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After Bill C-27

When Parliament introduced Bill C-27, it was billed as a sweeping overhaul of Canadian privacy and artificial intelligence governance. The proposal bundled three major initiatives: 

  • The Consumer Privacy Protection Act (CPPA). 
  • The Personal Information and Data Protection Tribunal Act. 
  • The Artificial Intelligence and Data Act (AIDA). 

Had it passed, Bill C-27 would have created new obligations for employers around data handling, employee privacy, and AI use in hiring and workplace management. But as of mid-2025, Bill C-27 is officially off the table—it did not survive into law. 

That doesn’t mean HR managers can relax. If anything, the compliance bar is getting higher, but in a different way: provincial rules are tightening while Ottawa resets. Employers that fail to prepare will find themselves scrambling in 2026. 

Where Things Stand Now 

Federally 

  • Bill C-27 has stalled and expired. 
  • The federal government is expected to bring forward a new proposal, but nothing is active right now. 
  • Until then, the current federal private-sector privacy law (PIPEDA) still applies. 

Provincially 

Several provinces are stepping into the vacuum with their own reforms: 

  • Québec’s Law 25 (fully phased in by 2024) sets some of the strictest privacy requirements in North America, including mandatory privacy impact assessments and hefty fines. 
  • Ontario has signaled interest in its own privacy legislation and has taken a harder look at AI use in employment and public services. 
  • British Columbia and Alberta already operate their own private-sector privacy regimes and are expected to modernize them. 

The result is a patchwork: national employers must navigate overlapping and sometimes diverging rules. 

Why HR Managers Can’t “Stand Down” 

Even though the federal mega-bill is gone, the trends that fueled it (concerns about privacy, data protection, and A) are accelerating: 

  • Employee trust is at stake. Surveys show workers are more concerned than ever about how employers use their data, especially in an era of remote monitoring and AI-driven productivity tools. 
  • AI in HR is under the microscope. From resume screening algorithms to performance-tracking software, AI systems carry risks of bias, discrimination, and lack of transparency. 
  • Regulators are watching. Québec’s privacy authority has already begun enforcement under Law 25, and other provinces are poised to follow. 

What HR Managers Should Do for 2026 

  1. Conduct a Privacy & Data Audit
    • Map out what employee data you collect, why you collect it, and where it is stored. 
    • Identify cross-border data transfers (e.g., if your HRIS is hosted outside Canada). 
    • Review retention policies—are you keeping data longer than necessary? 
  1. Prepare for AI Oversight
    • Inventory any AI tools used in recruitment, performance management, scheduling, or workplace monitoring. 
    • Ask vendors about bias audits and transparency practices. 
    • Build internal documentation so you can demonstrate responsible use if challenged. 
  1. Update Consent & Transparency Practices
    • Ensure employees understand how their personal data and work performance information is used. 
    • Use plain language policies, not just dense legal boilerplate. 
    • Provide employees with clear channels to ask questions or opt out where feasible. 
  1. Strengthen Governance Structures
    • Appoint or confirm a Privacy Officer role in HR or compliance. 
    • Build a cross-functional team (HR, IT, Legal) to manage privacy and AI issues. 
    • Incorporate privacy/AI risks into enterprise risk management frameworks. 
  1. Watch for New Developments
    • Expect a new federal privacy/AI proposal in the next Parliament. 
    • Track Ontario’s legislative moves and any reforms in Alberta/BC. 
    • Engage with employer associations and chambers of commerce to stay ahead of consultations. 

Looking Beyond Compliance: Building a Culture of Trust 

Employees increasingly judge their employers not only on pay and benefits but also on how responsibly they handle personal information. HR leaders who get ahead on privacy and AI aren’t just avoiding fines, they’re building credibility. 

Practical steps like sharing data-handling FAQs with staff, holding “Ask Me Anything” sessions with your privacy officer, or providing training on responsible AI can send a powerful message: we respect your rights, and we’re accountable. 

Bottom Line 

Bill C-27 may be gone, but the issues it tried to address are alive and pressing. For HR managers, the path forward is clear: 

  • Stay compliant with PIPEDA and provincial laws today. 
  • Prepare for AI oversight before it arrives. 
  • Build trust with employees through transparency and accountability. 

By weaving privacy and AI governance into your 2026 HR strategy, you’ll not only avoid regulatory headaches but also strengthen your employer brand in an increasingly data-sensitive world.