Statement by Deputy Commissioner Marc Chénier to the Senate Standing Committee on Social Affairs, Science and Technology on Bill S-5

April 22, 2026
Ottawa, ON

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Madam Chair, members of the Committee.

Thank you for the invitation to speak on the subject of Bill S-5, the Connected Care for Canadians Act.

Commissioner Dufresne sends his regrets for not being able to be here himself. I am pleased to represent him and discuss the privacy implications of the Bill with you today.

The mission of the Office of the Privacy Commissioner of Canada is to protect and promote Canadians’ fundamental right to privacy. Its mandate is to oversee compliance with Canada’s federal public and private-sector privacy laws, which set the ground rules for how federal government institutions and businesses handle personal information.

Data access and mobility are persistent challenges in the health sector due to technical incompatibilities between systems, which can result in incomplete records, duplication of medical histories and tests, and delays in care.

Bill S-5 aims to address these issues and to support responsible innovation by accelerating the adoption of common standards to enable secure information sharing across health platforms and improve interoperability.

A system that is connected, secure, and that allows health information to be used efficiently will help governments, health care administrators, and researchers make evidence-based decisions that will improve health care delivery.

This Bill would help to operationalize a modern, secure, and interoperable digital health communication infrastructure.

This objective was one that was endorsed by the OPC and its provincial and territorial counterparts in a 2022 resolution on securing public trust in digital health care.

Health information is one of the most sensitive types of personal information. Harms resulting from data breaches in the health sector can include potential discrimination and stigmatization, as well as financial and psychological distress.

Reasonable safeguards around digital health care can support Canadians’ trust in the health system and also mitigate financial and reputational costs that accompany data breaches.

By promoting interoperability between health information systems, Bill S-5 would help to ensure that personal health data can flow more easily across systems, giving patients greater access to their health records and more control over their information.

The OPC supports a more interoperable digital health system that includes measures to ensure that privacy is properly protected.

To that end, the OPC is pleased that the Bill’s interoperability provisions specify that the access, use, and exchange of personal health information are not required where it would be prohibited by privacy laws. We recommend that the proposed data-blocking prohibition also be subject to a similar exception.

Under S-5, many requirements and standards, including any privacy and security requirements, are left to regulations. It will be important for the OPC to be consulted on the development of any regulations that pertain to privacy and security.

It will also be important for the OPC to continue to collaborate with provincial and territorial counterparts to facilitate regulatory alignment in an increasingly interconnected and digitized health sector.

Moreover, health information technology vendors will already be subject to applicable private- and public-sector privacy laws across the country, such as the Personal Information Protection and Electronic Documents Act, or PIPEDA. This highlights the importance of modernizing PIPEDA to ensure that Canadians are protected in all sectors, including health.

Thank you. I would now be pleased to take your questions.