Ep.12 | The Importance of Privacy Rights (Guest: Michael Power)

Show Transcript

[00:00:00] Hello, and welcome to episode 12 of Privacy Lawls, where I, Donata Stroink-Skillrud, talk with amazing privacy professionals, and we have some laughs along the way as well. This podcast is brought to you by Termageddon, an auto-updating Privacy Policy generator. Today, I’ll be speaking with Michael Power about something that I’ve always wanted to have, and honestly, I’m jealous of the people who do have this, and that’s privacy rights.

Privacy rights are the cornerstones of how people keep control of their personal information and protect their privacy. So I’m very excited to talk about this today. My guest today is Michael Power, who is a lawyer and consultant working with public and private sector clients on Canadian corporate and privacy law issues.

Michael has a wealth of expertise in regulatory compliance, privacy, security, data governance, and the use of AI. Prior to his current position, Michael was the Managing Director of Privacy at Valencia IIP [00:01:00] Advisors Limited, the Vice President of Privacy and Security at eHealth Ontario, and the Deputy Director at the Chief Information Officer Branch at the Government of Canada.

Michael, thank you so much for joining me today. You’ve had a really distinguished career in privacy. What sparked your interest in this area of law? Well, first of all, thank you for inviting me to be a guest. I’m very happy to be here. What sparked my interest in privacy? To be honest with you, I’m perhaps telling tales out of school.

I fell into it once upon a time. When I was in with the federal government with the Canadian Department of Justice. I was the coordinator of the Electronic Commerce Secretariat. Now this was back in the mid nineties. So I’m, I’m dating myself a bit. And my, the very grandiose title, but it was really me, myself and I, and I was tasked to address.

Issues related to legal issues related [00:02:00] to the use of information technology to provide government services. So in other words, e government. And as part of that, I was the instructing solicitor on a piece of legislation called the Electronic Documents Act. And then one day the instructing solicitor on the Personal Information Protection Act Heather Black, she and I got called to the House Leader’s office on Parliament Hill and were quickly informed that the Prime Minister had decided that the bills would be merged and they would be merged that night in order to be presented to Parliament the next day.

And I remember you know, Heather and I saying, looking at each other and saying, well, sir, these are two different topics, not a good idea. And the house leader looked at us and he said, you want to take it up with the prime minister? And we said, no, we don’t. Thank you very much. So we left went back, got the drafter.

We shared the same drafter. [00:03:00] And the last thing we had to do was to, and we spent the night basically taking two separate pieces of legislation and merging them. And the last thing we had to do was choose the name. Thank you. So, if you’re wondering why the Canadian federal legislation is called the Personal Information Protection and Electronic Documents Act, it was because it was the middle of the night, we were tired, and we just said, we don’t care what you call it, and the drafters just said, I’ll put an and in.

So, all of a sudden for a guy who was working on information technology e government issues, I was quickly thrust into the privacy world, because I had to know That other piece of legislation that had gotten attached mine and for Heather’s credit it she had to do the same thing. I take a certain amount of pride that with the with the new legislation currently in the House of Commons in Canada[00:04:00] which does a massive update on Canadian federal privacy legislation.

What they did was is that they radically changed. The personal information protection part in terms of structure and in terms of and they didn’t touch the piece of legislation that I helped create, which was the Electronic Documents Act that just simply hiked it off and parked it somewhere. So I, I do take a certain amount of pride in the fact that something I was involved in substantively has continued to survive some 30 odd years later.

Thank you. The, the Privacy Act that obviously has to change with the times. Because of that, I got into the, and because it’s intrinsically related to technology issues, that’s how I wind up in the privacy business. That’s awesome. Yeah. I went into private practice in 2000 went into big law [00:05:00] and started practicing in the privacy emerging technologies area.

And aside from a brief stint in the health sector, I’ve been doing that for the, well, now for almost 25 years. So that must have been a really long night combining those two two pieces of legislation together. Well, we got over the shock of it. Well, I think we were all sort of going, what’s in that other bit that I’m merging into, what do I have to learn about?

And I, I had to do more, certainly more than Heather did. But because the document stuff was really just making equivalencies from paper to electronic document there were some legislative techniques at play there. But no, it was yeah, I, I think it was more the drafter but we had to sit there and answer every question that the drafter had, the legislative drafter had.

So I don’t, I don’t recall it being, being particularly stressful in, in the construction of the document, but we had to be there to [00:06:00] answer the questions and think through the permutations and implications of doing that. Very interesting. So you worked as a lawyer and, and privacy expert in public and private sectors.

Do you have any advice for law students or lawyers who are trying to choose between the two? Oh, they’re very different worlds. I’ve, I’ve had, I divide the world into, in terms of data protection. I divide into three domains. One is obviously the public sector, the private sector, and for us in Canada, certainly, and for you in the United States, the health sector and I’ve worked in all three.

What I would tell a student today is that if you want to work on really interesting work for low pay, go into government, go into the public sector, If you wanna get paid. But the work is less interesting going to the private sector. That’s sort of been my experience. [00:07:00] That’s a really interesting way to put that.

I’ve never heard that before, but it definitely makes sense. Well, in the public sector you’re dealing with you’re dealing with a lot of policy issues. And you, you know, if you don’t like a rule in the public sector, you can change it. I mean, it’s often it’s heard sometimes depending upon the politics of the situation, it may not be doable at that particular moment in time.

But, you know, when you’re in government, you take a longer term view of the world. In my experience, governments do anyway. And so if you don’t like something, you can change it. the law or the regulation and that you, you have to then think through all the, as I mentioned earlier, all the combinations, all the permutations.

You know, if you, if you do X, you know, it’s almost like an algorithm. If you do X, you know, ABC will come out. If you do Y, DEF will [00:08:00] come out. And because of that, you, it’s much more intellectually interesting. It’s much more exciting. It’s much more cutting edge because you’re dealing with policy issues of the day.

When you’re a private sector unless you’re in sort of like a government relations kind of practice, you’re not. I’m speaking more as a solicitor here rather than a barrister or a litigator. You know, you, you find yourself in, in more in a compliance world, more in a dealing with regulations, interpreting them for clients, educating clients.

So it’s, it’s less for me, and I, I have to throw in that big qualifier, certainly for me and the person that I have evolved to be. I find that less interesting. I’m lucky enough that I’m senior enough that what I’ll often get now is I will have cause I have a mix of clients in both public and private sector.

I will have public sector clients come to me and ask me those very [00:09:00] cutting edge kinds of questions. You know, we’re, we’re thinking of X, we’re trying to interpret Y. You know, give us your opinion on this. So I, I get to play in both spaces. So I’ve been fortunate throughout a lot of my career and being able to do stuff like that.

That’s fun. Yeah. Changing legislation is so satisfying. So. I had a very small experience with this, obviously not comparing the two in any sense whatsoever, but I live in Chicago in unincorporated DuPage County and my husband and I got some chickens and one of our neighbors complained and the county came here and said, Hey, turns out it’s illegal to keep chickens here.

You either get rid of these or you’re paying like 500 per chicken per day And to me, that was, you know, I’m not doing that. Like, I’m sorry, I’m not getting rid of my chickens. So I worked with a group called sustained page and we actually got the law changed in our County [00:10:00] to allow for chickens and now like a whole bunch of our neighbors have chickens and it was like one of the most satisfying things I’ve ever done in my life where, you know, it’s something so small, it only affects like a few people here and there.

It’s like. You know, nobody really cares about it as much but it’s really nice to you know See our neighbors have chickens now and everybody just being able to do that and and it being allowed, you know I think so. I think for young lawyers and law students Probably you know, I I should qualify this.

I know people can’t see me, but I am of a certain vintage this year 2024 marks my will be in june my 40th anniversary as a member of the bar as a lawyer. Wow. Congratulations. Thank you. And still going strong And but when I look back 40 years ago You know the world has changed a lot and I think you know for if I had to give advice to[00:11:00] law students or young lawyers I would say, you know Change is the constant You know, once you, once you get out there practicing whatever sector you’re in things change and be prepared for things to change and accept change.

The only constant is change. You know, absolutely. So now that you’re in private practice, what types of clients do you work with and where can clients find you? Oh I have a mix of clients, you know I would say they would be some of them are public sector. Some of them are private sector. I have, as you mentioned earlier, I have two practices.

I have a law practice and a consulting practice. Both are defined because my insurers insist that they be defined as separate and distinct. And they are. And so you know, and clients, depending upon what they want, they will hire me as a lawyer or they will hire me as a consultant. And so, in my own mind, I don’t [00:12:00] distinguish between the types of clients I have.

I distinguish between how I build them and the type of deliverable that I provide to them. So, in terms of my both my practices, I have a mix of what I would characterize as certainly public sector clients these are departments, institutions, if you want to use the, the parlance here in Canada at both the federal and provincial level.

I have private sector clients, they tend to be larger and I, on occasion I have health sector clients because of A, my experience in the health sector, and B, just simply the nature of the kinds of The work that I do. I tend to deal with more emerging technology issues. You know, I’ve, I’ve throughout my career.

I’ve, you know, I’ve, I’ve done big law. I’ve done you know, in house. I’ve done I’ve been the owner of a, you know, a, [00:13:00] a consulting practice, you know, with, with, you know a number of employees. So I’ve had a variety of experiences. Now I’m a sole practitioner with a very, how would I characterize discreet practice, you know, where the people who have tricky technical questions come to me and they’re looking for not only the legal answer, but the solution to whatever problem they have they can reach me.

I have a website. I don’t think I’ve updated my website in years. When I find time, I think that’s one of my, on my list of things to do, but I’m, I’m readily accessible through LinkedIn. I do have a website michaelpower. ca and people can contact me through that, but

that’s how, that’s how I’m rolling these days. So. Well, that’s great. So let’s talk about privacy [00:14:00] rights. You know, living in Canada, you have those and, and I don’t living in Illinois, I only have the right to protect my biometric information, which, you know, doesn’t come up frequently. So why are privacy rights important to people and what do they aim to achieve?

I think you know, one of the things that I would say is that I, I make a distinction between personal information protection, or to use the European term, data protection and privacy. Certainly in Canada, we have both federal and provincial legislation. We have federal legislation, which covers most of the country, including the largest province, Ontario.

I’m in Toronto, so PETA as the law is called now, until it changes. Is the law of the land here but in Quebec British Columbia and Alberta vis a vis the private sector there are provincial [00:15:00] statutes that are characterized as substantially similar in nature. And these statutes provide certain rights to individuals, not a lot, when you compare them to what you have under GDPR in Europe.

But certainly where, if you live in a state without any kind of data protection law, certainly more than what you would receive in Illinois. Yeah. You know, essentially here you know, as I said, the rights are, I don’t want to characterize them as insignificant, but they are limited in the sense you have the right to access your information.

You have the right to correct the information. You have, certainly in Quebec, you have the right to delete your information, or have your information deleted. So you have the right to be forgotten, to use the Ethiopian parlance. And you have, you have a challenge mechanism, in the sense that if you don’t like the, how your personal information is being treated there is an enforcement mechanism.

That you can seek address from. [00:16:00] Under PIPEDA, it’s the Office of the Privacy Commissioner of Canada, the Federal Privacy Commissioner. In and the provinces, Quebec, Alberta, B. C., have provincial, the equivalents of provincial privacy commissioners. So, when you think in one hand about statutes, you, you, I think you have to think in terms of data protection laws.

Thank you. If you think in terms of constitutional law certainly under the Canadian Charter of Rights and Freedoms when you look at certainly Section 7, which concerns life, liberty, and security of the person, there are implicit privacy rights baked in there. And of course, we have Section 8, which is you know, a right against unreasonable search and seizure, where the bulk of the constitutional privacy laws kick in in a primarily in a criminal law context, but can also happen in a regulatory law context.

So I think in the past, you know, privacy rights or data [00:17:00] protection was initially meant to protect individuals from intrusion by the government, right? So the unlawful search and seizure. Wiretapping, all of these types of things. How have you seen this evolve to cover private institutions in the more recent memory?

Well, I think it’s certainly in Canada. I think that there’s a big caveat, you know, we have you know, for public sector legislation both at the federal and provincial levels, we have you know freedom in information and Protection of privacy statutes. At the federal level, we call it the Privacy Act.

And it, it is quite limited and it hasn’t changed since the 1980s. It was enacted roughly about the same time, just before I got called to the bar. And it hasn’t really been changed. There’s been some interpretation of it, but it has not kept pace with the changing world. When you look at the private sector, probably I would say [00:18:00] that you know, the GDPR’s predecessor you know, the Privacy Directive probably had more influence on Canadian legislators and the, in determining the need to ensure international data flows.

So because of the need for you know, sort of equivalency between regimes to facilitate data flows, what you have here is in Canada, there was a drive to enact privacy legislation more to I wanna use this word ’cause it’s not really an appropriate, but it’s the one that comes to mind more to appease the eu.

Mm-Hmm. Than any kind of. Evolution of domestic privacy law from the Public Sector Privacy Act to the private sector legislation. And with the advent of the private sector legislation, what you saw was provincial governments. Then they moved in because of the sensitivity of the [00:19:00] information.

They used that law and the principles and the concepts found in that law and found in the GDPR or the EU Data Protection Directive, I should say. As it then was to craft personal information protection laws vis a vis health information. And all provinces and territories in Canada have personal health information protection legislation.

So it’d be like your HIPAA. So that’s kind of how, that’s kind of how privacy laws, data protection laws in Canada evolved. It wasn’t from a, well, this is what we do in government, so we should do it for the private sector. It was more of a, this is what Europe is doing vis a vis the private sector and a little bit of the public sector.

But because of our own constitutional arrangements, we can’t really dictate to the public sector in the provinces. So we’ll create a private sector law, and then from that, you get into the health protection [00:20:00] laws, health information protection laws. Yeah, it’s really interesting, at least to me, how much copying and pasting happens in the United States when it comes to privacy laws.

So one of the things that I do is I track privacy bills, right? So I have seen instances in which one state proposes a privacy bill, and then another state takes the same exact text, And then proposes it as their privacy bill sometimes forgetting to switch out the name of the state or leaving blanks like this law will apply to you if you collect blank number of of data of a blank number of people where you know, it seems like maybe a little bit more time should have been spent on the drafting at least that’s what I see in the u.

s here. Well, that’s that goes to legislative drafting , that’s a lot of times you, you kind of have to blame the staff in a, in a particular politician’s office for that. Yeah. But you know, fundamentally you do see you, [00:21:00] if they were drafted correctly, you, you know, you would see I think you would nonetheless see a lot of commonality.

And that’s because the fundamental principles behind these laws, whether they’re in the United States or whether they’re in Canada, or whether they’re in Europe. There are a certain degree of universal principles that have evolved and have been translated into legislation. And that’s because when you, the wording might be different, the scope might be different, the application might be a little different, but the substantive rules or requirements, Are often the same they may vary they may be tweaked a little bit But the core idea is there and now we’re talking about do we apply it all do we apply a little bit of it?

Medium bit so you’re you’re fine tuning the application of the legislation, but the core principles are there. Yes Or hopefully they’re there Well, you would think you know, a lot of times privacy is used to [00:22:00] justify You know Doing something that isn’t very private, you know, in some respects, it’s very Orwellian.

Yeah, absolutely. That’s true. So let’s talk about some rights specifically. So the right to access and portability, how does that help individuals? Well, the right, you know, it’s, I would characterize that as you cannot fix something you don’t know about. And so what will happen is that in order to determine whether or not there has been, when you think about the, the, let me back up a little bit and talk about the principles.

So, you know, in terms of limiting collection, limiting use, limiting disclosure, retention, if you have collected information about me and you have certain requirements to meet under legislation, under ARPA PETA, under any kind of privacy statute, in order to determine whether an [00:23:00] organization or an institution is adhering to those requirements, You need some kind of mechanism to audit it.

Yes, there may be an enforcement arm somewhere, but the best audit mechanism is yourself. You know, if people have information about you and you want to ensure that they are processing or using that information correctly, you want to check up on them. And that ability to check up is a right of access.

Portability, that’s a separate concept. It often gets lumped in with access, but essentially that means that if you want to move institutions more, it’s more of a private sector concept, but if you want to move between organizations, you want to use a different bank, but you don’t want to re input all your information.

What you want is that you want an ability to transfer it from one to the other works fine in theory, less so in practice. You know, we’ve not quite had that kind of open [00:24:00] standards that we need in order to have true portability. The one place where you might see that first would probably be the financial sector, certainly here in Canada.

Certainly they’re working on it in Europe, but people talk less about portability and play and give it less attention and focus more on A, the ability to access. And especially in Europe, the ability to delete, you know, in other words, have information Have information removed from the record.

One of the things like a concept that I heard a couple years back about portability that I found really interesting, and this isn’t really in play right now, it doesn’t work like that, but the idea is that. Platforms like Facebook have a lot of control over consumers, because if you think about it, how difficult would it be to change from Facebook to another provider, right?

Like you have all your [00:25:00] pictures, you have all your posts, you have all your friends, you have all your interactions, and then you would lose all of that and have to start from scratch on another platform. And the idea was that portability would allow consumers. to switch from these large platforms easier if we had true portability in the future.

That’s true. But that’s a portability question. And then I would say, how is that a privacy question? How is that, you know, it, you know, it, you’re, you’re now touching upon what I would characterize as, you know, the, the evolution of, of privacy concepts, because now what we’re talking about is information governance.

And the ability to have a greater degree of control over your information that stems from privacy in the sense that when you privacy is a very hard concept to define we’ve gotten away from that trying to do that. We’ve got more into sort of a taxonomy [00:26:00] approach to privacy ideas. And even there, there’s a debate about whether that’s a good thing or not.

But privacy in essence, one concept of privacy. Is that it provides when we have privacy. We have a greater degree of control over our own personal information. So in that sense, you could say, you know, it’s it’s related to the portability issue, because now we’re talking about, hey, they’re my pictures.

And I want to move them somewhere else. So I want control over that information, but we’re talking about a concept of now where it’s. And the idea is that information becomes more about the information than about privacy, even though the concept of radio control originally originated in the privacy space because we didn’t want information about ourselves being displayed publicly, but here we’re talking about in a weird way, and I put it in quote to air quotes here public information because you’re [00:27:00] sharing it with the world.

Yeah, it’s not a privacy concept. It’s more of an information governance concept. And you can see that because. You know, 50 years ago, privacy was about confidentiality. It was about keeping information about yourself out of the public domain. And now what you see is that there’s almost an evolution in that concept in the sense that privacy is now about Use in that.

Well, yes, I may have given you my information. I may have put it out in the public, but I put it out for this reason, and you’re using it for a different reason, and that I didn’t consent to that. Or I didn’t approve of that. So you can see that what originated in the privacy world is now we’re not talking more about information governance.

And taking the concepts from a privacy world into an information governance world. [00:28:00] Which in a lot of ways is very appropriate today when we talk about certainly AI and the, the voracious appetite for data, not necessarily limited to personal information, but the, you know, it becomes related to the concept of I want to control the information about me or related to me.

And that includes whether it’s private information or public information. Yeah, it’s it’s very interesting. I think you can kind of mold these things together as well depending on why somebody’s seeking Portability or a different right? So You know if I just want to switch providers That’s different than I don’t like the fact that Facebook uses my information for marketing.

Or, or something like that, you know, may depend on the individual and what purpose they’re trying to achieve as well. Well, that’s true. And it’s, as I mentioned, it’s now our, our, we’re using privacy concepts as they were originally [00:29:00] developed to apply. We’re trying to, you know, put a, You know, square peg in a round hole because we live in a world full of round holes.

So now you’re seeing the concept of information. What I characterize is data governance, information governance concepts. Are now being populated with privacy notions. So yeah Yeah in the u. s We have a lot of that of trying to adapt laws from the 1980s into the modern world and all these other things And in the u.

s We’re seeing more states, pass laws that allow consumers to opt out of targeted advertising Opt out of sales of their personal information, opt out of profiling. Do you think that this is actually helpful or that an opt in approach would be much more helpful to individuals? I think you know, that’s balancing of needs.

And I know this is going to sound crazy, but certainly the Canadian [00:30:00] federal law, that was, that was, it’s designed to balance the interests of businesses that need information in order to thrive. And the ability of individuals to have some degree of control over their personal information. And I think we’re, we’re struggling with that now.

And I’ll come back to your opt in, opt out question before soon. And what you, what I find is that, you know, in my experience, people do not necessarily mind sharing information with an organization. So whether you have opt in or opt out doesn’t matter. What we object to, what people object to, is that sharing of information between organizations.

I might tell you something and I might bare my soul with you, but I’m doing it with you, and I don’t necessarily want you to turn around and share that information with other people. So, if I was just [00:31:00] sharing with you, I could live with an opt out, because I know that the information is only going to stay with you, and I’m giving it to you willingly.

