Compliance Briefing — April 24, 2024
Canada’s House of Commons passed Bill C-27, advancing the Consumer Privacy Protection Act to the Senate and signalling organizations to ready GDPR-level consent, automated decision notices, and tribunal appeal processes ahead of enactment.
Executive briefing: On April 24, 2024 Canada’s House of Commons approved Bill C-27 (Digital Charter Implementation Act, 2022), moving the Consumer Privacy Protection Act (CPPA) and Artificial Intelligence and Data Act (AIDA) to the Senate. Once enacted, the CPPA will replace PIPEDA with higher penalties, mandatory privacy management programmes, algorithmic transparency obligations, and expanded appeal rights before the proposed Personal Information and Data Protection Tribunal.
Key compliance checkpoints
- Privacy management programme. Section 9 of the CPPA codifies governance requirements: documented policies, risk assessments, and training covering collection, use, disclosure, retention, and disposal.
- Automated decision notices. Sections 63–64 obligate organisations to explain automated decision systems, provide meaningful information about factors, and offer human review.
- Penalty exposure. Administrative monetary penalties up to the greater of CAD $10 million or 3% of global revenue, plus fines up to 5% of global revenue, demand executive attention.
Control alignment
- Map GDPR/CPRA controls. Leverage existing GDPR, Quebec Law 25, and California CPRA programmes to accelerate CPPA readiness while filling Canadian-specific gaps (tribunal processes, service provider contracts).
- Data inventory extensions. Update processing registers with lawful basis tags, retention triggers, and cross-border transfer safeguards referencing CPPA schedule requirements.
- Incident response. Align breach notification thresholds and documentation with CPPA Section 58 and Office of the Privacy Commissioner of Canada (OPC) expectations.
Enablement moves
- Launch cross-functional CPPA steering committees linking privacy, legal, security, AI ethics, and product teams.
- Prototype tribunal appeal workflows so denied data subject requests and penalty notices trigger escalation, response templates, and evidence packs.
- Conduct algorithmic impact assessments for AI-driven features targeting Canadian residents, aligning with the forthcoming AIDA risk management requirements.
Sources
- Parliament of Canada: Bill C-27 status
- Office of the Privacy Commissioner statement on Bill C-27 third reading
Zeph Tech unifies CPPA playbooks across privacy governance, AI accountability, and tribunal response so Canadian compliance enhances customer trust.