Uploaded October 2025 | Updated September 2026, 1 hour ago
In this episode, Canadian privacy lawyer David Fraser breaks down the joint investigation by Canada’s federal and provincial privacy commissioners into TikTok — an interesting, complex and consequential privacy finding. The report tackles three major issues: whether TikTok’s data practices (especially with respect to young users who circumvent age-gating) serve a legitimate purpose, whether its consent process is valid and meaningful, and whether it meets transparency obligations under Quebec law. This episode explains the key findings, including TikTok’s commitments to introduce new age-verification systems, restrict ad targeting for youth, and overhaul its privacy communications for Canadian users.
But this case also raises a bigger question: Have Canada’s privacy regulators set an impossible standard? In seeking to protect children’s privacy, the Commissioners may have required TikTok to collect more sensitive information — including facial scans or identity documents — from all users. David argues that these well-intentioned recommendations risk making privacy compliance more invasive, not less. Watch (or listen) for a deep dive into how this decision reshapes the balance between privacy, practicality, and policy.
The federal/provincial privacy finding is here: priv.gc.ca/en/opc-actions-and-decisions/investigations/investigations-into-businesses/2025/pipeda-2025-003
Where you can find me
► Privacylawyer blog: blog.privacylawyer.ca
► My law firm: mcinnescooper.com/people/david-fraser
► Twitter: twitter.com/privacylawyer
► LinkedIn: linkedin.com/in/davidtsfraser
Disclaimer: This is intended for education and information only and should not be taken as legal advice. If you need advice for your particular situation, you should seek out qualified counsel.
All views expressed are solely those of the creator and should not be attributed to his firm or any of its clients.
In this episode, Canadian privacy lawyer David Fraser breaks down the joint investigation by Canada’s federal and provincial privacy commissioners into TikTok — an interesting, complex and consequential privacy finding. The report tackles three major issues: whether TikTok’s data practices (especially with respect to young users who circumvent age-gating) serve a legitimate purpose, whether its consent process is valid and meaningful, and whether it meets transparency obligations under Quebec law. This episode explains the key findings, including TikTok’s commitments to introduce new age-verification systems, restrict ad targeting for youth, and overhaul its privacy communications for Canadian users.
But this case also raises a bigger question: Have Canada’s privacy regulators set an impossible standard? In seeking to protect children’s privacy, the Commissioners may have required TikTok to collect more sensitive information — including facial scans or identity documents — from all users. David argues that these well-intentioned recommendations risk making privacy compliance more invasive, not less. Watch (or listen) for a deep dive into how this decision reshapes the balance between privacy, practicality, and policy.
The federal/provincial privacy finding is here: priv.gc.ca/en/opc-actions-and-decisions/investigations/investigations-into-businesses/2025/pipeda-2025-003
Where you can find me
► Privacylawyer blog: blog.privacylawyer.ca
► My law firm: mcinnescooper.com/people/david-fraser
► Twitter: twitter.com/privacylawyer
► LinkedIn: linkedin.com/in/davidtsfraser
Disclaimer: This is intended for education and information only and should not be taken as legal advice. If you need advice for your particular situation, you should seek out qualified counsel.
All views expressed are solely those of the creator and should not be attributed to his firm or any of its clients.
