Authored by: Kirsten Thompson, Danielle Dudelzak and Jen Rees-Jones

Bill C-27’s proposed Consumer Privacy Protection Act (CPPA) includes new protections for minors by requiring a higher standard of diligence and protection in respect to the collection and processing of their personal information. Legislators in Canada are clearly following international trends with respect to the protection of children’s personal information, and organizations that operate in sectors interacting with children’s personal information on any level will need to pay close attention. Increasing regulatory scrutiny of the handling of children’s personal information, and an upswing in class actions related to the same issue, have created a material change in the risk environment for these businesses.

Bill C-27, currently in second reading, proposes to overhaul Canada’s current federal private-sector privacy law (a summary of Bill C-27 can be found here). Part 1 of the new Bill would enact the CPPA as an updated framework to govern the protection of personal information while taking into account businesses’ need to collect, use or disclose personal information. While much of Bill C-27 refines or builds out existing privacy protections found in PIPEDA, it also contains some wholly new provisions. Among these new provisions are new privacy requirements in respect of children’s personal information (cPI).

This insight examines:

1. The amendments proposed in the CPPA as they relate specifically to the protection of cPI;
2. How the proposed protections compare to other child protection frameworks; and
3. Potential impact on businesses and the practical steps that organizations can take to ready themselves.

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