy Commissioner of Canada (OPC) released its Children’s Privacy Code (“the Code”). It is not new legislation, but that does not make it optional. The Code lays out how the OPC reads the Personal Information Protection and Electronic Documents Act (PIPEDA) when children’s personal information is involved online, and it is a clear preview of what the regulator will look for in complaints and investigations.

Privacy, Data Protection, And Cybersecurity: What Foreign Companies Must Consider Before Entering The Canadian Market

Foreign companies entering Canada often assume their existing privacy programs designed for GDPR or CCPA compliance can simply extend to Canadian operations, but Canada's legal requirements demand targeted modifications. This comprehensive guide examines Canada's private sector privacy legislation, breach reporting obligations, AI governance expectations, and anti-spam regulations that businesses must navigate before launching in the Canadian market.

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

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.

Bennett Jones LLP

OPC Issues New PIPEDA Guidance On Assessing Third-Party Service Providers

Canada's privacy regulator has released new draft guidance establishing comprehensive due diligence standards for organizations evaluating third-party service providers under PIPEDA. The framework introduces eleven best practices covering everything from data flow mapping and AI training data sourcing to vendor lock-in risks and ongoing monitoring obligations, signaling heightened expectations for privacy accountability in vendor relationships.

Bennett Jones LLP

Canadian Privacy Regulators Publish Findings And Guidance On OpenAI Privacy Compliance

Federal and provincial privacy regulators have concluded a multi-year investigation into OpenAI's data practices, finding contraventions of Canadian privacy legislation in how personal information was collected and used...

Canada’s OpenAI Findings: What Businesses Need To Know About AI And Privacy Compliance

Canadian privacy regulators have completed a joint investigation into OpenAI's ChatGPT, examining whether the company's collection, use, and disclosure of personal information complies with federal and provincial private-sector privacy legislation. The investigation involved the Office of the Privacy Commissioner of Canada alongside regulators from Quebec, British Columbia, and Alberta, scrutinizing OpenAI's practices in developing and operating its AI chatbot platform.

Aird & Berlis LLP

Quebec's Privacy Law 25: What You Need To Know

The Canadian market is ripe with opportunities for U.S. companies seeking to expand beyond domestic borders. Before diving in, however, it can be helpful to have a basic understanding of Canada's legal system...