Canada's privacy framework presents unique complexity with overlapping federal and provincial jurisdictions, bilingual requirements, and close economic integration with the United States requiring cross-border data handling considerations. Organizations operating in Canada must navigate PIPEDA at the federal level, provincial privacy laws in Quebec, Alberta, and British Columbia, sector-specific health information laws in multiple provinces, and the intersection of all these frameworks.
Canadian personal information also has distinct characteristics—from the Social Insurance Number as the primary national identifier to provincial health card formats, from bilingual documentation requirements to Canadian-specific address and phone formats. Effective Canadian data protection requires understanding these Canadian particularities, not applying generic North American rules.
Social Insurance Number (SIN)
The Social Insurance Number is Canada's primary national identifier for tax, employment, and government services—equivalent to the US Social Security Number in function and sensitivity. Proper SIN detection requires understanding its specific characteristics:
Format: The SIN is a 9-digit number, sometimes written with spaces or dashes (123-456-789 or 123 456 789). The first digit indicates the type: 1-7 for individuals, 8 for temporary SINs, 9 for temporary residents and those awaiting status.
Luhn Validation: SINs use the Luhn algorithm (modulus 10) as a check digit mechanism. This enables validation but also means some random 9-digit numbers accidentally pass validation. Context analysis distinguishes actual SINs from coincidentally valid numbers.
Sensitivity: The SIN is considered highly sensitive personal information. Its exposure enables identity theft, tax fraud, and unauthorized employment. Protection is emphasized in PIPEDA guidance.
Collection Limits: Unlike US SSNs, Canadian privacy law restricts SIN collection—only specific purposes (employment, tax, benefits) justify collection. Detection helps identify inappropriate SIN presence in other contexts.
PIPEDA and Federal Privacy
The Personal Information Protection and Electronic Documents Act (PIPEDA) governs private sector collection, use, and disclosure of personal information in commercial activities:
10 Fair Information Principles: PIPEDA codifies principles including accountability, consent, limiting collection, limiting use, accuracy, safeguards, openness, individual access, and challenging compliance. These principles align with international privacy standards.
Knowledge and Consent: PIPEDA requires individuals know what personal information is collected and consent to its collection, use, and disclosure. Redaction supports data minimization aspects of these requirements.
Breach Notification: PIPEDA requires breach notification when a breach creates "real risk of significant harm." Reducing stored personal information through redaction limits breach scope and notification obligations.
Cross-Border Transfers: PIPEDA allows international transfers with "comparable protection" but requires accountability. Redaction reduces transferred data's sensitivity.
Provincial Privacy Laws
Three provinces have private-sector privacy laws deemed "substantially similar" to PIPEDA, taking precedence within their jurisdictions:
Quebec: An Act Respecting the Protection of Personal Information in the Private Sector, significantly enhanced by Law 25 (2021), creates strong privacy rights including data minimization, purpose limitation, and individual control. Quebec law is among the most stringent in North America.
Alberta: Personal Information Protection Act (PIPA) governs private-sector privacy with requirements similar to PIPEDA but with some variations in consent exceptions and breach notification.
British Columbia: Personal Information Protection Act (PIPA) applies to BC private-sector organizations with requirements closely paralleling Alberta's law.
Ontario: While Ontario lacks general private-sector privacy law (PIPEDA applies), specific laws govern health information (PHIPA) and other sectors.
Provincial Health Information
Most provinces have health-specific privacy legislation protecting personal health information:
Ontario - PHIPA: Personal Health Information Protection Act governs health information custodians including healthcare providers, hospitals, and health record services.
Alberta - HIA: Health Information Act regulates health information in the public health system.
Quebec: Health information is addressed through general privacy law with additional professional secrecy requirements.
Each province's health insurance plan uses distinct identifier formats:
- OHIP (Ontario): 10-digit health card number with 2-character version code
- RAMQ (Quebec): 12-character code encoding name and birthdate
- BCMSP (British Columbia): 10-digit Personal Health Number
- Alberta Health Care: 9-digit number
Bilingual Requirements
Canada's official bilingualism creates unique processing requirements:
French in Quebec: Quebec's Charter of the French Language requires French as the language of business. Documents may be entirely in French, requiring native French NLP for accurate detection.
Federal Bilingualism: Federal government documents often appear in both English and French, either as separate documents or side-by-side translations. Processing must handle both simultaneously.
Mixed Language Documents: Private sector documents in Quebec often mix French and English. Names may appear in English form (John Smith) or French form (Jean-Pierre Tremblay) depending on context.
Address Formats: French addresses use "rue" instead of "street," "avenue" for both languages, province names in French (Québec, Nouvelle-Écosse, Colombie-Britannique).
Canadian Contact Formats
Canadian contact information follows distinct patterns:
Phone Numbers: Canadian numbers use the North American Numbering Plan (NANP) with 10-digit format (area code + 7-digit number). Area codes are province-specific: 416/647/437 for Toronto, 514/438 for Montreal, 604/778/236 for Vancouver.
Postal Codes: Canadian postal codes use alternating letter-digit format: A1A 1A1. The first letter indicates province/region (H for Montreal, M for Toronto, V for Vancouver). We validate against known valid FSA (Forward Sortation Area) patterns.
Addresses: Canadian addresses include apartment numbers before street (123-456 Main St.), province abbreviations (ON, QC, BC), and may use bilingual street types in Quebec.
Driver's License Formats
Each province issues driver's licenses with distinct numbering systems:
Ontario: Letter followed by 14 digits (e.g., A1234-56789-01234)
Quebec: Letter followed by 12 digits
British Columbia: 7 digits
Alberta: 9 digits
Other Provinces: Various numeric formats with provincial variations
We detect all provincial formats with appropriate validation to distinguish driver's license numbers from other numeric sequences.
Canadian Financial Identifiers
Canadian financial data has specific formats:
Bank Transit Numbers: 5-digit transit number + 3-digit institution number format (e.g., 12345-001). Institution numbers identify banks (001 = BMO, 002 = Scotiabank, 003 = RBC, 004 = TD, 010 = CIBC).
Account Numbers: Variable length depending on institution, typically 7-12 digits.
Credit Union Numbers: Credit unions use different numbering with institution numbers in the 800-899 range.
Canadian Tax Numbers: Business Number (BN) is a 15-character identifier for businesses (9-digit account + 2-letter program ID + 4-digit reference). GST/HST numbers use this format with RT program identifier.
Cross-Border Considerations
Canada-US economic integration creates cross-border data handling needs:
NAFTA/USMCA Context: Trade relationships mean Canadian companies frequently exchange data with US partners. Redaction helps meet both countries' requirements.
Cloud Services: Many Canadian organizations use US-based cloud services, creating cross-border transfer considerations. Quebec's Law 25 specifically addresses these scenarios.
Dual Presence: Organizations operating in both countries may have records with both Canadian and US identifiers (SIN and SSN). Detection must handle both accurately.
