The Portfolio Management Association of Canada (PMAC) is pleased to have the opportunity to submit the following comments regarding the Government of Canada’s proposals via the Ministry of Innovation, Science and Economic Development to amend the Personal Information Protection and Electronic Documents Act (PIPEDA) as set out in the discussion paper titled “Strengthening Privacy for the Digital Age” (referred to in this letter as the Federal Proposal or the Consultation).
As background, PMAC represents over 270 investment management firms – both Canadian and foreign – registered to do business in Canada as portfolio managers with the members of the Canadian Securities Administrators (CSA). In addition to this primary registration, most of our members are also registered as investment fund managers and/or exempt market dealers (we refer to these entities collectively herein as “asset managers”). PMAC’s members encompass large and small firms, and “traditional” as well as on-line firms, managing total assets in excess of $2.7 trillion for clients.
PMAC’s mission statement is “advancing standards” and we are consistently supportive of measures that improve standards for the benefit of investors (the clients of asset managers). We applaud the Federal government’s aim of ensuring that Canadians can trust that their privacy is protected, that their data will not be misused, and that companies communicate privacy matters in a simple and straightforward manner. We also support the 10 broad principles outlined in the Digital Charter. We believe the Federal Proposal is a timely and important initiative.
PMAC’s member firms echo the feedback received by the Federal government that PIPEDA needs to be modernized and streamlined in a way that both supports innovation and protects Canadians.