On May 24, 2026, the ICLMG submitted our brief opposing state surveillance Bill C-22 to the SECU committee studying the bill. You won’t see the usual accompanying video of our testimony at committee because we are amongst a large group of organizations that defend human rights and civil liberties whose requests to appear at committee have been ignored. On top of that, this is yet another case of a very problematic bill being rushed through Parliament, as only 3 meetings have been dedicated to studying this bill at committee after a rushed 2nd reading debate in the House.
Please see the introduction to our brief below and click the button to take action. Thank you!
Over the past two decades, the ICLMG has observed with alarm the rapid expansion of government surveillance tools and networks, often with inadequate safeguards, and concurrent erosion of privacy protections. This includes the collection and retention of traveler data such as Advance Passenger Information / Passenger Name Record Data, granting the Canadian Security Establishment expansive surveillance powers, the use by law enforcement (from local police to the RCMP) of invasive tools like IMSI catchers and facial recognition tools (such as ClearviewAI), millions poured into new surveillance drones and towers to monitor Canada’s borders, enabling CSIS to collect entire datasets of non-threat related information, and more. Recent reporting has further revealed the long history of law enforcement and intelligence agencies have surveilled Indigenous and environmental movements without justification.[1]
Our coalition has contributed consistently to these conversations, through op-eds, briefs, consultation submissions and committee appearances.[2]
Time after time, federal governments of all stripes have attempted to weaken privacy protections under the name of ‘lawful access,’ which others have aptly called “zombie legislation” that keeps returning from the grave. This includes the ill-fated Bill C-30, proposals in the 2016 National Security Green Paper consultation, the 2023 Consultation on the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), and ultimately, Bill C-2, the now-shelved Strong Borders Act. Each time, governments have sought to significantly erode privacy protections under the guise of providing police and CSIS with powers to fight illicit activity – whether it be terrorism, money laundering/terrorist financing or online exploitation. However, each time it has become clear that people across Canada refuse to trade the important protections that privacy laws afford, in exchange for promises of “security” built on nebulous justifications that these powers are necessary for law enforcement. There has also been a pattern, including regarding Bill C-22, that while police and law enforcement argue new investigatory powers are necessary to address novel challenges, evidence demonstrates that tools and powers already exist that would allow them to adequately address these problems. As the Citizen Lab has described it, while law enforcement may present these issues as a blockage, in reality they are experiencing investigatory friction: difficulties exist, but investigations can still be carried out effectively.[3]
Even in its recent report on lawful access—which is relatively supportive of new lawful access laws—the National Security and Intelligence Committee of Parliamentarians found that law enforcement and intelligence agencies lack evidence to demonstrate the need for such new powers and have been largely effective without the tools they claim are so urgently needed.[4]
Position on Bill C-22
Our coalition is deeply concerned that, if enacted, Bill C-22 will supercharge state surveillance and seriously threaten privacy rights, with concurrent impacts on free expression, freedom of association, and equality rights. Such an expansion of state surveillance also undermines Canada’s adherence to international human rights and civil liberties obligations, including article 2 (equality), article 12 (privacy), article 19 (expression) and article 20 (association) of the Universal Declaration of Human Rights,[5] and article 2.1 (equality), article 17 (privacy), article 19 (expression) and article 22 (association) of the International Covenant on Civil and Political Rights.[6]
This legislation presents one of the greatest threats to privacy in Canada of the past two decades. Its provisions will weaken the rules governing police access to personal information, all while facilitating a vast expansion of government surveillance. As detailed above, this is another clear case of the decades-long trend of governments using national security as an excuse to erode civil liberties and human rights.
Bill C-22 is more limited in scope than its predecessor, Bill C-2, focusing solely on lawful access, and includes some modifications that attempt to respond to previous criticisms. However, not only do these changes not go far enough, but the government has added a new data retention provision to Bill C-22 that raises significant additional privacy concerns.
Furthermore, as detailed by Professor Michael Geist in a recent article, the government has once again failed to present convincing evidence or scenarios to justify the legislative reforms they are seeking in this legislation.[7]
Based on these concerns, our coalition is calling on Members of Parliament to reject Bill C-22 and to vote against it. Should Bill C-22 proceed through Parliament, at a minimum, significant amendments must be made to Part 1, and Part 2 must be withdrawn.
To read our full brief and all details of the issues with C-22, click here.
Footnotes
[1] Fenlon, Brodie. “How the RCMP spied on Indigenous organizations — and how we broke the story,” CBC News, 24 March 2026. Online: https://www.cbc.ca/news/editorsblog/cbc-news-indigenous-rcmp-surveillance-9.7133525
[2] See, for example: https://iclmg.ca/atf-consultation/, https://iclmg.ca/opc-biometrics-consultation/, https://iclmg.ca/mr-paulson-we-have-enough-power-to-fight-cybercrime/, https://iclmg.ca/wp-content/uploads/2016/12/Nat-Sec-Consultation-ICLMGs-Answers-EN.pdf, https://iclmg.ca/issues/bill-c-59-the-national-security-act-of-2017/bill-c-59s-mass-surveillance-and-cyber-powers/
[3] Parsons, Christopher. “Canada’s New and Irresponsible Encryption Policy,” The Citizen Lab, 21 August 2019. Online: https://citizenlab.ca/research/canadas-new-and-irresponsible-encryption-policy-how-the-government-of-canadas-new-policy-threatens-charter-rights-cybersecurity-economic-growth-and-foreign-policy/
[4] National Security and Intelligence Committee of Parliamentarians. “Special Report on the Lawful Access to Communications by Security and Intelligence Organizations,” His Majesty the King in Right of Canada, 2025. Online: https://nsicop-cpsnr.ca/reports/rp-2025-09-15-sr/250915_NSICOP_Lawful_access_report.pdf
[5] United Nations. Universal Declaration of Human Rights. 10 Dec. 1948, United Nations UDHR. Online: https://www.un.org/en/about-us/universal-declaration-of-human-rights
[6] United Nations (General Assembly). “International Covenant on Civil and Political Rights.” Treaty Series, vol. 999, Dec. 1966, p. 171. Online: https://www.ohchr.org/en/instruments-mechanisms/instruments/international-covenant-civil-and-political-rights
[7] Geist, Michael. “The Government Tries to Make the Case for Bill C-22: Why Its Own Use Cases Reveal Disproportionate Overreach,” michaelgeist.ca, 21 May 2026. Online: https://www.michaelgeist.ca/2026/05/the-government-tries-to-make-the-case-for-bill-c-22-why-its-own-use-cases-reveal-disproportionate-overreach/ [Geist 2026]
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