Letter to the Standing Committee on Procedure and House Affairs on the privacy implications of Bill C-25

Chris Bittle, M.P.
Chair, Standing Committee on Procedure and House Affairs
Sixth Floor, 131 Queen Street
House of Commons
Ottawa ON  K1A 0A6

I am writing to present my views on the privacy implications of Bill C-25, tabled on March 26, 2026. While Bill C-25 would make several amendments to the Canada Elections Act and enact the new An Act to change the name of certain electoral districts, 2026, the focus of my comments will be on provisions pertaining to requirements for political party’s policies for the protection of personal information (privacy policies).

Role of the Office of the Privacy Commissioner of Canada

As Privacy Commissioner of Canada, my mandate is to oversee compliance with both the Privacy Act and the Personal Information Protection and Electronic Documents Act (PIPEDA). The Privacy Act governs how federal government institutions handle personal information and PIPEDA governs how personal information is handled by private sector organizations in the course of their commercial activities. My mission is to protect and promote the privacy rights of Canadians.

Political Parties and Privacy Requirements

Political parties are not currently covered under either the Privacy Act or PIPEDA. In 2018, Parliament enacted Bill C-76, the Elections Modernization Act. Bill C-76 amended the Canada Elections Act to require political parties to develop specific privacy policies to protect personal information, to submit those policies to Elections Canada and to publish them online. Although there have been changes made to these requirements since 2018, it remains that the prescribed content of these policies falls short of privacy related requirements in either the Privacy Act or PIPEDA.

Bill C-25 would bring improvements to the current privacy policy requirements under the Canada Elections Act. These include: