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A Pan-Canadian Descriptive Study of Privacy Risks from Synthetic Data-Generation Practices within the Evolving Canadian Legislative Landscape


Children’s Hospital of Eastern Ontario (CHEO) Research Institute



Project leader(s)

Khaled El Emam


Interest in synthetic data generation has been growing quite rapidly over the last few years. This has been driven by three simultaneous trends: 1) the demand for large amounts of data to train and build artificial intelligence and machine-learning (AIML) models, 2) technical advances allowing for the generation of high-quality synthetic data, and 3) the erosion of public and regulators’ trust in contemporary de-identification methods by repeated claims of successful re-identification attacks on anonymized data.

These trends have resulted in the growing recognition that synthetic data can solve some difficult problems quite effectively, especially within the AIML community. However, a more precise definition of the privacy risks of this emerging—and increasingly adopted—technology is necessary.

This report aims to provide a detailed analysis of data synthesis in a Canadian context and has three main sections. The first presents a unified privacy model for evaluating the different disclosure risks in synthetic data. The second is a legal analysis of how synthetic data is regulated under the Personal Information Protection and Electronic Documents Act and Bill C-11, the Digital Charter Implementation Act. The final section presents the results of interviews with Canadian privacy regulators to understand their perspectives on how synthetic data—and non-identifiable data in general—is and should be regulated. The overall findings can inform frameworks and mechanisms for managing and regulating the privacy risks of synthetic data.

Project deliverables are available in the following language(s)


OPC-funded project

This project received funding support through the Office of the Privacy Commissioner of Canada’s Contributions Program. The opinions expressed in the summary and report(s) are those of the authors only and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada. Summaries have been provided by the project authors. Please note that the projects appear in their language of origin.

Contact information

Khaled El Emam
Senior Scientist, CHEO Research Institute and Professor, Faculty of Medicine, University of Ottawa
CHEO Research Institute
401 Smyth Rd
Ottawa, Ontario K1H 8L1
Email: Khaled El Emam
Phone: 613-737-7600, ext. 6771

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