Call for Comments – Consultation on OPC Guidance Processes

Press Release

December 04, 2025

The OPC issues regulatory guidance to help businesses and other organizations understand and comply with their privacy obligations under the Personal Information Protection and Electronic Documents Act (PIPEDA). Guidance documents clarify how and when privacy laws apply, identify best practices for protecting privacy, highlight key risks, and clarify regulatory expectations.

To help maximize the impact and utility of the OPC’s PIPEDA guidance, we are seeking input on our guidance processes, including the format, presentation, and contents of our guidance, and how we carry out guidance consultations.

We are hoping to hear from a variety of stakeholders about their views on the accessibility and utility of our guidance, and about how we consult with stakeholders and the public before issuing guidance documents.

Why are we opening this consultation?

In our 2024-2027 Strategic Plan, the OPC identified “Protecting and promoting privacy with maximum impact” as a key strategic priority for our office. Our work under this priority involves engaging with stakeholders to better understand their perspectives, and providing focused guidance based on data and stakeholder input.

As part of this effort, the OPC is assessing the processes we use to develop PIPEDA guidance, including the ways we engage with stakeholders. Our aim is to ensure that our processes are fair, effective, and responsive to diverse stakeholder perspectives. The input we receive during the consultation will inform decisions we make about how to adjust our guidance processes going forward.

Who do we want to hear from?

While the main goal of PIPEDA guidance is to assist businesses in complying with their privacy obligations, the privacy issues involved can have significant impacts on many different groups, individuals, and organizations. We are therefore interested in gathering a diverse range of perspectives, including those from:

• Businesses, industry representatives, and trade associations
• Civil society and not-for-profit organizations
• Representatives of Indigenous communities
• Legal and academic professionals
• Any other individual, group, association, professional, or organization with relevant experience or expertise

How to participate

We invite interested individuals and organizations to provide feedback by email to cpvp-opcconsultation1@priv.gc.ca. Feedback can be submitted as text, or in a Word or PDF attachment. Areas of particular interest to the OPC are set out in the consultation questions below.

The consultation period is open from December 2, 2025 to March 13, 2026. Be sure to submit your feedback no later than 11:59 PST on March 13.

Any comments that violate Canadian law or violate our Comment Policy will not be considered within scope of this call for feedback and will either be deleted or dealt with in accordance with our legal authorities under the Privacy Act. Please note that the OPC is not providing funding for any feedback related to this call for comments.

For any questions relating to this consultation, including any requests for accommodation regarding submission procedures, please contact us at cpvp-opcconsultation1@priv.gc.ca.

Important information about your submission

The OPC is subject to the Access to Information Act and the Privacy Act. The Access to Information Act provides a public right of access to government records. The Privacy Act provides individuals with a right of access to their own personal information and protects that information from unauthorized disclosure.

Feedback that you provide to us in this consultation process may be accessible to third parties outside of the OPC under the Access to Information Act. However, this does not apply to any personal information (as defined in the Privacy Act) that may be associated with your submission.

Your feedback will not be posted on the OPC website but we may post summaries of feedback that we receive, and we may share summaries of feedback with external organizations. The summaries will not attribute views or feedback we received to any specific individual or organization.

Please see the OPC’s Privacy Policy, Terms and Conditions, and Comment Policy for how we handle your information. The personal information you provide will be used and may be disclosed for the purpose for which the information was obtained or compiled by the OPC, or for a use consistent with that purpose.

If you have a question unrelated to this call for feedback, please use our Online information request form or contact our Information Centre. Feedback will not be treated as a privacy complaint under the Privacy Act or PIPEDA. For further information on filing complaints under either Act, please see File a formal privacy complaint.

Consultation questions

The consultation questions below set out areas where we are especially interested in learning about stakeholders’ views.

We welcome feedback on any or all of these questions. Submissions do not need to address each question in order to be included in our analysis of feedback.

1. OPC engagement with businesses, groups, and individuals

OPC engages with stakeholders and the public when developing PIPEDA guidance to help deepen our understanding of various perspectives and the potential impacts of our advice. Doing so helps us to ensure that our guidance is clear, informative, impactful, and mindful of diverse experiences and viewpoints.

