As you may recall, I recently wrote about the Office of the Information and Privacy Commissioner of Ontario (IPC) seeking feedback for strategic priority setting for the next five years. I discussed the consultation paper, which included several potential strategic priorities that were being considered, along with some cross-cutting approaches that could be applied across all strategic priorities. In April 2021, the final report was released setting out the selected strategic priorities.
More specifically, the IPC wanted to identify how to better focus its energies and resources to advance access and privacy issues that were most relevant and impactful, and within its jurisdiction and capacity. After considering the feedback of stakeholders and the ad hoc strategic advisory committee, the following priorities and goals were chosen:
- Privacy and transparency in a modern government: the goal is to advance Ontarians’ privacy and access rights by working with public institutions to develop bedrock principles and comprehensive governance frameworks for the responsible and accountable deployment of digital technologies
- Children and youth in a digital world: the goal is to champion the access and privacy rights of Ontario’s children and youth by promoting their digital literacy and the expansion of their digital rights while holding institutions accountable for protecting the children and youth they serve
- Next generation law enforcement: the goal is to contribute to building public trust in law enforcement by working with relevant partners to develop the necessary guardrails for the adoption of new technologies that protect both public safety and Ontarians’ access and privacy rights
- Trust in digital health: the goal is to promote confidence in the digital health care system by guiding custodians to respect the privacy and access rights of Ontarians, and supporting the pioneering use of personal health information for research and analytics to the extent it serves the public good
As an independent Office of the Legislature, the IPC promotes and protects Ontarians’ privacy and access rights within each of the above strategic areas. In order to accomplish this task, the IPC’s dual mission is to help enable and enforce compliance with Ontario’s access and privacy laws and thereby do its part in helping to build citizens’ trust in the institutions and organizations that serve them.
In addition, the IPC will be using four cross-cutting approaches across all strategic priority areas:
- consider accessibility and equity issues to help reduce disparate outcomes on marginalized communities
- be bold and aspirational in the IPC’s vision, but also stay grounded in pragmatism
- strive to be consultative and collaborative with relevant partners and stakeholders
- develop the knowledge, skills, and capacity needed, both internally and externally, to advance these strategic priorities
The IPC also pointed out the need to be flexible in its approach. This was especially the case when it came to the possibility of the IPC’s mandate being expanded by the introduction of an Ontario private sector privacy law; the IPC has developed a fifth provisional priority and associated goal to apply if this takes place:
- (Provisional) Made-in-Ontario private sector privacy law: the goal is to develop the foundational building blocks and oversight mechanisms for implementing Ontario’s private sector privacy law in a manner that protects privacy, supports responsible innovation, and accords with our province’s unique circumstances and economic reality
At this point, the next step is to develop short-term and long-term action plans for operationalizing each priority, along with the criteria for measuring and evaluating the IPC’s work and reporting on the progress over time.