Policy and regulationDigital infrastructure and AI
Canada privacy commissioner calls for usable AI transparency
The OPC’s consultation submission says AI disclosures should be understandable at decision time and address privacy, system limits, recourse and incident reporting.
- Event
- First published on EPC Feed
- Sources
- 5 listed below
- Reading time
- 3 min
On 23 October, the Office of the Privacy Commissioner of Canada (OPC) published its submission to Innovation, Science and Economic Development Canada’s consultation on AI transparency. The letter itself is dated 23 September 2026; the OPC release and AI-topic index identify 23 October as the date the submission was published. The submission responds to a federal discussion paper that asks whether additional measures are needed to help people understand AI-generated content, AI interactions, information about AI systems, AI incidents and AI agents. The OPC agreed those five areas raise transparency issues and said that addressing them would support responsible innovation. The release records the publication of advice; it does not announce a new regulation or a decision to impose disclosure duties.
The commissioner’s central qualification is that information must be understandable and available when it matters to a person’s decision. A disclosure buried in documentation or presented in technical language may technically exist without helping a user assess a service or exercise a right. The submission connects that standard to meaningful consent under federal privacy law, which calls for people to reasonably understand an organization’s purposes and the nature, purpose and consequences of processing. For AI systems, the OPC suggests the relevant information can include what personal information is collected, who receives it, why it is used and what risks or consequences follow.
The submission treats transparency as a set of related questions across different stages of AI use. It says people should be told when automated systems make or inform significant predictions, recommendations or decisions about them, so they can understand the process and use available review or explanation mechanisms. It also highlights cases where an AI-enabled system collects personal information without a direct conversation with the person affected. The commissioner cautions against fragmented notices: people should not have to consult separate documents to learn how personal information is used depending on whether AI is involved.
For system information, the OPC points to known capabilities, limitations and intended uses. It draws on its earlier work on generative AI, including its recommendation that users receive accessible explanations of model accuracy, training-data categories and sources, and explainability limits. Businesses deploying AI also need enough information from developers to judge whether a tool is suitable for a proposed purpose. The submission therefore describes transparency as useful to both individuals and organizations procuring or operating systems, while recognizing that excessive or duplicative disclosure can overwhelm users and impose compliance effort without improving meaningful choice.
On incidents, the commissioner supports clear information about system failures and says a mechanism for users to report failure cases, alongside developers’ regular testing, could help. Timely and complete reporting is especially relevant when incidents involve personal information; the OPC points to delays in privacy breach reports as a practical lesson for any future AI incident process. On AI agents, it says its work is ongoing and offers no specific measure. The submission is thus a set of consultation recommendations, not a finalized position on a tracking regime.
The federal discussion paper places the exercise within Canada’s AI strategy and describes transparency as one possible foundation for accountability and informed decisions, while acknowledging it cannot address every AI risk. It asks for feedback rather than prescribing a preferred policy. The OPC’s October 23 publication adds a privacy commissioner’s perspective to that process, emphasizing comprehensibility, recourse and fit with existing privacy notices. No consultation outcome, implementation timetable or new legal requirement was announced in the release.
Sources
- Office of the Privacy Commissioner of Canada publishes comments to government consultation on AI transparency
- Submission of the Office of the Privacy Commissioner of Canada on Enhancing trust in artificial intelligence through increased transparency
- Privacy and artificial intelligence (AI)
- Enhancing trust in artificial intelligence through increased transparency
- 2025 G7 Data Protection and Privacy Authorities Roundtable Statement
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