Policy and Public Consultation Submissions

The submissions posted here serve—I hope—as a starting point for regular contributions to public consultations on issues of information policy. Sadly, participation in these efforts is typically limited to corporate interests and lobbying groups, and those voices dominate the discussion. Much more is needed, and I’m always interested in helping out. If you’d like to collaborate on a submission you think I’d be interested in, please contact me.

Mar 2021: Consultation on the extension of Canada’s term of copyright

Adoption of the new Canada US Mexico Agreement (CUSMA) has forced Canada to extend the term of copyright protection from life of the author plus 50 years to life of the author plus 70. This brings us in line with the United States, but implements it through a “back door” treaty approach that bypasses public consultation and subtly sidesteps the results of the recent comprehensive Copyright Act review. The government ask for comment on how to implement the CUSMA commitment, asserting that the decision to go forward with the extension is final.

Michael McNally and I put together a brief submission that called the extension into question and advocated for as few barriers as possible for people interested in exploiting works after the 50-year term.

Sept 2019: Promoting Trust and Confidence in Ontario’s Data Economy

The Government of Ontario used a set of discussion papers and questions to get feedback on how they might build a digital strategy for the province. I submitted comments in response to the first discussion paper, on the topic of trust and confidence (which touched on many issues of data collection and management).

My submission advocated a human rights based approach to privacy, the implementation of a “self-sovereign” personal data management platform, and mechanism for informing people about the data collection & use practices of online services.

Jan 2019: Canadian Communications Legislation Framework

These comments were submitted by Michael B. McNally and me as part of to ISED Canada’s Broadcasting and Telecommunications Legislative Review in January 2019.

Topics addressed include rural, remote and indigenous broadband connectivity, network neutrality, and recommendations for changes to the policy objectives of the Telecommunications Act.

Apr 2018: The Office of the Privacy Commissioner’s position paper on online reputation

Created in April 2018, in partnership with Arija Fisher and Lorisia Macleod. This submission was a response to the Canadian Office of the Privacy Commissioner‘s position on online reputation (which centered on “the right to be forgotten”).

The Office has not yet posted or reported on submissions received as part of this notice of consultation.