Records / Laws and rulings

OPC, Guidelines for processing personal data across borders: a transfer for processing is a use, not a disclosure (Office of the Privacy Commissioner of Canada, Guidelines for processing personal data across borders)

This rule covers a service provider working for the holder (storage, support tools). A buyer that trains its own model is not processing for the holder, so my reading is that the licence is a disclosure and needs consent; I found nothing from the OPC that says otherwise.

Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text

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