PIPEDA sections 2 and 4(1): commercial activity, and staff data only for federal works (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, s. 2 (commercial activity), s. 4(1))
A paid licence of records is a commercial activity, so PIPEDA reaches the disclosure. Staff information is covered by PIPEDA only where the employer is a federal work, undertaking or business; for other employers it depends on the province's own law, which this research did not read for every province.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“commercial activity means any particular transaction, act or conduct or any regular course of conduct that is of a commercial character, including the selling, bartering or leasing of donor, membership or other fundraising lists. ... This Part applies to every organization in respect of personal information that (a) the organization collects, uses or discloses in the course of commercial activities; or (b) is about an employee of, or an applicant for employment with, the organization and that the organization collects, uses or discloses in connection with the operation of a federal work, undertaking or business.”
Where it was read
Also read from the same source
- For customers or staff in Canada, has each person consented to this new use, or will the data be anonymised to the Canadian standard before it leaves? For Quebec, is the privacy impact assessment done and the written agreement ready?
- PIPEDA Schedule 1, clause 4.2.4: a purpose not previously identified needs the individual's consent (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, Schedule 1, cl. 4.2.4)
- PIPEDA Schedule 1, clause 4.5: no use or disclosure for other purposes without consent (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, Schedule 1, cl. 4.5)
- PIPEDA section 5(3): only purposes a reasonable person would consider appropriate (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, s. 5(3))
- PIPEDA section 7.2(4): the business transaction exception excludes the sale or lease of personal information itself (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, s. 7.2(4))
- PIPEDA section 7(3)(f): disclosure without consent for statistical or scholarly research (Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, s. 7(3)(f))
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide