Government Submissions
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2024 Government Submissions
The Canadian Marketing Association (CMA) provided feedback to the Office of the Privacy Commissioner of Canada (OPC) on how it will advance the priorities identified in its Strategic Plan 2024-27.
Read our response.
The CPPA’s purpose statement reflects the need for Canada’s private sector privacy law to continue to achieve two essential priorities:
1. providing effective privacy protection for consumers; and,
2. enabling Canadians to benefit from the enormous social and economic benefits of data use.
These two priorities can and must be achieved in harmony.
The CPPA, as currently written, has a dual-purpose statement, which is to: “govern the protection of personal information of individuals while taking into account the need of organizations to collect, use or disclose personal information in the course of commercial activities.” This builds on the strengths of PIPEDA, whichhas been guided by the dual objective of protecting consumer privacy and enabling responsible data use and innovation since its enactment in 2001.
Our letter outlines needed amendments to ensure that the policy intent of the proposed CPPA is achieved without unintended consequences for consumers and organizations.
If you have questions or comments, contact us.
The responsible, secure use of biometric data provides many advantages for Canadian consumers and organizations, including enhanced security, accuracy, cost reduction, relevance, and convenience.
In the marketing sector, biometric data, used responsibly, can help marketers reach and serve consumers in the personalized and unique ways that they expect – including serving them with ads at ideal moments and in more meaningful ways.
Our submission recommends that the OPC adopt a more risk-based and contextualized approach to their biometrics guidance to reflect that different levels of risk require proportionate regulatory emphasis.
Read the CMA’s submission. If you have questions or comments, contact us.
2022 - 2023 Government Submissions
Canadians have never been more reliant on the digital economy. At home, it supports our daily lives and well-being. At work, it supports our ability to innovate, build businesses and remain competitive.
As technology continues to advance, so have people’s attitudes towards sharing their information. Canadian consumers increasingly understand that data exchange with business is essential to the running of modern society.
Our submission urges the Standing Committee on Industry and Technology to adopt the proposed Consumer Privacy Protection Act (CPPA) – with targeted amendments – in order to modernize consumer privacy protections and to ensure Canada maintains a competitive economic position in the global digital economy.
The CPPA would preserve Canada’s principles-based and technology-neutral approach to privacy, which would ensure that the law continues to apply to rapidly evolving technologies, business models and consumer expectations for decades to come.
The submission is available in English and French.
If you have questions or comments, contact Fiona Wilson, Director, Public Policy & Chief Privacy Officer.
The CMA is one of only 17 organizations – including only five business associations – that were invited by the Quebec privacy regulator to provide feedback on its draft consent guidelines under Quebec’s new privacy law.
Our submission urges the regulator to amend the guidelines in seven key areas, and to align them with other Canadian jurisdictions to support consumer understanding, ensure businesses can operate seamlessly across borders, and create a foundation for a wide availability of goods, services and investment in Quebec.
The submission is available in English and French.
If you have questions or comments, contact Fiona Wilson, Director, Public Policy & Chief Privacy Officer.
The CMA provided a response to the Alcohol and Gaming Commission of Ontario (AGCO) consultation on restricting athlete and celebrity participation in advertising for internet gaming..
iGaming has characteristics that underscore the importance of high standards and a compliance-first approach. Public confidence in the integrity of iGaming is critical to its long-term success.
Read the CMA's submission.
If you have questions or comments, contact Florentina Stancu-Soare, Director, Public Affairs and Regulatory Standards.
The CMA’s comments focused on the implications of new technology and business practices for the deceptive marketing provisions in the Competition Act, as presented in the consultation paper.
In its submission, the CMA addressed:
- Deceptive marketing practices and criteria for adopting new specific prohibitions;
- Remedies to address deceptive conduct; and
- Deceptive design patterns.
If you have questions or comments, contact Florentina Stancu-Soare, Director, Public Affairs and Regulatory Standards.
The CMA provided feedback to the Government of Ontario’s consultation paper on Modernizing the Consumer Protection Act (CPA).
Our specific comments focused on the government’s proposals in the areas of consolidating contract disclosure rules, unfair practices, consumer rights and prohibited contract terms, promotional gift cards, emerging issues and new challenges.
If you have questions or comments, contact Florentina Stancu-Soare, Director, Public Affairs and Regulatory Standards.
The CMA provided feedback the Government of Canada’s consultation: Taking Stock of Progress: Cannabis Legalization and Regulation in Canada.
The CMA supports the protection of young people and efforts to eliminate illegal market activities.
CMA members involved in the cannabis sector are committed to compliance to fulfill the purpose of the Act. They are also committed to helping consumers understand the safety considerations involved in purchasing cannabis and to helping them distinguish between legal and illegal products and brands so they can make informed decisions about which products meet their needs.
Our submission contains three recommendations to consider how regulators can increasingly support the provision of legal, safe products to adults, and diminish the illegal market.
If you have questions or comments, contact Florentina Stancu-Soare, Director, Public Affairs and Regulatory Standards.
The CMA provide a response to the Alcohol and Gaming Commission of Ontario (AGCO) on the potential regulatory risks associated with promotional partnerships related to internet gaming.
In its submission, the CMA supports amendments that reflect:
- A measured regulation of activities that are fair and consistent across the industry, as opposed to an outright ban; and
- A responsible gambling approach that presents iGaming for entertainment purposes to ensure that existing and potential new participants in the space make informed choices.
If you have questions or comments, contact Florentina Stancu-Soare, Director, Public Affairs and Regulatory Standards.
2020 - 2021 Government Submissions
The Canadian Marketing Association (CMA) appreciates the opportunity to provide feedback to the Ministry of Government and Consumer Service’s consultation on modernizing privacy in Ontario.
We strongly urge Ontario to continue to rely on federal privacy law for privacy protection. Federal privacy law reform is expected to be a continued priority in the new parliament, and any new provincial legislation should address only those sectors and activities that a reformed federal law will not cover.
Should the Government of Ontario move forward with private sector privacy legislation, the CMA has put forward recommendations in seven key areas to protect the personal information of individual Ontarians, while ensuring that any new privacy protections do not pose an unnecessary burden on businesses or inhibit the growth and prosperity of Ontario’s innovation ecosystem.
The CMA looks forward to continued discussions with the Government of Ontario in this area.
For questions or comments regarding this submission, please contact Fiona Wilson, Director of Government Relations.
The CMA has seven recommendations to update PIPA to better protect the privacy of individual British Columbians, while ensuring that any new requirements do not pose an unnecessary burden on businesses or inhibit the growth and prosperity of British Columbia’s innovation ecosystem.
We strongly urge British Columbia to proceed with amendments to PIPA only after the federal government proceeds with the next iteration of privacy law reform to ensure organizations and consumers have consistent regulation and protection.
The CMA looks forward to continued discussions with the Government of British Columbia in this area.
For questions or comments regarding this submission, please contact Fiona Wilson, Director of Government Relations.
The CMA provided feedback to the Government of Ontario’s Consumer Protection Act consultation paper. CMA also arranged for members to participate in a roundtable with Minister Thompson to discuss the Consumer Protection Act proposals.
The CMA looks forward to continued discussions with the Government of Ontario in this area.
For questions or comments regarding this submission, please contact Florentina Stancu-Soare,
Senior Manager, Regulatory and Consumer Affairs.
CMA-Submission-Ontario-Consumer-Protection-Act-Consultation
The Canadian Marketing Association (CMA) provided feedback to the Government of Ontario’s consultation on strengthening privacy protections in Ontario. The CMA is urging the Government of Ontario to continue to rely on the federal Personal
Information Protection and Electronic Documents Act (PIPEDA) for privacy protection, with new provincial legislation focusing on addressing sectors and activities that a reformed federal law will not cover. Against that backdrop, the CMA
provided detailed feedback in response to the Government of Ontario’s discussion paper on private sector privacy reform to ensure any new provincial legislation is proportionate and flexible enough to enable marketers to serve consumers
effectively while protecting their privacy interests.
The CMA looks forward to continued discussions with the Government of Ontario in this area.
For questions or comments regarding this submission, please contact
Fiona Wilson, Director of Government Relations.
CMA-Submission-to-Ontario-Privacy-Law-Consultation
The CMA provided feedback to the Quebec National Assembly’s Committee on Institutions as it reviews Bill 64’s proposed amendments to Quebec’s Act respecting the protection of personal information in the private sector.
The marketing community supports many improvements proposed in Bill 64. Other aspects of the Bill require adjustments to ensure Quebec’s privacy framework achieves its dual goal of protecting consumers while supporting responsible innovation and competitiveness.
The marketing community is particularly concerned about certain provisions in the Bill inspired by the EU’s stringent GDPR framework, including additional requirements for consent and transparency, cross-border data transfer requirements, and significant monetary penalties and enforcement measures.
The submission provides several recommendations to ensure Quebec’s privacy law remains a proportionate and flexible law that will enable marketers to serve consumers effectively. Alignment with other privacy reform initiatives underway across Canada, including at the federal level, will be critical to prevent significant negative impacts on businesses and consumers, and on trade and foreign investment in Quebec.
The CMA looks forward to continued discussions with the Government of Quebec in this area.
For questions or comments regarding this submission, please contact Fiona Wilson, Director of Government Relations.
CMA-Submission-on-Quebec-Bill-64-ENGLISH
L'ACM réagit aux modifications proposées par le projet de loi 64 à la loi québécoise sur la protection des renseignements personnels dans le secteur privé
L'ACM a fait part de ses commentaires à la Commission des institutions de l'Assemblée nationale du Québec dans le cadre de l'examen des modifications proposées par le projet de loi 64 à la Loi sur la protection des renseignements personnels dans le secteur privé du Québec.
La communauté du marketing soutient de nombreuses améliorations proposées dans le projet de loi 64. D'autres aspects du projet de loi nécessitent des ajustements pour que le cadre de protection de la vie privée du Québec atteigne son double objectif de protection des consommateurs tout en soutenant une innovation et une compétitivité responsables.
La communauté du marketing est particulièrement préoccupée par certaines dispositions du projet de loi inspirées par le cadre strict du GDPR de l'UE, notamment les exigences supplémentaires en matière de consentement et de transparence, les exigences relatives au transfert transfrontalier de données, ainsi que les importantes sanctions pécuniaires et mesures d'exécution.
Le mémoire présente plusieurs recommandations pour que la loi québécoise sur la protection des renseignements personnels demeure une loi proportionnée et souple qui permettra aux spécialistes du marketing de servir efficacement les consommateurs. L'harmonisation avec d'autres initiatives de réforme de la protection de la vie privée en cours au Canada, y compris au niveau fédéral, sera essentielle pour prévenir d'importantes répercussions négatives sur les entreprises et les consommateurs, ainsi que sur le commerce et les investissements étrangers au Québec.
L'ACM se réjouit de la poursuite des discussions avec le gouvernement du Québec dans ce domaine.
Pour toute question ou commentaire concernant cette soumission, veuillez contacter Fiona Wilson, Directrice des relations gouvernementales.
CMA-Submission-on-Quebec-Bill-64-FRENCH
Support post-pandemic upskilling and employability initiatives, particularly for youth
Encourage self-regulation to drive regulatory efficiencies and protect consumers
Ensure balanced regulation of digital and data transformation in Canada
Recognize marketing as a key driver of Canada’s economic recovery and growth
The attached letter elaborates on these proposals. The CMA looks forward to further discussions with the Government of Canada to ensure a strong Canadian economy in the years ahead.
For questions or comments regarding this letter, please contact Sara Clodman, Vice President, Public Affairs and Thought Leadership.
Speech-from-the-Throne
The submission provides several recommendations to ensure PIPA remains a proportionate, flexible and technologically neutral law that will enable marketers to serve consumers effectively while protecting their privacy interests.
The CMA looks forward to continued discussions with the Government of British Columbia in this area.
For questions or comments regarding this submission, please contact Fiona Wilson, Director of Government Relations.
CMA-Submission-to-Special-Comittee-on-BC-PIPA-Review_2020
It’s important to preserve PIPEDA’s strengths as principles-based and technology neutral. A policy framework that is overly prescriptive would impede important new technologies and services, and push AI activity to other jurisdictions. Bridging the gap between principles and practice should occur outside of the Act itself and in a staged approach, with significant input from those with direct knowledge of AI’s operational realities. Industry should be encouraged to develop standards and codes, with those approaches informing future AI-specific guidance and regulations.
The appropriate regulatory treatment of AI warrants further time and thought beyond this consultation period and privacy protection focus. While privacy protection is an important component of such an analysis, many other perspectives need to be taken into account, including issues relating to intellectual property law, competition law and policy, economic development initiatives, human rights and consumer protection laws, employment laws, and laws and policies respecting particular industry sectors that may make use of AI technologies.
The CMA looks forward to continued discussions with the Government of Canada in this area. For questions or comments regarding this submission, please contact Fiona Wilson, Director of Government Relations.
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2018 - 2019 Government Submissions
The CMA was pleased to respond to the federal government’s May 2019 Proposals to Modernize the Personal Information Protection and Electronic Documents Act (PIPEDA). The spirit of PIPEDA, since its inception and into the future, is based on a balance between embracing the enormous social and economic benefits of data use for Canadians while protecting their individual right to privacy. The CMA is providing recommendations in six key areas to preserve this important balance under a reformed law: PIPEDA’s general structure, consent and transparency, third-party processing, codes and certifications, enforcement and data mobility. In light of the challenges faced by international frameworks like the GDPR, the submission urges government to preserve the strengths of PIPEDA as principles-based, technology neutral and not overly prescriptive.
The CMA is involved in continued discussions with officials on PIPEDA reform. For questions or comments regarding this submission, please contact Fiona Wilson, Director of Government Relations.
CMA-PIPEDA-Submission-to-ISED
In its submission, the CMA urged the federal privacy commissioner to not change its interpretation of PIPEDA with regards to third-party data processing. The additional consent that would be required would not provide consumers with any meaningful improvement in privacy protection and would instead contribute to "consent fatigue". As the voice of the marketing profession in Canada, we are committed to helping Canadian marketers maintain high standards of professional conduct and transparency through our mandatory Canadian Marketing Code of Ethics & Standards and other resources, including the CMA Guide to Transparency for Consumers, which helps organizations provide clear, user-friendly information to consumers about how personal information is collected.
For questions or comments regarding this submission, please contact Fiona Wilson, Director of Government Relations.
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Quebec-Draft-Regulation-Loyalty-Program
PIPEDA-Review-2017
Submission_Prohibiting-F&B-Marketing-to-Children-Bill-S228
CMA-Response-to-Health-Canada-CBA-Marketing-to-Kids
CMA-Submission-Gift-Card-Rule-Amendments
CMA-response-to-OPC-Position-Paper-on-Online-Reputation
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Government Submission Archive
If you are interested in obtaining a copy of a submission made prior to 2017, please connect with us.
- CMA Responds to Government of Quebec's Consultation on Loyalty Program Bill
- CMA submission to OPC Consultation on Online Interest Based Advertising
- CMA Speaking notes to Industry Science and Technology Committee regarding the Electronic Commerce Protection Act (Bill C-27)CMA
- Speaking notes to Industry Science and Technology Committee regarding the Electronic Commerce Protection Act (Bill C-27)
- CMA Submission to Health Canada
- CMA responds to draft OPC guidance on online consent and no-go zones
- CMA makes written submission on CASL to parliamentary committee
- CMA responds to Competition Bureau’s Big Data whitepaper
- CMA calls for key improvements to CASL at parliamentary committee
- CMA participates in Data Breach Regulations consultation
- CMA sends letter to CRTC Chair on High Fees for NDCL
- CMA Appears Before ETHI Committee on PIPEDA Review
- CMA Submits Brief to Parliamentary Review of Canada Post
- CMA comments on review of Canada Post
- CMA Responds to OPC’s ‘Consent and Privacy’ Discussion Paper
- CMA responds to discussion paper on online reputation
- CMA responds to discussion document on data breach notification and reporting regulations
- CMA participates in review of Alberta’s privacy legislation
- CMA responds to draft identification and authentication guidelines
- CMA appears before House Committee on Bill S-4 (Digital Privacy Act)
- CMA signs onto coalition submission on amendments to Bill S-4 (Digital Privacy Act)
- CMA appears before Senate Committee on Bill S-4 (Digital Privacy Act)
- CMA submission to the CRTC on “Let’s Talk TV”
- CMA letter to Government re: CASL Private Right of Action
- CMA Submission to Standing Committee on Access to Information, Privacy and Ethics regarding statutory review
- CMA submission to Ontario Ministry of Health on plan to ban the marketing of junk food to children under 12
- CMA, on the recommendation of the Not-for-Profit Council, responds to the Canada Post Corporation’s proposed letter mail rate changes
- CMA provides preliminary feedback on proposed Administrative Monetary Penalties Framework for Ontario
- CMA Submission to the Office of the Privacy Commissioner of Canada (OPC) regarding OPC’s PIPEDA Review Discussion Document
- CMA submission to Industry Canada on Canada's Anti-Spam Law (CASL)
- CMA submission to the CRTC on Canada's Anti-Spam Law (CASL)
Coalition of Business and Technology Associations submission to Industry Canada on Canada’s Anti-Spam Law (CASL) - CMA submission to Industry Canada on Canada's Anti-Spam Law (CASL)
- CMA submission to the CRTC on changes to Automatic Dialing-Announcing Devices (ADADs) rules
- CMA submission to the CRTC on changes to the Unsolicited Telecommunications Rules
- CMA comments on Interventions submitted to the CRTC on changes to the Unsolicited Telecommunications Rules
- CMA submits final comments to the CRTC on changes to the Unsolicited Telecommunications Rules
- CMA submission to the Attorney General of Ontario on the proposed Unclaimed Property Act
- CMA submission to the CRTC on permanent National Do Not Call List registration
- CMA issues reply comments to the CRTC on permanent National Do Not Call List registration
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