This article discusses how current Canadian privacy law lacks a clear governance framework for the collection and use of some personal information.

Mobility data that is de-identified – stripped of markers revealing the identity of its source – and which does not contain the risk of re-identification is not considered personal information in Canadian privacy law, says Cutinha, a commercial litigator and associate at Miller Thomson in Toronto.

“There isn’t a governance framework right now for the protection of that data,” she says. “That data can be shared with the Government of Canada. It can be shared with whomever, without the knowledge and consent of individuals.”

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