There is no disagreement, whether in Europe, the Americas or Asia, that a fully connected world requires those that think and act with data to demonstrate that their processing of data is legal, fair and just. Demonstration requires comprehensive data impact assessments that help organizations discover the issues for all stakeholders. Discovery of issues helps determine that data is processed appropriately, particularly when uses go beyond the common understanding of the individuals to whom the data pertains.
Over the past year, the Information Accountability Foundation (“IAF”) has had the pleasure of working with many Canadians in developing an assessment framework for Canadian organizations thinking and acting with data. The IAF received a grant from the Office of the Privacy Commissioner of Canada to develop and evaluate an assessment process for thinking and acting with data in Canada. The IAF further received support and participation from twenty companies in actually developing an assessment framework that would be an extension of Canadian privacy impact assessments. The product of that work was evaluated with other stakeholders last December. The project would not have been possible without the wise assistance the IAF received from Adam Kardash of Osler, Hoskin & Harcourt LLP.
On February 28, 2017, the IAF submitted the assessment framework and its report to the OPC. Both are proudly posted on the IAF website. The IAF believes the report and assessment framework demonstrate that similar frameworks, that both link with local law and global trends, are doable. The IAF looks forward to doing further work in Canada on scalable oversight of assessments and in other locations on developing a growing tool chest of comprehensive assessments.