FIPA requested and was granted the opportunity to present to the Standing Senate Committee on Legal and Constitutional Affairs (LCJC) in The subject matter of Part 4 of Bill C-4, An Act respecting certain affordability measures for Canadians and another measure.
FIPA Executive director Jason Woywada appeared in committee via video conference February 12th. We were grateful for the opportunity to present and hope that we’ve contributed to the matter in a meaningful manner to the benefit of Canadians.
Video of the committee is available here. You can read our full brief to the committee. The full transcript of the presentation follows.
Chair, Honourable Senators, thank you for the opportunity to appear today.
My name is Jason Woywada. I’m the Executive Director of the Freedom of Information and Privacy Association or FIPA.
I am presenting from the unceded ancestral homelands of the Lekwungen -speaking peoples in what is now known as Victoria, BC.
I will be very direct with the Committee.
Bill C-4, Part 4 represents a significant departure from established Canadian democratic and privacy norms that places the personal information of Canadians at increased risk.
It does not simply modernize electoral rules.
It removes guardrails protecting the personal information of Canadians at a time when global experience tells us those guardrails are increasingly important.
Political parties in Canada invest heavily in collecting and analyzing personal information.
Parliament is well aware that this data can be misused and weaponized.
In 2018, the House of Commons Ethics Committee examined data-driven electoral manipulation connected to Brexit, prompted by Canadian corporate involvement and the offshoring of voter data.
In 2024, the Public Inquiry into Foreign Interference in Federal Electoral Processes examined coordinated efforts by foreign states to influence Canadian elections through domestic channels.
Now, in 2026, we have organizations and political parties aligning with separatists and a foreign power to promote a referendum question to break up the country.
Instead of drawing from and treating these studies and experiences as cautionary lessons, Bill C-4, Part 4 moves in the opposite direction and opens the floodgates.
Part 4 is troubling for numerous reasons, it:
removes meaningful limits on the collection, use, and retention of personal information by political parties and their agents;
removes independent oversight specialized in information management; and
removes citizen rights without establishing any minimum national standards framework.
Additionally, there is:
no alignment with Canadian Privacy Standards established in 1996 and reaffirmed in 2001;
no right for people to access their own personal information under the control of political parties;
no breach-notification obligations; and
no independent regulator empowered with order-making capabilities.
Part 4 grants political parties more power and less oversight in the collection, use, and retention of personal information than Canada’s spy agency.
At a moment of declining public trust, Parliament is effectively saying: “Trust the parties.” Experience tells us that trust without law is no protection for the public.
Political parties now hold information that is as valuable as the money they raise.
Those managing these systems operate under intense pressure to identify, persuade, and mobilize voters.
This creates predictable structural risks and dangerous moral rationalizations that cannot be addressed through voluntary policies alone.
That is precisely why Canadian privacy law has always relied on a principles-based approach with legislated guardrails.
Civil rights — including privacy — have long been protected through shared federal and provincial frameworks, enforced by independent officers of Parliament and the legislatures.
Part 4 attempts to remove those protections when personal information is held by a single, powerful class of actors, political parties and their agents, without replacing them with equivalent federal safeguards.
That approach is inconsistent with Canadian federalism, established privacy jurisprudence, and democratic principles.
Foreign interference does not require hackers overseas.
It often relies on lawfully obtained domestic personal information, accessed through intermediary domestic actors that can include Canadian political parties.
In such cases, the data may be lawfully collected, and election law may not be formally breached — yet the cumulative effect can still be the distortion of democratic choice, decision-making, and the erosion of electoral sovereignty.
That is why privacy and fair information safeguards are also national security safeguards.
By weakening those safeguards without replacing them, Bill C-4 lowers the barrier for foreign interference.
In conclusion, it is fact that the elected members of the House of Commons have passed this law.
It is also a fact that, as majority members of federal political parties involved in ongoing litigation – they have vested interests in Part 4. That is unusual, and it is precisely the sort of scenario where sober second thought is essential.
In past interventions on privacy, national security, and electoral law, the Senate sought to strengthen legislation by seeking to add guardrails when the House moved too quickly or too narrowly.
Bill C-4, Part 4 calls for that same corrective function.
The Senate can:
Ensure Canadians do not lose long-recognized civil rights simply because their personal information is controlled by a political party;
Require minimum national standards for political parties aligned to Canadian Fair Information Principles and Canadian Privacy Standards;
Restore the need for involvement of independent oversight with expertise in information management; and
Ensure constitutional alignment while explicitly accounting for foreign-interference risks.
These steps would not impede democratic participation. They would ensure it occurs within enforceable, transparent, and constitutionally sound boundaries.
Once privacy protections are removed, they are unlikely to come back and the harm may be irreversible.
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