Lobbied Canada

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Philippe Dufresne

Privacy Commissioner of Canada, Office of the Privacy Commissioner of Canada (OPC)6 communications in the past year

Lobbied by

Sun Life Financial

6

Infrastructure - Expand opportunities for long-term investors to support infrastructure investment, including opportunities to support investment in housing. Pensions & savings plans – Engage with public office holders regarding enhancing retirement and savings security for Canadians through retirement planning, public and registered savings plans, annuities, etc. Prescription drugs - Seeking to raise awareness about prescription drug & workplace benefit coverage. Group benefits & paramedical health care – Engage with public office holders regarding health care programs and policy that may impact group benefit plans. Climate/Environment – Engagements related to the impacts of extreme weather on the health and wellness of Canadians and expanding opportunities to meet our decarbonization commitments. International relations & trade – Engage with public office holders regarding international relations as it relates to Canada’s insurance industry. This includes how best to maximize the benefits of Canada’s trade relations for the industry and broader economy. Insurance and health regulation and legislation - Engage with public office holders regarding Canada’s financial services and health care sectors, in relation to the insurance industry. This may include the industry’s governing legislation and regulations, taxation policy, administration, and related issues, guidelines & rules. Cyber security, data, and privacy – Engage with public office holders on how to ensure the safety and integrity of Canada’s insurance industry’s data and technology systems. This may include engagement on privacy legislation, policy, and technological innovation in the insurance industry.

CANADIAN MARKETING ASSOCIATION

4

Discussions on the collection, handling, and use of data by companies and government institutions. Engagement with government on taxation matters, including proposed digital services tax. Provide input on immigration and training policies that support Canadians in finding meaningful employment and assist employers in securing skilled workers, particularly in areas such as marketing and AI. Engage in dialogue on the impact of trade agreements and tariffs, including the CUSMA, on marketing and its’ related services. Engage in discussions and consultations regarding the evolution of legislation, such as privacy, artificial intelligence and intellectual property laws that impact the competitiveness of marketing practices. Contribute insights to policy development aimed at growing Canada's digital economy to support competitiveness, including AI activities in the marketing sector. Engage in discussions regarding the evolution of privacy laws and regulations that impact marketing practices. Our aim is to contribute to the development of policies that effectively protect consumers while supporting innovation and economic growth in Canada's marketing sector. Competition Act: Discussions with government to ensure competition law and enforcement (with regards to deceptive marketing, misleading advertising provisions, and new measures related to competition in the digital economy) serves marketers and consumers.

Centre for Digital Rights

2

PIPEDA modernization including Bill C-36 Bill C-27, Digital Charter Implementation Act, 2022 - application to federal political parties Bill C-4, Part 4 - privacy and data protection regimes applicable to federal political parties Bill C-27 Digital Charter Implementation Act and Bill C-65 Act to Amend the Canada Elections Act - privacy and data protection regimes applicable to federal political parties

Hearn Law

BMO Financial Group

1

The Consumer Driven Banking Act and related regulations as it applies to banks The federal government’s framework for stablecoins and digital assets Canada Deposit Insurance Corporation Act as it relates to banks and the administration of the deposit insurance framework Federal government programs and policies related to Artificial Intelligence regulation Housing finance framework, including reforms to expand housing supply, mortgage underwriting regulations and covered bonds Financial institutions with respect to Canada/US relationship and trade policy Office of the Superintendent of Financial Institutions guidelines with respect to capital, liquidity, and non-financial risk The Canadian Payments Act, as it relates to management of Canada’s payment system and payments modernization The modernization of the supervisory framework for financial institutions as it relates to the responsibility for administering prudential and consumer measures Requirements for financial institutions as they relate to corporate governance rules under the Bank Act Promotion of the importance of a competitive financial sector in achieving improved economic development in Canadian regions Providing inputs with respect to capital requirements as they relate to Basel III and lending for businesses Official languages policy as it relates to financial services. Federal government programs and policies supporting growth for small businesses Federal government programs and policies respecting financing for infrastructure projects Federal government programs and policies on employment and training as they pertain to financial institutions Federal government programs and policies respecting consumers as they pertain to relationships with financial institutions Federal government programs respecting financing for the agriculture industry Federal government programs respecting financial services for Indigenous communities The Bank Act and the National Housing Act as they relate to potential measures affecting housing affordability and lending Promotion of resources to support mental health and well-being of Canadians Promotion of financial services available to finance Canadian infrastructure development; sharing of international best practices with respect to infrastructure policy, particularly in terms of options for project financing arrangements Privacy legislation and acts with respect to the banking industry’s collection, use and protection of personal information Office of Superintendent of Financial Institutions Guidelines regarding accounting rules regulating financial institutions Income Tax Act with respect to corporate income tax, capital tax, international taxation, personal taxation, and registered saving products Impact of federal national security policy as it relates to the banking sector Financial services policy with respect to study of retirement income security Federal government programs and policies to combat financial crimes Federal government programs and policies related to sustainability, natural resources and climate change in support of achieving net zero targets Federal government position with regard to ongoing discussions on international financial regulation reform, as it pertains to Canadian banks Federal government policies affecting Canada’s payment systems as well as access to financial data Bank Act with respect to its impact on financial sector

