Remarks by Brad Callaghan, Associate Deputy Commissioner of the Policy, Planning and Advocacy Directorate
April 22, 2026
Ottawa, Ontario
Good afternoon Madam Chair and Honourable Senators,
Thank you for the invitation to appear before you today.
My name is Brad Callaghan and I'm the Associate Deputy Commissioner of the Competition Bureau's Policy, Planning and Advocacy Directorate.
The Bureau is an independent law enforcement agency that protects and promotes competition for the benefit of Canadian consumers and businesses. We administer and enforce Canada's Competition Act, a law of general application that applies to every sector of the economy.
The Competition Bureau has long been active in promoting the importance of data portability to competition. We know that more competition pushes companies to innovate, invest, and deliver the best solutions to customers. Data portability makes switching easier, ensuring that companies have to compete for customers on the merits of its products.
Our most recent study on data portability suggests that the ability to easily and securely transfer data has a huge potential for our economy, saving consumers both time and money.
But getting the data out from one provider is only one part of more competitive digital markets. For switching to be meaningful, digital systems need to be able to interact with one another. This is known as interoperability - an idea that is central to this committee's study.
In Part One of the Bureau's Digital Health Care Market Study, released in 2022, we looked at how to unlock the power of personal health information - so that Canada's digital health care sector can fully benefit from competition. We found that the majority of health care providers in Canada used a primary health care electronic medical record (EMR) system owned by one of three companies. Accessing and sharing information within those systems could be difficult, meaning much of Canadians' personal health information was locked within the system of very few companies.
We made three recommendations to Canada's policymakers to improve competition:
- First: Harmonize privacy and data governance rules across Canada;
- Second: Require primary health care EMR companies to comply with anti-blocking rules; and
- Third: Establish interoperability standards for primary health care EMR systems.
Our recommendations are an effort to not only ensure that health care providers can easily switch between the companies, but also to incentivize entry from other players in order to increase competition. I'd be happy to discuss these recommendations in more detail during our Q&A session.
In closing, the Bureau is encouraged by the initiative proposed in Bill S-5 to put these ideas into practice. We see them as a positive step toward implementing our recommendations on interoperability and compliance with anti-blocking rules.
Before answering your questions, I would note that the law requires that the Bureau conduct its investigations in private and protect the confidentiality of the information we obtain. This obligation could prevent us from discussing some of our current or previous investigations.
