The Office of the Privacy Commissioner of Canada (the “OPC”) has recently launched a consultation on transborder data flows under the Personal Information Protection and Electronic Documents Act (“PIPEDA”).   PIPEDA is a federal law of Canada that regulates how individuals’ personal information should be collected, used, and disclosed in commercial transactions. It is restricted to provincial, interprovincial, and international commercial transactions and therefore does not apply to government activities, collection of information for journalistic, literary or artistic services, not-for-profit enterprises and charity groups, among others. Due to growing concerns regarding transfers of personal information beyond Canada’s borders, the OPC revisited its previous position and determined that the cross-border transfer of personal information to third parties for processing (a “Transfer”) may now be considered “disclosure”.