The Office of the Privacy Commissioner of Canada (OPC)’s report, Personal Information Protection and Electronic Documents Act (PIPEDA) Report of Findings #2019-001, issued April 9, 2019, into the Equifax hack, created controversy as the report suggested that the existing law on the level of consent necessary for Canadian organizations to engage in transborder processing of personal data had changed and that the OPC was now asserting that a new standard of express consent was required.
In para. 111 of the report, the OPC stated “we acknowledge that in previous guidance our Office has characterized transfers for processing as a ‘use’ . . . [more]