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IPC Strategic Priorities 2021-2025 – Final Report
When I started my five-year mandate as Information and Privacy Commissioner of Ontario in July 2020, I committed to focusing on the access and privacy issues that matter most to Ontarians. As part of this commitment, my office began a strategic planning exercise to identify the priorities that will guide the IPC’s work throughout my term as commissioner. The purpose of this exercise was to identify how we can better focus our energies and allocate our resources to advance those key access and privacy issues:
- that are of greatest relevance to Ontarians today and in the future
- that fall squarely within the IPC’s jurisdiction
- that the IPC is well-suited to lead, given our strengths, capacity, and ability to partner and collaborate
- on which the IPC is most likely to have a positive and significant impact
The mandate of the IPC includes resolving access to information appeals, investigating privacy breaches, reviewing privacy policies and information practices, conducting research, and educating the public about access and privacy rights. In carrying out this mandate we issue decisions and reports, develop practical guidance and public education materials, publish research papers, provide advisory services and participate in speaking engagements throughout the year. Given limited resources, we often have to make difficult decisions about which activities to carry out or advance.
Succinctly put, priorities will assist us in making these tough strategic choices.
That said, we also recognize the need to stay flexible. While strategic priorities will help guide us, we cannot predict everything that will happen over the next few years and will have to remain open to the potential for priorities to shift in response to the unknown. The COVID-19 pandemic that caught the entire world off-guard and overwhelmingly altered how we work and live our day-to-day lives is a case in point. Difficult times like these can inspire change, and even growth, as long as we maintain the agility to deviate from the course originally charted, to face unexpected challenges, and find alternate ways of navigating new obstacles in our path.
Taking these factors and realities into account, and having considered the valuable feedback of stakeholders as well as our ad hoc strategic advisory committee, I am pleased to set out the IPC’s strategic priorities for 2021-2025:
- Privacy and Transparency in a Modern Government
- Children and Youth in a Digital World
- Next Generation Law Enforcement
- Trust in Digital Health
Within each of these strategic priority areas, it is important to situate the appropriate role of the IPC. To be clear, our mandate is not to champion these modernization or digitization initiatives as an end in and of itself – this is the work for others to do. Rather, our role as an independent Office of the Legislature remains essentially and fundamentally focussed on promoting and protecting Ontarians’ privacy and access rights within each of these strategic areas. In so doing, our dual mission is to help enable and enforce compliance with Ontario’s access and privacy laws and thereby do our part in helping build citizens’ trust in the institutions and organizations that serve them.
More specifically, our goals in each strategic priority area are as follows:
|Privacy and Transparency in a Modern Government||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
|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||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||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.
We have also identified four cross-cutting approaches that we will adopt across all strategic priority areas as we work to achieve our stated goals:
- We will consider accessibility and equity issues to help reduce disparate outcomes on marginalized communities.
- We will be bold and aspirational in our vision, but also stay grounded in pragmatism.
- We will strive to be consultative and collaborative with relevant partners and stakeholders.
- We will develop the knowledge, skills, and capacity needed, both internally and externally, to advance these strategic priorities.
At the time of issuing this report, the IPC oversees compliance with four laws:
- Freedom of Information and Protection of Privacy Act (FIPPA)
- Municipal Freedom of Information and Protection of Privacy Act (MFIPPA)
- Personal Health Information Protection Act (PHIPA)
- Part X of the Child, Youth, and Family Services Act (CYFSA)
It is possible that the IPC’s mandate may be expanded by the introduction of an Ontario private sector privacy law. Should the government decide to move in this direction, the IPC must be able to pivot its focus to include this important priority and to operationalize and implement the new law. For this reason, we have developed a fifth provisional priority so that we are ready to hit the ground running should a new private sector privacy law be adopted:
|(Provisional) Made-in-Ontario Private Sector Privacy Law||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.|
On behalf of the IPC, I would like to thank the ad hoc strategic advisory committee members for the ongoing support and sage counsel they provided throughout this process. I would also like to express our most sincere gratitude to the nearly 60 respondents who gave their precious time and made considerable effort to file submissions as part of our public consultation process. While we recognize that we did not hear from all stakeholders, we were very encouraged to see such a high level of engagement from those who participated in the process and provided thoughtful insights into what the IPC could or should do over the next few years, and offered suggestions on how we might collaborate with others. As this exercise is about selecting priorities and making tough choices, we clearly cannot onboard all of the excellent ideas we received, but we have considered them all. We will continue to do so as we move towards implementation and welcome the opportunity to work with interested stakeholders.
Listening to Ontarians