TC Privacy Play by Play – OLD updates
The day the Declaration dropped, several airline pilots were in contact with ALPA Pilot Assistance and LEC reps.
Within a couple days a 'Communique' was released by ALPA Canada.
Two separate CAMEs we contacted assured us this kind of unlimited access to members' private medical info has never been the case. They were shocked by its release (they had heard nothing of it) as they have always been highly restricted in what they can access.
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ALPA Rep Verbal Updates:
"ALPA Canada has sent an email regarding the newly required privacy notice that Transport Canada Civil Aviation Medicine has imposed on all pilots renewing their Aviation Medical.
ALPA Canada is reaching out to the regulator with proposals to change the wording of the document to be less overbearing.
In the meantime, to receive a valid medical, pilots are required to sign the document in its current form."
14 Dec
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"There was zero advanced notice from TC-CAM to the industry prior to the release of this document, so it has put us in challenging position to inform our membership about this new policy. Our Alpa Canada staff along with Tim, Gilles and Louie-Eric are working to get answers."
16 Dec
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We have expressed these concerns with TC Aeromedical through our legal team. We have done this through a carefully drafted letter which includes the appropriate language needed on this form and we our anxiously awaiting a reply.
As you would expect this is concerning to all of us and we will continue to press TC on this matter. You will see our communication as soon as we have received their reply.
19 Dec
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Apparently this was sent to CARAC members after release of the form. We’d call it an effort to misrepresent the facts, when you compare the old wording (one short para on your medical examination report) versus this sweeping one page release.
All CARAC Members:
On 09 December 2025, TC re-introduced a Privacy Notice and Declaration form that must be signed by applicants during in-person medical examinations for aviation medical certificates. This fulfills TCs requirements under the Privacy Act to inform applicants of how TC collects and manages their information, the authority of the Minister of Transport to collect information, and the obligations of applicants under the Aeronautics Act. A signed privacy notice and declaration was part of the paper Medical Examination Report (MER) prior to TC’s transition to the electronic Medical Examination Report (eMER) system in 2020. The reintroduction of the signed form replaces the medical examiner attestation in eMER made on behalf of applicants.
Sincerely,
Canadian Aviation Regulation Advisory Council
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Dec 22 - ALPA Legal drafted and sent correspondence to Transport Canada, requesting they remove the worst parts ('third parties', 'including but not limited', along with using your private medical information for things like "audit and evaluation").
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Jan 12: ALPA Legal, through local reps, provided a brief opinion:
ALPA’s representation obligation applies to labour law. It does not extend to licensing arguments with the regulator. They agree that transparency is lacking and ALPA Canada is engaged and advises they are working to get more information.
They cannot provide an answer with respect to what "third parties" refers to, at this time. “Includes, but not limited to” in their view is a statement often used to indicate that in future, appropriate parties that become relevant to the file may be included. This avoids the need for individual notifications.
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Jan 13:
From ALPA AC, Toronto LEC Chair: “This is a far reaching change that stakeholders were not consulted on. We all agree that this is unacceptable.
We cannot advise pilots to not get their medicals what we can do is support directly our members seeking to get answers and make change.
To that end, we will be drafting a formal letter to send to the minister, and other relevant MP’s. I will be drafting this letter personally. First we will ask that it come from all the bases that make up the MEC, however if there is not full support we will send it on behalf of our local members.
One way or another we will get the message over to Transport Canada and parliament. In the coming days as I get this draft together I will reach out to you and some of the other active members, bringing forward these concerns for some feedback and input.”
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