OTTAWA, February 4, 2022 – The Canadian Association of Research Libraries (CARL) agrees with the underlying premise of this bill – that Canadian citizens deserve a “safe, inclusive, and open online environment”. How to accomplish this and effectively address harmful online content is critically important.
CARL is pleased that the government has reviewed and publicly acknowledged the many areas of concern that were raised in the submissions and is now prepared to re-examine the bill.
The library community sees it as vital that the government take the time to re-study this complicated issue, drawing on the wealth of thoughtful – but divergent – input received to propose a more acceptable, nuanced framework.
Clearly, a balanced regulatory framework is required to address unlawful online behaviour without impinging on fundamental rights such as privacy and freedom of expression.
We are pleased that the government is addressing the concerns raised in our brief regarding the potential for over removal of content (and its implications for freedom of expression), individual privacy rights, and the potential impacts on certain marginalized groups.
The academic library community is gratified to see there will be improved definition as to what an online service or platform is and what would be exempt. Many systems used in academia can be considered online platforms that could be subject to the Act as originally written.
Another positive is the report acknowledges the critical need for transparency and accountability and to ensure safeguards are in place to mitigate the potential for over-removal of content and censorship.
We are likewise happy to see that our concerns related to 24 hour takedown, and the burden of compliance for small entities’ resources to meet those demands, are captured.
The report captures our concerns in regards to a lack of transparency in the regulatory process, mandatory reporting requirements to law enforcement and how onerous administrative elements could create an overburdened, slow-moving system. As noted in our submission, “protecting children and vulnerable and marginalized communities from online harm is a priority, however, the regulation must include clear, transparent protocols that prevent a surveillance state and mis-categorization of individuals”. The regulatory processes, procedures and regulating bodies must be fair, balanced, transparent and move at an effective pace.
Our submission referenced the important role libraries play in fighting misinformation online. We continue to advocate for education and research and reiterate that libraries are ready and willing to contribute to these efforts. We would be happy and willing to engage with the government further and look forward to a revised framework.
For more information on CARL’s Submission please see https://www.carl-abrc.ca/wp-content/uploads/2021/10/CARL-response-to-harmful-content-online-1.
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CARL members include Canada’s twenty-nine largest university libraries as well as two national libraries. Enhancing research and higher education are at the heart of its mission. CARL develops the capacity to support this mission, promotes effective and sustainable scholarly communication, and public policy that enables broad access to scholarly information.
For more information:
Susan Haigh, Executive Director
susan.haigh [at] carl-abrc.ca
613.482.9344 x 101
