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Appearance before the Standing Committee on Human Resources, Skills and Social Development and the Status of Persons with Disabilities on the Study of Bill C-4, An Act to Amend the Canada Labour Code, the Parliamentary Employment and Staff Relations Act, the Public Service Labour Relations Act and the Income Tax Act

May 2, 2016
Ottawa, Ontario

Opening Statement by Daniel Therrien
Privacy Commissioner of Canada

(Check against delivery)


Chair and Committee members, thank you for inviting me to speak with you regarding Bill C-4.

In May of 2015, I appeared before the Senate Legal and Constitutional Affairs Committee to comment on one of the legislative enactments of Bill C-377 — which the bill before you now proposes to repeal. 

Namely, those provisions imposed certain public disclosure requirements upon unions under the Income Tax Act.

Before that, my predecessor appeared in the House in 2012 and the Senate in 2013 on the same issue.

As during my last appearance, I will keep my remarks at a fairly high level.   

Firstly, as a matter of general government policy, I fully support efforts to encourage transparency and accountability, including for unions.

These are fundamental organizational principles for good governance — and they underpin effective, robust democratic institutions.

But transparency is not an end unto itself; it cannot be an absolute objective to the exclusion of other considerations. 

Given my role and mandate, I count privacy as one such competing good.  

Transparency efforts must be carefully balanced with the need to protect the personal information of individuals.

Bill C-377

It was the aim of Bill C-377 to render operations of union organizations transparent and therefore more accountable.  This was to be achieved by requiring publication of:

  • Individual employee compensation over $100,000;
  • Details of all transactions and disbursements for which the cumulative value in respect of a particular payer or payee is greater than $5,000, and;
  • Percentage of time spent by certain individuals on political, lobbying and non-union activities.


In my remarks before the Senate on the proposal, I expressed doubt that true accountability for union members required publication of such extensive personal information to the general public through the website of the Canada Revenue Agency.

The vast majority of unions already have financial statements that are internally available to their members and, in many cases, publicly posted on their websites.

These statements containing financial information are usually in aggregate form and seem to achieve their intended purpose without having to name specific individuals.


As I have emphasized in other venues, most recently before the House ETHI Committee, political activity can for some individuals be a very sensitive and personal matter.  

Publicly listing specific individuals along with their political and lobbying activities as well as education, training and conference activities was, in my view, overreaching.

Likewise, publicly naming individual payers and payees (often third parties) associated with transactions involving cumulative value over $5000 seemed disproportionately intrusive from a privacy perspective.

Finally, as for shining light on the compensation levels of a union’s highest paid officers, there are several ways this can be achieved in practice without having to legislatively require disclosure of specific salaries of named individuals.

While several provinces require that detailed reports of a union’s spending be made available upon request — these measures have stopped well short of publishing the names and earnings of individuals.  

Similarly, in France, unions publish annual financial statements (assets, liabilities, loans, etc.) but they contain no personal information.  


In short, I am supportive of the legislation before you that will revoke these more problematic aspects.

I would be pleased to answer any questions.

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