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Message from the Privacy Commissioner of Canada

April 17, 2020

Privacy Act Bulletins are intended to offer lessons learned, best practices and other important privacy news, trends and information related to privacy protection in the federal public sector.

Dear colleagues,

I hope this message finds you, your teams and your families safe and healthy.

While everyone in society is currently facing unprecedented challenges, government institutions have a particularly difficult task as they endeavour to respond to the COVID-19 crisis. At the OPC, we thank you for your efforts and recognize that the current situation calls for a flexible and contextual application of privacy laws.

Consistent with this approach, we have prepared an assessment framework for privacy-impactful government initiatives that seek to alleviate the effects of the pandemic. This document has been made public on our website today.

The Framework, as a policy document, aims to offer the flexibility that is required in this context, while at the same time providing an important analytical tool that reflects well-established principles found in privacy law.

During a crisis, laws can be applied flexibly and contextually, but they must still apply. Because privacy is a fundamental human right, it is very important in our democratic country based on the rule of law that key privacy principles continue to operate, even if some of the more specific requirements are not applied as meticulously as they normally would be. The Framework is therefore a pared down yet more targeted version of our general expectations with regard to privacy impact assessments. In other words, it aims to focus on what we believe are the most relevant principles in context, without abandoning others.

With a view to achieving both greater flexibility and respect for privacy as a fundamental right, the Framework also suggests that while the current context makes certain data management practices reasonable that would otherwise not be, these exceptional measures should in some ways be subject to stricter limits (for instance as to purpose limitations and retention periods) than what would apply to normal processing in normal times.

We appreciate the support of the TBS in encouraging government institutions to consider the principles found in the Framework in their important work in responding to the crisis.

Our Office is of course available to answer any questions departments may have about applying the framework, particularly in the event that initiatives aimed at dealing with the public health crisis would come at an especially high risk for privacy. 

Please feel free to reach out to the OPC’s Government Advisory Directorate at


Daniel Therrien
Privacy Commissioner of Canada

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