Bell Canada

1

Discussions regarding procedures and policies as well as best practices and reducing costs in procurement associated with end user devices, networks, support services and solutions, including development and deployment of sovereign AI capacity. Seeking to raise awareness about Bell’s technological innovations, including AI, with an aim to convey how policies affect investments in innovation and research. Copyright Act amendments affecting internet service providers and/or broadcasting distribution undertakings and/or broadcasting programming undertakings Discuss and sharing of best practices with respect to Bell Let’s Talk mental health initiative. Proposed government broadband programs, policies and initiatives including in rural and Northern Canada. The Comprehensive Progressive Agreement for Trans-Pacific Partnership (CPTPP), provisions related to copyright, culture, telecommunications and broadcasting. The Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), provisions related to copyright, culture, telecommunications and broadcasting. Spectrum policy framework with respect to technological and financial implications of government policies. Replacement Worker Legislation - legislation that bans replacement workers during a labour dispute hindering our ability to operate our networks and serve our customers Regulatory modernization of the Canada Labour Code. Proposing amendments pursuant to Income Tax Act. Potential Amendments to the Broadcasting Act. Potential Amendments to the Broadcast Act and Telecommunications Act as per legislative review. Policies relating to signal piracy, and copyright infringement Policies Relating to Broadcasting Distribution Undertakings with regard to the terms of carriage of our services by terrestrial and satellite television distributors Pension plan regulations with regard to their impact on the solvency funding and other requirements for Bell as a plan sponsor Legislation regulation or policies focused on critical infrastructure, cyber security and lawful access Information and Communications Technologies (ICT) labour force -- policies related to increasing the talent supply in Canada Broadcasting Policies Relating to Specialty and Pay Television Broadcasting Policies Relating to Conventional Television Broadcasting Policies Relating to Commercial Radio Broadcasting Licence Fee Regulations, 1997 under section 11 of the Broadcasting Act. An Act to amend the Consumer Privacy Protection Act and the Personal Information and Date Protection Tribunal Act, as well legislation, policies or regulation having impact on Bell customers from a privacy perspective, and with respect to obligations imposed on carriers with respect to intercept and subscriber information. Act respecting online communications platforms that make news content available to persons in Canada

CANADIAN IMPERIAL BANK OF COMMERCE ( CIBC)

1

The Proceeds of Crime (Money Laundering) and Terrorist Financing Act, initiatives for enhancement of reporting mandatory information, and risk assessment methodology. The introduction of policies, programs or legislation related to "Open Banking". The Canadian labour force and labour mobility as it relates to the Express Entry program. Policies related to Canadian economic growth, and international trade. Policies related to Canada's development of natural resources. Policies related to asset recycling and industry investment in public infrastructure development . Policies and programs that affect the Canadian housing market and lending practices. Policies and programs related to gender diversity, inclusion and accessibility. Personal Information Protection and Electronic Documents Act (PIPEDA), the Privacy Act, and any legislation and associated regulations with regard to privacy and security, identity theft risks, use and protection of information Payment Processing System with regard to rates, fees, oversight of credit and debit procedures Office of the Superintendent of Financial Institutions Act (OSFI) and regulations, in respect of regulatory compliance for banks Immigration policies and programs to address labour shortages and market needs. Canadian Payments Act, as it applies to applicable legislative reviews and the government's Payment's Modernization initiative. Canada Labour Code, Parts II and III Bank Act and regulations, in respect of the five year financial system review, as well as any changes resulting from the review.

