Cybersecurity Policy Report, Privacy Risk Mitigation Guidance Offered in Canada, (Oct 29, 2025)
By Tony Foley
The Canadian Office of the Privacy Commissioner (OPC) has issued a Privacy Bulletin outlining steps that businesses should take in building privacy considerations into the life cycle of a technology, program, or service.
The bulletin emphasizes that considering these issues from the moment that personal information is collected, through its use, storage, and eventual disposal, can support and enable responsible innovation, increase confidence in the program or service, and ensure compliance with the Canadian Privacy Act. OPC said it gave a presentation earlier this year, together with the Treasury Board Secretariat (TBS), to more than 1,000 government participants about protecting personal information within the life cycle of a program or activity.
Key takeaways are presented in the bulletin suggesting issues that should be top of mind in the context of the development life cycle, including the following:
Before collecting personal information, determining the legal authority for collection, considering conducting tests of necessity and proportionality for complicated initiatives, and conducting privacy impact assessments as necessary, among other considerations;
While collecting personal information, ensure transparency as required under the Privacy Act, be clear about what personal information is being collected and why it is necessary, and provide clear privacy notices; and
After collecting personal information, fulfill legal obligations related to safeguarding personal information and reducing the risk of data breaches, and when a breach occurs, ascertain the risk of significant harm to determine the appropriate response, using tools like the OPC’s online privacy risk assessment and the TBS privacy breach management toolkits, links to which are provided in the bulletin.
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