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Notice of Consultation and Call for Comments on Draft Online Reputation Position Paper


Please send your feedback in accordance with our procedures and criteria by April 27, 2018.

In May 2015, the Office of the Privacy Commissioner of Canada (OPC) released its strategic privacy priorities to guide its proactive work for the next five years. Reputation and Privacy was identified as a strategic priority, where we said that we will “seek to create an environment where individuals may use the Internet to explore their interests and develop as persons without fear that their digital trace will lead to unfair treatment.”

We initiated a dialogue on online reputation with a discussion paper, and received a total of 28 submissions from industry, academics, civil society, lawyers and the general public. The submissions presented a broad range of proposals for protecting reputational privacy from de-indexing, to standardized takedown request forms and procedures, to enhanced powers for the OPC. The OPC has also put together an overview of all the submissions, which highlights the key themes, recommendations and issues identified.

On January 26, 2018, my Office released its draft Position Paper on Online Reputation. We have had discussions with our provincial colleagues and will continue to work with them. In the meantime, we are inviting feedback on this draft position paper before finalizing it.

Participating in the consultation: Criteria and Deadline

We are calling on individuals, organizations, other privacy enforcement authorities, academics, advocacy groups, information technologists, educators, students and other interested parties to join in this discussion by contributing their views on this draft position paper.

Please send your feedback in accordance with our procedures and criteria by April 27, 2018.

We are particularly interested in answers to the following questions:

  1. Is the position clear?
  2. Of the positions taken in this paper, have we struck an appropriate balance between individuals’ right to privacy and the right to free expression? Why or why not?
  3. Are there gaps that have not been identified in the position that require further direction from the OPC? 

Additional questions for organizations:

  1. Is the position useful to your organization in terms of guiding behaviour? What additional guidance might be required to provide additional clarity?
  2. Are there areas of the proposed position that would pose challenges and how would you minimize them?
  3. How long will it take for your organization to implement the guidance recommendations into your policies and practices?

Feedback Criteria and Procedures:

  1. Please send your response to by April 27, 2018.
  2. Your feedback may be sent in the form of an email, Word or pdf document.
  3. Please indicate your name, contact information and category which best represents your perspective (e.g. individual, organization, academic, advocacy group, information technologist, educator, etc.)
  4. Any comments that violate Canadian law or violate our comment policy will not be considered within scope of this call for feedback and will either be deleted or dealt with in accordance with our legal authorities under the Privacy Act.

A confirmation email will be sent if your email address has been provided in accordance with the terms above.

Please note that the OPC is not providing funding for any feedback related to this call for comment.

Your feedback will not be posted on the OPC website; however an overall summary of comments may be posted on the OPC’s website. If you post your feedback online, please advise us and provide us with a link. If you are submitting previously published works as part of your feedback, please include appropriate references and links.

The Office of the Privacy Commissioner of Canada is subject to the Access to Information Act and the Privacy Act. The Access to Information Act provides a public right of access to government records. The Privacy Act provides individuals with a right of access to their own personal information and protects that information from unauthorized disclosure. Some of the information you provide to us in this process may be accessible under the Access to Information Act; this does not include personal information as defined in the Privacy Act.

If you choose to participate in this consultation, the personal information that you provide directly to the OPC is included in Personal Information Bank PSU 938 Outreach Activities. Please also see the OPC’s Privacy Policy, Terms and Conditions, and comment policy for how we handle your information. The personal information you provide will be used and may be disclosed for the purpose for which the information was obtained or compiled by the OPC, or for a use consistent with that purpose.

If you have a question unrelated to this call for feedback, please use our Online Information Request form or contact our Information Centre. Feedback will not be treated as a privacy complaint under the Privacy Act or the Personal Information Protection and Electronic Documents Act. For further information on filing complaints under either Act, please see File a formal privacy complaint.

If you have any questions, please feel free to contact Melanie Millar-Chapman, who can be reached directly at, by telephone at 819-994-6008, or toll free at 1-800-282-1376.

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