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Exam Code: IAPP CIPP/C
Exam Name: IAPP Certified Information Privacy Professional/Canada (CIPP/C)
Exam Format: Multiple choice questions (MCQs)
Number of Questions: 90 questions
Time Allotted: 2.5 hours (150 minutes)
Passing Score: The IAPP uses a scaled scoring system, but the raw passing mark is generally considered to be around 75% (i.e., approximately 68 correct answers out of 90). The passing score is 300 on a scale of 100-500.

I. Introduction to Canadian Privacy Environment 20%

- Structure of Canadian law (constitutional foundation, federalism, Charter of Rights and Freedoms, common law vs. civil law in Quebec)
- Canadian legal system and sources of privacy law
- Key privacy concepts (personal information, consent, accountability, openness, etc.)
- Evolution of privacy law in Canada
- Role of privacy commissioners (federal OPC and provincial commissioners)
- Enforcement models (ombudsman vs. order-making powers)

II. Federal Private-Sector Privacy Law: PIPEDA and Substantially Similar Provincial Laws 35–40%

- Application and Scope

- Public vs. private sector
- Commercial activities
- Employee personal information in federally regulated organizations
- Substantially similar provincial laws (BC PIPA, Alberta PIPA, Quebec Private Sector Act)
- Health information laws (when they override PIPEDA (BC, Alberta, Ontario, New Brunswick, Newfoundland & Labrador, etc.)

- The 10 Fair Information Principles (Schedule 1 of PIPEDA)

- Accountability
- Identifying purposes
- Consent (including implied/expressed, opt-in/opt-out, withdrawal)
- Limiting collection
- Limiting use, disclosure, and retention
- Accuracy
- Safeguards
- Openness
- Individual access
- Challenging compliance

- Key compliance obligations

- Privacy policies and notices
- Privacy management programs
- Appointment of a privacy officer
- Breach notification requirements (mandatory since Nov 2018)
- Cross-border data flows and transfers (Accountability principle, APEC CBPR, EU adequacy decisions, etc.)
- Childrens privacy and CASL interaction

- Oversight and enforcement

- OPC investigations and findings
- Commissioner-initiated complaints
- Federal Court hearings and remedies
- New powers under proposed Bill C-27 / CPPA (if enacted by exam date)

III. Provincial Laws 25–30%

- Public Sector Privacy Laws

- Federal: Privacy Act
- Provincial: FIPPA/MFIPPA (Ontario), FOIP (Alberta), ATIPPA (Newfoundland), etc.
- Municipal: MFIPPA (Ontario)

- Provincial Private-Sector Privacy Laws

- Quebec Law 25 (formerly Law 25 – Act to modernize legislative provisions respecting the protection of personal information)
- British Columbia PIPA
- Alberta PIPA
- Differences from PIPEDA (consent, breach notification, private right of action in Quebec, etc.)

- Provincial Health Information Acts (very high yield)

- Ontario PHIPA (Personal Health Information Protection Act)
- British Columbia Personal Information Protection Act (health provisions)
- Alberta HIA
- New Brunswick PHIPAA
- Role of health information custodians, agents, circle of care, express consent requirements

IV. Emerging Developments and Specialized subjects 15–20%

- Anti-spam legislation (CASL) – interaction with privacy
- Artificial intelligence, automated decision-making (Directive A-1, Bill C-27/CPPA proposed rules)
- De-identification, anonymization, and pseudonymization standards
- Privacy by Design (PbD) and privacy impact assessments (PIAs/TIAs)
- Online behavioral advertising (OPC guidelines)
- Workplace privacy (video surveillance, biometric data, monitoring, drug testing)
- Transborder data flows and international transfers
- Children and minors privacy (Quebec, OPC guidelines)
- Political party and election privacy (provincial election laws)
- Proposed Consumer Privacy Protection Act (CPPA) / Bill C-27 / Digital Charter Implementation Act (if passed by exam date – know the major proposed changes)

- High-Yield subjects (appear very frequently)

- Differences between PIPEDA and provincial health laws (especially Ontario PHIPA)
- Breach reporting requirements (federal vs. Alberta vs. Quebec)
- Consent exceptions (Schedule 1, clause 4.3)
- Substantially similar designation process
- Health Information Custodian vs. agent under PHIPA
- Quebec Law 25 requirements (DPO appointment, privacy impact assessments, default privacy settings)
- Cross-border transfers and accountability