CPPA: identifying the inscrutable meaning and policy behind the de-identifying provisions

The Consumer Privacy Protection Act (CPPA) will make substantial changes to Canada’s privacy law. As noted previously, the bill includes many of the provisions in the Personal Information Protection and Electronic Documents Act (PIPEDA), plus a lot more. In a prior post, CPPA: transfers of personal information to service providers, I examined the new provisions dealing with transfers of personal information to service providers. In this post I examine the significant proposed changes to the law as they relate to personal information that has been “de-identified”.…