The passage of Canada’s Digital Charter Implementation Act, better known as Bill C-27, in November 2022 has stirred fresh debate among logistics professionals, legal experts, and policymakers alike. Its implications for supply-chain data privacy are only beginning to be fully digested. At its core, the legislation aims to modernize privacy law, introducing stricter standards for personal data protection and more explicit rules around cross-border data transfers. For firms operating across international boundaries—especially those involved in supply-chain traceability and logistics—this has added an extra layer of complexity to an already intricate compliance landscape. And the truth is, not everyone’s ready.
One of the immediate questions many logistics providers face is how to reconcile the growing demand for supply-chain transparency with the Act’s tightened controls on data usage and sharing. It’s a tension that can’t be easily dismissed. On one hand, supply-chain actors are under pressure—from regulators, customers, even shareholders—to map and disclose their sourcing and routing practices in unprecedented detail. On the other hand, Bill C-27 introduces fresh obligations to protect personal data, creating potential friction points where these goals intersect.
Cross-border data transfers are where much of this friction materializes. Under the Act, organizations need to ensure that data sent outside Canada is afforded equivalent protection to what it would receive domestically. That sounds straightforward, but in practice it requires careful vetting of third-country data processors and transport partners. What complicates matters further is that supply-chain traceability often relies on real-time or near-real-time data feeds that include geolocation information, driver IDs, and sometimes other identifiers that could, under the law’s broad definitions, count as personal information. The line between operational data and personal data can be blurry, and logistics teams are, frankly, still working through where that line falls.
One emerging solution—and it’s far from perfect—is to lean more heavily on anonymized or aggregated data sources. GTFS, or General Transit Feed Specification, records, which are increasingly made available as open data by transit agencies, offer a useful example. While originally designed for public transit, GTFS datasets are being repurposed by some logistics firms to aid in route optimization without needing to process individual driver or vehicle data directly. The appeal is obvious: GTFS feeds provide rich spatial and temporal information about network flows, without tying that data to specific individuals or companies in ways that would trigger privacy concerns. However, the suitability of GTFS data varies depending on the complexity and geographic scope of a firm’s operations. What works for urban delivery routes may be of little value for long-haul or cross-border freight.
Logistics operators looking to future-proof their practices under Bill C-27 would be wise to review how their third-party transport management systems, or TMS platforms, handle personal and operational data. Too often, data governance is treated as a back-end issue—something for the IT department to sort out—but the new compliance environment demands a more proactive approach. Ensuring that TMS providers can demonstrate not just technical capability, but also adherence to privacy-by-design principles, is fast becoming a baseline expectation. Some firms have begun formal privacy impact assessments of their TMS and related software, a process that, while resource-intensive, helps identify weak spots before they become regulatory liabilities. The steps themselves aren’t novel—mapping data flows, classifying data types, reviewing security controls—but the urgency with which they now need to be undertaken is different.
Of course, not all actors are moving at the same speed. Some larger logistics players were already well along the path to stronger data governance, either because of parallel obligations under the GDPR or because of internal risk management policies. Smaller operators, or those with predominantly domestic operations, may have further to go. And, perhaps inevitably, there is still some uncertainty as to how certain provisions of Bill C-27 will be interpreted or enforced. Legal clarity often lags behind operational need, leaving firms to make judgment calls in the meantime.
There is a sense among some in the sector that the conversation around supply-chain data privacy is only just beginning. Bill C-27 has set a new marker, but as digital traceability tools grow more sophisticated, and as customer expectations evolve, the demands on logistics data management are unlikely to stop here. The balancing act—between transparency and privacy, efficiency and compliance—will, it seems, only get more delicate.