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Retail Council of Canada's Comments on the Federal Government's Response to the Fourth Report of the Standing Committee on Access to Information, Privacy and Ethics
Statutory Review of the Personal Information Protection and Electronic Documents Act (PIPEDA)
January 15, 2008

Introduction

Retail Council of Canada (RCC) is pleased to have the opportunity to submit its comments to the House of Commons Standing Committee on Access to Information, Privacy and Ethics upon the release of its Fourth Report.

Since the inception of Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), RCC has been actively working with its members — small, mid and large — across the country through its member-driven Privacy Committee to ensure that retail businesses are aware of and complying with the law. Similar efforts have been undertaken where provincial privacy law rules the day in British Columbia, Alberta and Quebec.

Over the past year, RCC has embarked on proactive working arrangements with the Federal Privacy Commissioner's Office, including:

  • Providing input and retailer feedback to the recently launched on-line privacy best practices tool targeted for small and medium-sized Canadian businesses.

  • Partnering with the Federal Privacy Commissioner's office in doing a joint mailing of Your Privacy Responsibilities: A Guide for Canadian Businesses and Organizations to over 3,000 members operating outside of British Columbia, Alberta and Quebec. RCC was extremely pleased with the response to the mailing as we received subsequent requests from retailers for over 60 additional guides, which were mailed from our Toronto office.

  • Actively participating in an exercise to develop guidelines for businesses in Canada to follow for breach notification.

RCC is appreciative of this opportunity to share its members' perspectives on breach notification, business contact information, work product information, investigative bodies and the authority of the Federal Privacy Commissioner to dismiss frivolous or vexatious claims.