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))
The research exception needs all three conditions, including telling the Commissioner before the disclosure. I found no OPC statement that treats commercial AI training as scholarly research, so a holder should not rely on this exception for a licence.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“for statistical, or scholarly study or research, purposes that cannot be achieved without disclosing the information, it is impracticable to obtain consent and the organization informs the Commissioner of the disclosure before the information is disclosed”
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 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))
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide