On June 16, 2022, the government of Canada tabled a bill that would make significant changes to privacy laws impacting employers in the federal jurisdiction. The new legislation, the Digital Charter Implementation Act (Bill C-27) would replace Part 1 of the Personal Information Protection and Electronic Documents Act (PIPEDA) and would create three pieces of legislation in its place, the Consumer Privacy Protection Act (CPPA), the Personal Information and Data Protection Tribunal Act (PIDPTA), and the Artificial Intelligence and Data Act (AIDA).

Consumer Privacy and Protection Act (CPPA)

The legal framework of the CPPA is designed around the familiar concept of consent. As under PIPEDA, employers would be required to obtain consent for the collection, use, and disclosure of personal information except in limited circumstances. In terms of an employment relationship, the bill would only apply to employers in federal industries (examples of which include transportation, radio, and banks), and most obligations for employers would remain much the same as under PIPEDA.

The major change worth noting would be the ability for individuals, including employees of federal organizations, to request that their personal information be deleted, effectively withdrawing consent where the data is not strictly needed. The CPPA outlines the process of requesting deletion of information, and establishes timelines for response and processes for denials and appeals. The bill also specifies...

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