Sometimes new law requires very broad compliance. It might be easy to dismiss an act like the one proclaimed in force on December 8, 2011 titled “An Act respecting the mandatory reporting of Internet child pornography by persons who provide an Internet service” as applying to Internet Service Providers only, but it might apply to you as well.
Today’s Tip is about identifying who in your organization to inform about a newly proclaimed law.
Order fixing December 8, 2011 as the day on which an ACT RESPECTING THE MANDATORY REPORTING OF INTERNET CHILD PORNOGRAPHY BY PERSONS WHO PROVIDE AN INTERNET SERVICE, chapter 4 of the Statutes of Canada 2011, COMES INTO FORCE.
To identfy who to alert, first read the act (or the Summary page). In this case, go to the Annual Statutes page at the Justice Canada Laws site and link to the act by chapter number.
Review the duties the act prescribes. This act contains broad duties to preserve data, notify police, and notify the Canadian Centre for Child Protection, to name a few.
See to whom the duties apply to by reviewing the definitions. This act very broadly defines providing Internet Service VERY broadly and this could affect clients like public libraries, academic institutions, coffee shops, municipalities, airport authorities – anyone who provides unlocked wifi. The duties apply to any person, and person means an individual, a corporation, a partnership or an unincorporated association or organization.
Look at the regulations if published. Note that regulations under this act “Internet Child Pornography Reporting Regulations” will be published in the December 21, 2011 Canada Gazette Part II.
These steps should help you decide who to inform within your organization.