Protecting Canadians' political data

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In a nutshell

The CBA’s Privacy and Access Law Section supports the objective of the Strong and Free Elections Act (Bill C-25) to strengthen electoral integrity. However, the CBA is concerned that the bill does not address key structural gaps in the political party privacy regime, including the treatment of political data as sensitive, individual access and correction rights, and independent oversight.

Key recommendations

Bill C-25 amends a framework that does not adequately protect Canadians’ right to see, correct, or independently challenge personal information held about them by the political parties that seek their votes. The CBA therefore recommends that the federal government amend Bill C-25 further:

1. To classify political opinion as sensitive personal information, subjecting it to proportionate consent and processing requirements consistent with international best practices.
2. To grant individuals explicit rights of access to, and correction of, personal information held by federal political parties, consistent with the Office of the Privacy Commissioner's 2019 Guidance for federal political parties.
3. To establish independent oversight of political party privacy practices by the Office of the Privacy Commissioner of Canada, rather than the Chief Electoral Officer.
4. To require political parties to provide transparency regarding the use of AI systems or automated decision-making for voter profiling and micro-targeting.

Why this matters

In late April 2026, a separatist group in Alberta publicly posted a searchable database of 2.9 million Albertans' names, home addresses, and phone numbers drawn from the provincial List of Electors. Alberta's own Privacy Commissioner confirmed her office has no jurisdiction over the political party that allegedly sourced the data, because the Personal Information Protection Act in Alberta does not apply to political parties. This is the structural gap the CBA is asking government to close at the federal level, before the same failure occurs under the Canada Elections Act.

Without the classification of political data as sensitive, access and correction rights, and independent oversight, the framework will continue to fall short of the standards Canadians expect and that comparable democracies have already adopted.

Read the full submission.