Implications of Canada’s proposed privacy overhaul Bill C-36 for organizations | Insights
Implications of Canada’s proposed privacy overhaul Bill C-36 for organizations | Insights
Publish Date: 2026-06-18 17:43:00
Source Domain: www.mltaikins.com
This article prepared with the assistance of summer student Zoë Goetz.
On June 15, 2026, the Government of Canada introduced Bill C-36, which would enact the Protecting Privacy and Consumer Data Act (PPCDA), amend the Personal Information Protection and Electronic Documents Act (PIPEDA) and make related amendments to other Federal legislation. If passed, Bill C-36 would represent the most significant overhaul of Canada’s private-sector privacy framework in over 25 years. This follows previous attempts with Bill C-11 in 2020 and Bill C-27 in 2022, both of which died on the Order Paper when Parliament was dissolved.
Bill C-36 responds to the rapid evolution of digital and data-driven technologies, including the increased use of artificial intelligence, and aims to modernize Canada’s approach to protecting personal information while supporting responsible innovation. Organizations that collect, use or disclose personal information in the course of commercial activities should consider if Bill C-36 might apply to them and what it may mean for their operations.
Important note: Bill C-36 received first reading on June 15, 2026, and must still pass through the full legislative process before becoming law. The provisions discussed below reflect the Bill as introduced and may be subject to amendment.
Who Bill C-36 applies to
The PPCDA would apply to any organization that collects, uses or discloses personal information in the course of commercial activities, as well as to the personal information of employees of Federally regulated organizations. Alberta, British Columbia and Quebec each have their own private-sector privacy legislation – the Personal Information Protection Acts (PIPA) in Alberta and British Columbia and the Act respecting the protection of personal information in the private sector in Quebec – that are currently deemed substantially similar to PIPEDA and overseen by their respective provincial privacy commissioners. Unless…
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