Bill C-4 was introduced in the House of Commons on June 5, 2025 by the Minister of Finance and National Revenue. The bill passed third reading in the House of Commons on December 11, 2025 and received first reading in the Senate on the same day. It was adopted at second reading in the Senate on February 5, 2026. On that day, a motion was carried in the Senate referring the bill to the Standing Senate Committee on National Finance (NFFN) for study and authorizing the Standing Senate Committee on Legal and Constitutional Affairs (the committee) to examine and report on the subject matter of Part 4 of the bill in order to inform NFFN’s study. NFFN was required to submit its final report on Bill C-4 to the Senate by the end of Routine Proceedings on February 24, 2026.
Part 4 of Bill C-4 replaces the regime governing the protection of personal information by federal political parties (FPPs) under the Canada Elections Act. It would retroactively exclude FPPs from the application of provincial or territorial privacy legislation.
The committee studied Part 4 of Bill C-4 over the course of three meetings (six hours) on February 12, 2026, and heard testimony from the Chief Electoral Officer of Canada, the Commissioner of Elections Canada, the Office of the Privacy Commissioner of Canada, the Office of the Information and Privacy Commissioner of British Columbia, the Privy Council Office, as well as from advocacy organizations and other experts. The committee also heard from counsel for the Liberal Party of Canada, the Conservative Party of Canada, and the New Democratic Party. In addition to the testimony heard, the committee has received numerous written submissions from interested parties.
The committee appreciates the evidence provided and offers the following observations for the government and NFFN’s consideration.
Witnesses from the Privy Council Office and counsel for the FPPs described Part 4 of Bill C-4 as a narrowly targeted effort to clarify the federal government’s exclusive jurisdiction over the privacy obligations of FPPs. These witnesses underscored the importance of ensuring that FPPs are subject to a uniform national privacy regime under the Canada Elections Act, rather than a patchwork of provincial and territorial laws.
However, other witnesses observed that the regime proposed in Part 4 is not uniform from the perspective of electors or for enforcement purposes, since each party establishes their own policy with respect to the collection, use and retention of Canadians’ personal information. The Commissioner of Elections Canada noted that these policies are often drafted in vague language and frequently changed, creating further enforcement challenges.
Furthermore, several witnesses emphasized that the regime proposed in Part 4 is not substantively adequate, as it does not impose minimum privacy standards or meaningful independent oversight on FPPs. The committee heard that Part 4 lacks basic elements of a robust privacy regime, and that Canada is an outlier internationally in not having comprehensive data protection laws that apply to FPPs. Academic and policy experts, and advocacy organizations cautioned that, at a time when data-driven technologies used to influence voters are becoming increasingly sophisticated, this lack of protections creates significant risks to Canada’s democracy, digital sovereignty, and national security.
Witnesses emphasized the importance of subjecting FPPs to minimum privacy standards that reflect the core principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s private sector privacy legislation. These include requirements to:
• identify the purposes for which personal information is collected;
• obtain consent for the collection, use and disclosure of personal information;
• limit the collection, use, disclosure and retention of personal information to what is necessary for identified purposes;
• establish data security safeguards to protect against privacy breaches;
• provide a mechanism for individuals to access and correct their personal information under the control of FPPs; and
• report privacy breaches to affected individuals and to an independent oversight body.
The committee notes that some of these elements, along with prohibitions against selling or maliciously disclosing personal information, were included in former Bill C-65, An Act to amend the Canada Elections Act. This bill died on the Order Paper when Parliament was dissolved due to the 2025 general election. The protections proposed in Bill C-65 were not incorporated into Part 4 of Bill C-4.
Witnesses for the Privy Council Office noted that Part 4 does not preclude further legislation specifying more comprehensive privacy standards for FPPs, but could not confirm when or whether such legislation would be forthcoming.
Witnesses highlighted the need for meaningful independent oversight and enforcement of FPPs’ privacy obligations. The Commissioner of Canada Elections testified that her office would need additional powers to effectively enforce Part 4. The Privacy Commissioner of Canada indicated that oversight and implementation could be enhanced through formal collaboration between the Privacy Commissioner of Canada, the Chief Electoral Officer, and the Commissioner of Canada Elections.
The committee agrees with witnesses that the privacy obligations of FPPs should be set out in a uniform national regime. However, the majority of committee members are concerned that Part 4 falls far short of the minimum standards required to protect the individual and national interests of Canadians, at a time when global experience indicates that these interests are increasingly at risk.
This concern is heightened by the inclusion of Part 4 in an affordability bill that is proceeding on an expedited basis and by the lack of scrutiny of Part 4 in the House of Commons. Most witnesses appearing before the committee identified numerous deficiencies including gaps, anomalies, and ambiguities in Part 4 of Bill C-4. The committee finds itself in the frustrating position of attempting to conduct a thorough review of Part 4 without the time necessary to properly consider the many substantive amendments put forward by committee members, and that most committee members believe would be required to bring the proposed privacy regime governing FPPs up to standard, such as:
• minimum privacy standards aligned with recognized privacy principles, including rights of access and correction;
• privacy breach notification requirements;
• prohibitions on selling or maliciously disclosing personal information, and on misleading individuals regarding the purposes of data collection;
• independent oversight by the Office of the Privacy Commissioner of Canada;
• stronger administrative investigation tools for the Commissioner of Canada Elections or other designated authority;
• limits on the retroactive effect of Part 4; and
• measures to protect data sovereignty and to guard against foreign interference.
A majority of committee members believe that in light of this context, the evidence heard, and the seriousness of the deficiencies in Part 4 of Bill C-4, the following proposals are warranted:
1) That Part 4 of Bill C-4 be removed from the bill.
2) In the alternative, that Part 4 of Bill C-4 be severed from the other parts of the bill in order to allow for continued study of this Part while the remainder of the bill proceeds on an expedited basis.
3) In the alternative, that a sunset clause be included in Part 4 of Bill C-4 to cause the automatic repeal of this Part after two years, or another reasonable timeframe that would give the government sufficient opportunity to develop a more robust and comprehensive uniform privacy regime applicable to FPPs.
The subject matter of Part 4 of Bill C-4, An Act respecting certain affordability measures for Canadians and another measure. Order of Reference: 2026-02-05
You help us fulfill our mandate and stay independent. Every contribution – big, small, one-time, or recurring – makes a difference. Click here to donate.
