OFA provided comments on the proposed privacy reforms intended to address gaps in Ontario’s legislative privacy framework and to establish comprehensive, up-to-date rules to protect privacy rights. OFA fully supports ensuring the privacy of our members’ personal information. OFA believes personal information of our members should be protected and not released without their consent by anyone, including the government. OFA believes business information should be afforded the same protections and privacy considerations provided to personal information when that business information may reveal personal information. OFA strongly recommends that the Freedom of Information and Protection of Privacy Act (FIPPA) be amended to ensure information is not released by government without the consent of the person(s) the information relates to, and that business information be treated as personal information when the business and personal information are the same information, or the business information could be used to obtain the personal information of the business owner(s) or employee(s). OFA also strongly recommends that the Ontario government remove and cease to make available through Ontario’s Open Data, or any other initiative, all business information which may identify, or may be used to identify, personal information. OFA further recommends amending provisions in the Ontario Corporations Act and the Ontario Not-for-Profit Corporations Act that require the release of shareholder/member contact information to third parties to instead require a corporation, when appropriate, to send the information directly to its shareholders/members on behalf of the third party. OFA fully supports the proposal to increase transparency for individuals by providing them with more detail about how their information is being used by businesses and organizations; having clear consent provisions allowing individuals to revoke consent at any time, and adopting an “opt-in” model for secondary uses of their information; and giving individuals the right to obtain their data in a standard and portable digital format. With respect to the right for individuals to request information related to them be deleted or deindexed, i.e. “the right to be forgotten”, OFA believes this right should be subject to certain limitations such as when the information is required by law (for example the requirement to have a contact list of all members/shareholders of the corporation) or when complete information is needed for an emergency response purpose (such as a foreign animal disease outbreak).