constitutes destruction as well as the significant fines for failing to
safely destroy information that is no longer needed.
NAID-Canada believes that the amendments proposed here would
restore Canada’s leadership and, more importantly, give Canadians
the enhanced privacy protections enjoyed in other countries.
1 See https://nakedsecurity.sophos.com/2013/01/15/medical-patients-health-
2 See http://www.hhs.gov/about/news/2014/06/23/800000-hipaa-settlement-
3 See http://www.lexology.com/library/detail.aspx?g=5af8a709-0850-487d-
4 See http://www.hipaajournal.com/hipaa-settlement-reached-dumpster-phi-exposure/
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Trade Commission (FTC) fined a Las Vegas real estate broker
$35,000 for leaving 40 boxes of customer tax returns, bank
statements, consumer reports and other financial records in a
public dumpster. 3 Meanwhile, a Missouri medical company faced
fines of up to $1.5 million for leaving medical records in a public
When it comes to information destruction, there is no excuse for
failing to ensure documents are destroyed in a safe and secure
manner. As the cases above demonstrate, the U.S. and State
Governments take this matter very seriously and have been
imposing significant fines.
Recommendation: Empower the Privacy Commissioner to impose
fines for egregious or systemic privacy breaches.
Canada’s Lost Leadership
Canada used to be regarded as a global leader when it comes to
privacy protection. However, that distinction has waned as other
countries adopt more stringent privacy protections. Within our own
sphere of information destruction, we have documented above
the greater clarity required in other jurisdictions around what
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