OPC, Guidelines for obtaining meaningful consent: third parties that use data for their own purposes, and new purposes (Office of the Privacy Commissioner of Canada, Guidelines for obtaining meaningful consent (page modified 2025-08-11))
The regulator singles out disclosures to third parties that use the data for their own purposes, and expects consent for new purposes and new third-party disclosures, explicit where the data is sensitive or unexpected. A licence of records to an AI buyer is that kind of disclosure.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Particular attention should be paid to any disclosures to third parties that may use the information for their own purposes, as opposed to simply providing services for the first-party. ... Obtain consent when making significant changes to privacy practices, including use of data for new purposes or disclosures to new third parties. ... Obtain explicit consent for collections, uses or disclosures which generally: (i) involves sensitive information; (ii) are outside the reasonable expectations of the individual; and/or (iii) create a meaningful residual risk of significant harm.”
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Cited in this guide