Statement by the Privacy Commissioner of Canada to the Standing Committee on Public Safety and National Security (SECU) on Bill C-12

November 20, 2025
Ottawa, ON

Opening statement by Philippe Dufresne
Privacy Commissioner of Canada

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Thank you for the invitation to appear before you today to assist in your study of Bill C-12, the Strengthening Canada’s Immigration System and Borders Act.

Bill C-12 would amend a number of laws and regulations with a view to strengthening immigration and border security and combatting transnational organized crime and the flow of illicit narcotics and financing. These are important public interest objectives.

These provisions were initially included as part of Bill C-2, but Bill C-12 omits the elements of Bill C-2, including the lawful-access provisions, that raise the most significant privacy implications and on which I will have more to say when Bill C-2 is reviewed by this Committee.

Last month, when I appeared before you on Bill C-8, I made reference to Bill C-12, and noted that it contains important positive safeguards with respect to information-sharing agreements for disclosures outside Immigration, Refugees and Citizenship Canada.

Specifically, Bill C-12 requires written information-sharing agreements for when the Minister of Immigration discloses specified immigration-related personal information outside the Department.

The Bill indicates that such agreements must include the elements of personal information that may be disclosed, the purpose of the disclosure, any limits on secondary use and subsequent transfer of information and any other relevant details.

The Bill further provides for the issuance of regulations by the government with respect to the disclosure of information, and I would expect that my Office be consulted in the drafting of these regulations.

These are important requirements that I support, and I would recommend that they be included in Bill C-8 as well.

The Bill also includes a provision that would grant customs officers free access to premises or places where goods destined for export are stored. To harmonize this with the existing provisions of the Customs Act, in particular section 42(3), I would recommend that the Bill clarify that an officer may not enter a dwelling-house without the consent of the occupant except under the authority of a warrant.

Thank you again for the invitation to appear.

I look forward to answering any questions that you may have.