Molly Reynolds Contributes to Report Recommending Amendments to PIPEDA

March 13, 2018

Counsel Molly Reynolds has contributed to a House of Commons Standing Committee Access to Information, Privacy and Ethics report of its recommendations to the government on revising the Personal Information Protection and Electronic Documents Act (PIPEDA).

The 108-page report cites a number of Molly’s recommendations. The first is on page 60 of the report in “Part 4: Enforcement Powers of the Privacy Commissioner.” Her inclusions are below:

Similarly, Molly Reynolds, Senior Associate with Torys LLP, recommended amending PIPEDA to allow the OPC to issue advance compliance rulings.253 As she explained, advance rulings would lead to four main outcomes:

  • Canadians would be better protected;
  • the OPC would gain better insight into new technologies;
  • there would be greater certainty for all parties involved; and
  • private-sector risk assessment would improve.254

Ms. Reynolds specified that advance compliance rulings should not be binding.

Molly’s second contribution was cited in “Part 5: Adequacy of the Personal Information Protection and Electronic Documents Act Under the European Union General Data Protection Regulation.” Her comments below can be found on page 66 of the report.

Similarly, Ms. Reynolds of Torys LLP suggested that the Committee not focus on

reforms that would merely encourage an adequacy ruling from the EU, but rather areas in which harmonization of international standards with Canadian privacy law would truly help consumers and businesses protect information more consistently and with more certainty across jurisdictions

Molly contributed to the report while she was still in a senior associate role at Torys, prior to her commencement as counsel.

Torys has previously released an analysis of the report

You can learn more about Torys Privacy work by heading to its practice page.


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