We are therefore interested in learning about how groups, individuals, and organizations would like to be consulted on future PIPEDA guidance projects. This includes:

1.1 Forms of consultation

Typically, OPC issues an open Call for Comments when consulting on PIPEDA guidance. This involves publishing a request for feedback that is open to everyone, with feedback submitted in writing. OPC also sometimes organizes roundtable meetings, where multiple stakeholder representatives are invited to discuss ongoing or proposed guidance work.

• Do these forms of consultation raise challenges for organizations that the OPC should be aware of?
• Are there other ways to consult that could provide greater impact, improve accessibility, or increase efficiency of the process?
• Do stakeholders prefer to participate in roundtable meetings where other participants represent similar groups and organizations, or do they prefer mixed-attendance meetings (with stakeholders across varied groups and interests)?

1.2 Consultation timing

Consulting at different stages of a guidance project can present different opportunities for input. For example, consulting at an early stage allows the OPC to gather perspectives before major drafting decisions have been made, while consulting after a draft has been published provides an opportunity to understand the potential impacts of specific advice.

Given that consultations can involve substantial commitments of time and resources both for participants and for the OPC, it is not always possible to consult multiple times on the same guidance project. We are therefore interested in understanding stakeholder perspectives regarding the timing of guidance consultations.

• What considerations should we be aware of with respect to the timing of guidance consultations?

1.3 Draft OPC consultation policy

The OPC has developed a draft Guidance Consultation Policy that sets out our proposed approach to consulting on PIPEDA guidance. The policy aims to establish clear and consistent expectations around the procedures we use when engaging with stakeholders about our guidance.

• We welcome any feedback on the proposed procedures outlined in the draft Guidance Consultation Policy.

1.4 Awareness of OPC consultations

When opening a public consultation, OPC typically announces the consultation on our website and social media channels. Our aim is to ensure that the process for participating is fair, open, and transparent.

• Are there other ways of spreading awareness that we should consider?
• How can OPC ensure that consultation Calls for Comment reach a broad and diverse range of stakeholders?
• Following a consultation, is it helpful for OPC to publish a separate report on the feedback we received? Or should resources be focused on revising and finalizing guidance documents along with a summary of the consultation?

2. Presentation, contents, and utility of PIPEDA guidance

The OPC is committed to developing guidance that is accessible, informative, and practical. To help us meet this goal, we are interested in feedback on the ways we format and present PIPEDA guidance, and on the areas of guidance we focus on. This includes:

2.1 Format and organization

Guidance can be organized and presented in different ways. For example, guidance on a given topic can be presented in a question-and-answer format, as a set of key principles and their application, as a checklist of privacy practices or requirements, or as explanations organized thematically around key issues. Guidance documents can involve in-depth examination of a topic or a more cursory overview of the most pressing issues and can vary in length and level of detail.

We are interested in understanding views on what formats stakeholders find most effective and accessible. References to examples of published guidance, whether from OPC or another regulatory authority, are helpful.

• What preferences do stakeholders have for how guidance is organised and presented?
• Is it helpful for OPC to separate legal requirements (what organizations must do under the law) into separate sections from best practices (what organizations should do to meet legal requirements)?

2.2 Guidance topics

The OPC aims to produce guidance on topics and issues where there is a need among organizations for clarity and advice on how PIPEDA applies. To help identify relevant areas of focus for our guidance, we systematically review multiple inputs and indicators, including jurisdictional and media scans, insights from OPC engagements, internal business intelligence from across OPC directorates, and internal and external research.

• In your experience, does OPC PIPEDA guidance generally focus on the most relevant and important privacy topics and issues for businesses?
• Are there additional steps or sources of information we could use to help identify areas where there is a strong interest in guidance and advice?

2.3 Clarity and utility

We are interested in views on how else we can ensure that our guidance is clear, accessible, and useful.

• Are there specific changes OPC should consider making to our guidance and associated processes?
• Is it helpful to include hypothetical scenarios in the guidance that outline the application of privacy considerations for a given situation or set of circumstances?
• Is it helpful to include examples taken from OPC investigation findings to demonstrate how privacy requirements apply?

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