In 2018, the Office of the Privacy Commissioner of Canada (OPC), following an organizational review, adopted a new structure to support the Privacy Commissioner’s vision to be more proactive, and to focus efforts where there can be an impact for the greatest number of Canadians.
The core responsibility of the OPC is the protection of privacy rights of Canadians. To do this, the OPC’s work will now fall into two program areas — Compliance and Promotion. Both areas are part of the OPC’s mandate and are important in protecting privacy.
The OPC’s organizational structure is now comprised of three sectors: the Compliance Sector, the Policy and Promotion Sector, and the Corporate Management Sector. The work of each sector is overseen by a Deputy Commissioner. The three Deputy Commissioners, as well as the Legal Services Directorate, report directly to the Privacy Commissioner. The Commissioner is also supported by the OPC’s Executive Secretariat.
The Compliance Program, headed by the Deputy Commissioner, Compliance (vacant — selection process underway), focuses on addressing existing privacy compliance problems through a variety of enforcement activities to ensure violations of the law are identified and that remedies are recommended. This includes investigations into complaints filed by Canadians, but also a shift towards more proactive enforcement, such as proactive, Commissioner-initiated investigations or, in certain cases, audits, to review issues that aren’t being addressed through the complaint system.
The Compliance Sector includes two directorates: the Privacy Act Compliance Directorate (public sector) and the Personal Information Protection and Electronic Documents Act (PIPEDA) Compliance Directorate (private sector).
Privacy Act Compliance Directorate
The Privacy Act Compliance Directorate investigates complaints under the Privacy Act from individuals who believe they have not been given access to their personal information held by government institutions, or feel that their information has been inappropriately, collected, used, disclosed or managed. The Directorate also investigates complaints and conducts audits that are initiated by the Commissioner, and receives notifications of breaches from federal government organizations. The Directorate is headed by Sue Lajoie, Executive Director.
PIPEDA Compliance Directorate
The PIPEDA Compliance Directorate investigates complaints under the PIPEDA from individuals about the collection, use and disclosure of their personal information in the course of commercial activities. The Directorate also investigates complaints and conducts audits that are initiated by the Commissioner, including sector-wide investigations, and receives notifications of breaches from private sector organizations. The Directorate is headed by Brent Homan, Executive Director.
Policy and Promotion Sector
The Promotion Program, headed by the Deputy Commissioner (vacant - selection process underway), Policy and Promotion, is future-looking and aims to inform Canadians of their rights and how to exercise them, and to bring organizations toward compliance with the law. This involves, for example, the development and promotion of general—yet practical—information and guidance, reviewing and commenting on Privacy Impact Assessments (PIAs), and offering industry advice on specific initiatives. The goal is to share information and advice with businesses and departments when they are designing their services so that Canadians may enjoy the benefits of innovation without undue risk to their privacy.
The Policy and Promotion Sector includes five directorates: the Government Advisory Directorate, the Business Advisory Directorate, the Policy, Research and Parliamentary Affairs Directorate, the Technology Analysis Directorate and the Communications Directorate.
Government Advisory Directorate
The Government Advisory Directorate provides advice and recommendations to federal public sector institutions in relation to specific programs and initiatives, as well as in the review of PIAs and information sharing agreements submitted by departments and agencies. This group also undertakes various outreach initiatives with the federal public sector in order to encourage compliance with the Privacy Act. The Directorate is headed by Lara Ives, A/Director.
Business Advisory Directorate
The Business Advisory Directorate provides advice to businesses subject to PIPEDA in the context of advisory services for new programs and initiatives, reviews for existing privacy practices and proactive engagements with the business community. This group also undertakes various outreach initiatives with the private sector in order to encourage compliance with PIPEDA. The Directorate is headed by Abubakar Khan, Director.
Policy, Research and Parliamentary Affairs Directorate
The Policy, Research and Parliamentary Affairs Directorate develops strategic policy positions on legislative bills, government policies and private sector initiatives; supports the Commissioner’s appearances before Parliament; develops guidance for public and private sector; and conducts applied research on emerging privacy issues in support of this work. This Directorate also manages the OPC Contributions Program which funds external researchers and non-profit organizations to advance and apply new knowledge about data protection in the private sector. The Directorate is headed by Barbara Bucknell, Director.
Technology Analysis Directorate
The Technology Analysis Directorate identifies and analyzes technological trends and developments in electronic platforms and digital media; conducts research to assess the impact of technology on the protection of personal information in the digital world and provides strategic analysis and guidance on complex, varied and sensitive technological issues involving government and commercial systems that store personal information. The Directorate is headed by Luk Arbuckle, Director.
The Communications Directorate focuses on providing strategic advice and support for the planning and execution of public education and communications activities. Activities relate to the production and dissemination of information for Canadians and organizations aimed at increasing awareness of privacy rights and obligations through, for example, media monitoring and analysis, public opinion polling, media relations, publications, special events, various outreach campaigns and the OPC web site. The Directorate is also responsible for responding to requests for information from the public and organizations regarding privacy rights and responsibilities through the OPC’s Information Centre. The Directorate is headed by Anne-Marie Hayden, Executive Director.
Corporate Management Sector
The Corporate Management Sector is led by the Deputy Commissioner, Corporate Management. The Corporate Management Sector includes four directorates: the Human Resources Directorate, the Finance and Administration Directorate, the Information Management/information Technology Directorate, and the Business Planning, Performance, Audit and Evaluation Directorate.
The Corporate Management Sector provides advice and integrated administrative services such as corporate planning, resource management, financial management, information management/technology, human resources and people management and general administration to managers and staff. The Sector is headed by Daniel Nadeau, Deputy Commissioner, Corporate Management. It is also supported by four Directors: Bruno Prévost (Human Resources Directorate), Sophie Perreault (Finance and administration Directorate), Paul Beauchamp (IM/IT Directorate) and Chantale Roussel (Business Planning, Performance, Audit and Evaluation Directorate).
Legal Services Directorate
The Legal Services Directorate reports directly to the Privacy Commissioner. The Directorate provides legal advice in relation to PIPEDA and Privacy Act investigations and audits, and in support of other operational activities across the OPC. It represents the OPC in litigation matters before the courts and in negotiations with other parties. The Directorate also includes OPC’s Access to Information Program. The Directorate is headed by Julia Barss, General Counsel.
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