Canadian Automobile Association

1

Seeking potential funding or partnership with ESDC's Senior's Directorate to enhance the resources CAA makes available to Canadian drivers as they age. Engage government on climate change as it relates to the impacts on Canadian vehicle owners. CAA regularly communicates with Natural Resources Canada's Alternative Fuels Directorate in relation to federal funding to build awareness of zero-emission vehicles and other efforts that aim to reduce GHGs from light duty vehicles. CAA is seeking Health Canada funding support for national advocacy activities that raise public awareness about the dangers of cannabis-impaired driving. CAA is engaging the federal government on issues related the growing problem of automobile theft. CAA is engaged in discussions in support of increased funding for and activities related to public awareness and research around the dangers of drug-impaired driving as well as more resources for law enforcement and the need for enforcement data. CAA is engaged in consumer advocacy work related to Canadian air travellers and Canada's air passenger rights regime. CAA engages in discussions in support of the protection of the consumer interest (privacy, competitive choice) with respect to connected vehicles in the auto industry. CAA advocates for better and safer active transportation infrastructure. It seeks federal encouragement of and funding for active transportation infrastructure projects (e.g. bike lanes, pedestrian paths) via explicit set aside funds exclusive to active transportation projects. Advocate Transport Canada in regard to national road safety issues and related policy, programming and regulations, including seeking grant support from the Enhanced Road Safety Transfer Payment Program for public awareness activities.

Canadian Bankers Association

1

Discussions relating to the legislative, regulatory, and policy developments related to digital currencies and cryptoassets Providing input on the prudential regulation of the banking sector Providing input on amendments to the Bank Act Providing input on federal budget measures that may impact the banking sector Discussions on supporting women’s advancement, career opportunities, and equitable outcomes in the financial services sector Discussing the Accessible Canada Act with the purpose of identifying, removing and preventing barriers for people with disabilities Discussions on strategies to mitigate tariff risks and navigate the review of the Canada-United States-Mexico Agreement Providing input on effective Artificial Intelligence regulation to balance risks and foster innovation Providing input on the regulatory framework to facilitate the process to become a federal credit union and support their operations Discussing plans on the Data Collection Modernization initiative Providing views on the Macroeconomic Stress Test (MST) 2.0 review Discussing Bill C-27 – Digital Charter Implementation Act, 2022, relating to the privacy and artificial intelligence provisions Discussions relating to the efficiency and effectiveness of the financial sector regulatory system Discussions on consumer issues relating to potential postal strike ensuring an appropriate scope of guidance Providing inputs on criminal interest rate as it relates to the calculation of the rate and exclusions Office of the Superintendent of Financial Institutions guidelines with respect to capital adequacy requirements, prudential limits and restrictions, accounting and disclosure, and sound business and financial practices Providing inputs on OSFI regulations and draft guidelines including in connection with culture, integrity and security, third-party risk, and operational risk Providing input on the development of the Consumer-Driven Banking Framework Providing inputs on Basel III Implementation with respect to capital floor phase-in and risk weights Providing inputs on Competition Act amendments Personal Information Protection and Electronic Documents Act (PIPEDA): seeking workable, practical approaches in the reform of PIPEDA Excise Tax Act with respect to Goods and Services Tax (GST) and Harmonized Sales Tax (HST) Support the development of an innovative, efficient, and secure payments ecosystem in Canada that benefits consumers Support the goals outlined in the National Cyber Security Strategy and collaborate with government, including the Canadian Centre for Cyber Security, to strengthen Canada’s cyber resiliency The Access to Basic Banking Services: seeking to clarify appropriate identification for opening accounts and to make account opening procedures more workable U.S. Mexico Canada Agreement (USMCA), trade agreements with other jurisdictions, World Trade Organization rules regarding cross-border trade in financial services Support the Government initiative of modernizing the Employment Equity Act and provide input to further strengthen the Act. Discussion relating to agricultural financing, including the efficient administration of the Advance Payments Program and the Canada Loan Administration Act Discussions relating to the development of Financial Consumer Protection Framework and voluntary commitments to promote protection for consumers Capital markets statutory, regulatory and self-regulatory organization regime applicable to banks as corporate issuers and their provincially regulated subsidiaries that are capital markets participants Discussion relating to housing finance framework, including reforms to expand housing supply, mortgage underwriting regulations and covered bonds Providing inputs on climate standards and disclosures Corporate governance statutory and regulatory regime for banks Canada Labour Code with respect to (i) impact on bank management of human resources, (ii) review of Part III of the Canada Labour Code, (iii) flexible work

Canadian Chamber of Commerce

1

CYBER SECURITY - Encourage the government to invest in cybersecurity innovation, talent, and infrastructure; modernize research and development; accelerate commercialization in the space; support the secure digitalization of small-and-medium-sized enterprises (SMEs); and improve the global competitiveness of Canada’s cybersecurity industry. ARTIFICIAL INTELLIGENCE - Advocate for future-proofed, globally competitive, and interoperable policies that position artificial intelligence as a positive economic driver, and support the responsible development, deployment, and use of AI in business. PRIVACY AND ACCESS TO INFORMATION - Ensure that the modernization of Canada’s privacy legislation strikes the right balance between protecting consumers and promoting the ability of firms to innovate and compete by responsibly and securely using data. HOUSING - Support policies that enable the creation of more housing supply, incentivize investment in residential construction, and restore housing affordability for Canadian families. NATIONAL SECURITY/ECONOMIC SECURITY - Advancing policies related to enhancing Canada’s economic and national security. Key priorities include strengthening economic resilience, prudently navigating geopolitical challenges to trade and international relations, safeguarding business operations against new and emerging threats, and fostering conditions for economic growth. TRANSPORTATION - Regarding the consistent funding of trade-enabling infrastructure projects; the development of a competitive and efficient transportation network including all modes of transportation. TELECOMMUNICATIONS - Creating the right investment incentives to foster vibrant competition in the sector as a whole; responding to decisions regarding third-party access that will impact the deployment of internet services in rural and remote communities; and responding to regulatory proposals re: cell phone pricing. TAXATION AND FINANCE – With regard to undertaking a comprehensive and independent tax system review. TAXATION AND FINANCE – With regard to the measurement and improvement of Canada’s tax competitiveness, including: reforming the taxation, remittance, filing and audit processes of Canadian businesses; removing tax barriers for childcare expenses; addressing the taxation of family business transfers; and mobilizing private capital for recovery and growth. TAXATION AND FINANCE - With regard to modernizing our financial systems through open banking and digital currencies TAXATION AND FINANCE - Responding to proposals addressing taxation of digital services. TAXATION AND FINANCE - Maintaining and expanding real-time data made freely available to Canadian businesses, municipalities, academic researchers, and community groups. SMALL BUSINESS – Legislation, regulations and support programs that give Canadian small and medium-sized enterprises (SMEs) the tools to grow in Canada and internationally, including reducing their red tape and compliance burden. PRIVACY AND ACCESS TO INFORMATION - Improving digital privacy legislation to meet the needs of industry. PENSIONS - Treatment of corporate pensions in the event of bankruptcy. NATURAL RESOURCES - Support for the adoption of policy recommendations to strengthen Canada’s world-leading position in the mining industry, oil and gas, and forestry products. OPEN DATA - Maintaining and expanding real-time data made freely available to Canadian businesses, municipalities, academic researchers, and community groups. LABOUR: Ensuring that any changes to the Canada Labour Code are implemented in response to defined and demonstrated issues and not to increase regulatory burdens for employers. INTERNATIONAL TRADE – With respect to issues relating to import and export controls INTERNATIONAL TRADE - Negotiating bilateral, regional, and multilateral trade agreements and promoting them to Canadian businesses. INTERNATIONAL TRADE - Improving federal laws and regulations pertaining to responsible business conduct r

Canadian Western Bank

1

Housing policies and CMHC programs National Security/Security in respect of its implications for financial institutions. Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations with respect to the proposed changes Personal Information Protection and Electronic Documents Act (PIPEDA) as it applies to the banking industry’s collection, use, disclosure, and protection of personal information Payment Clearing and Settlement Act as it applies to the five year financial system review Office of the Superintendent of Financial Institutions Act as it applies to regulation and compliance Investment Canada Act as it applies to competitiveness Income Tax Act as it applies to corporate taxation, investment, competitiveness and registered savings products Financial Consumer Agency of Canada Act as it applies to consumer protection Employment Equity Act as it applies to banks as employers Competition Act as it applies to banks and competitiveness Canadian Payments Association Act as it applies to the five year financial system review Canada Small Business Financing Act as it applies to credit for SMEs Canada Labour Code as it applies to banks as employers Canada Deposit Insurance Corporation Act as it applies to the five year financial system review Bankruptcy and Insolvency Act in respect of its implications for banks Bank of Canada Act as it applies to the five year financial system review Bank Act and other financial services legislation as they apply to financial institutions in the context of the five year financial system review Anti-Spam legislation as it applies to anti-spam requirements

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May 4, 2026
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