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Lisa R. Lifshitz
transactions which largely remain illegal outside of Canada.
Subject organizations include private sector businesses in Canada that collect, use or disclose personal information during commercial activity, unless it takes place entirely within a province with “substantially similar” private sector privacy law, which currently includes only Alberta, British Columbia and Quebec. The Guidance correctly notes that if the cannabis retailer is operated by a provincial government or if heath information is collected, then provincial public sector and health privacy legislation may apply to this activity rather than PIPEDA.
While the guidance contains much useful advice, much of its application is currently limited in Ontario as recreational cannabis can currently only be