Children’s Hospital of Eastern Ontario (CHEO) Research Institute / Institut de recherche du Centre hospitalier pour enfants de l’est de l’Ontario (CHEO)

Published purpose

Data synthesis is rapidly emerging as a practical privacy enhancing technology (PET) for sharing data for secondary purposes. However, the strengths and weaknesses of this emerging technology are not fully appreciated and need to be evaluated. As well, we need to develop an understanding of how data synthesis would be treated under various privacy regimes in Canada. This project aims to provide a detailed overview of data synthesis as a PET used to facilitate data sharing within the Canadian context. It is intended to help Canadian organizations understand what data synthesis is, and to provide an assessment of contemporary methods and technologies and how they can be applied under current and proposed regulatory regimes. The proposed project consists of three main research phases: 1. An overview of data synthesis (environmental scan/literature review); 2. A legal analysis of data synthesis under Part I of PIPEDA and the Consumer Privacy Protection Act (CPPA) component of the Digital Charter Implementation Act, 2020 (Bill C-11), and; 3. Perspectives of Canadian regulators on data synthesis. The research will assess: i) whether PIPEDA and the proposed provisions of the CPPA adequately address data synthesis as a PET to protect individual privacy; ii) identify if there are gaps in both PIPEDA and in the legislative proposal, and the nature of such gaps; and iii) propose solutions to “close the gaps.”