But if we’re now talking about, you’re going to share it with other people, you’re going to sell it or even share it or whatever. And it’s even, I don’t care if the company’s related, it’s somebody else and it’s for a different purpose. And now I’m starting to be profiled. Then I would say no, I think you should you should ask me for my permission to do that In other words, they shouldn’t be locked in.

Yeah, the u. s is loving the opt out approach right now and I wonder how much of that is caused by by lobbying and things like that, but You know if I go onto a website and my information is being sold and then I have to opt out nine out of ten Individuals probably don’t know where they should have opted out in the first place like where they’ve put their information You And who’s selling it and who they’re selling it to so that it [00:32:00] doesn’t really truly help.

I don’t think. No, I think now you’re talking about the practical application of an opt out mechanism. And most businesses do not get that right. You know, the, and you have to keep in mind also, sometimes that can be that opt out or even opt in can be annoying. Just look at all the cookie. is that you get every time you visit a website you know, you have to essentially agree to, you have to go through the long, some of them, you have to go through a long list of abuses and you have to say, I don’t want, I don’t agree with this.

I, you know, I’m, I’m, I’m opting out. And it’s, it’s pain, it’s just painful. So we have not, you know, we have not had, businesses have not found an easy way to facilitate, to manage consent. And that’s probably one of the challenges that both businesses and individuals face over the next few [00:33:00] years, is trying to figure out, you know, how do I, how do I get to control that?

I agree with you on the lobbying point, partly because that’s how, that’s how business is using, persuading the political sector to avoid opt in requirements, to avoid stronger privacy laws. Because they haven’t quite figured out that where they want to be, you know, is it you know, is it, do we want to stop profiling?

Do we want to stop the sharing of data or do we want to stop the collection of data? And I think we need to figure out what is the practice that we want to what, what is really objectionable to us. And I suspect a lot of it would be the profiling stuff, the profiling aspect of it. Yeah, so how would someone who’s not a privacy lawyer figure out what privacy rights they have?

Well, certainly in the United States, you know that the major primary vehicle [00:34:00] would be the privacy policy Unfortunately, those can be changed on a whim or as circumstances dictate, but you know, there’s if you want to inform yourself, if you want a degree of transparency as to the practices of the organization to whom you are giving your personal information probably the you know, the privacy policy would be a starting point.

In states where there are privacy laws, probably, you know, I would say look at the the departments, the government departments that are in charge of administering those laws, you know privacy laws are almost like consumer protection laws now. Yeah, and and so that would be another source of information to find out what your privacy rights are.

Yeah, it’s hard, you know, a lot of times when reading the privacy policy, They don’t say who gets what rights. So it’ll say, you know, depending on where [00:35:00] you reside you may have The following privacy rights and then the rights don’t say like who they actually apply to I think that can be very confusing to consumers and i’m sure a lot of people have tried to exercise rights only to be Told well, you’re not a resident of california, so you don’t get anything exactly that that comes back to that presentation how to manage consent you know, how do you do that?

You usually see one document that has different sections depending upon where you live, and you have to look at those sections. A lot of these a lot of this documentation is regrettably written by lawyers. That, that can be a good thing and a bad thing. I’d rather have a lawyer write it than a marketer because, you know, you need some precision, But unfortunately, lawyers have to You know, we have a bad habit of wanting to be as precise as possible, which means that we tend to, you know, add a lot of words.

As I’ve gotten, as I’ve discovered in [00:36:00] my, during the course of my long career I edit, I edit things down more, I write less, I try to make it as short as possible, as plain language as possible. That’s a function of, I think, about age and experience. But, you know, a lot of the documentation is, unfortunately, in legalese.

And as I’ve discovered, late in life, you need to balance the legalese with the precision required. Yeah, I think it’s really interesting of how much lawyers love to write so when you’re in High school or college you would get a page minimum So you’d say you need to write a paper that’s at least five pages when you were in law school You had a page maximum So the maximum that your paper can be is 10 pages.

You don’t write like 40 Oh, exactly. Exactly. You know, I I You know, I spent one of the universities here in Toronto, it’s the, it’s York University, and it has [00:37:00] a very distinguished law school Osgoode Hall Law School. And they asked me to teach a privacy course which I did and it was a writing course.

So to keep my life simple, it was always, you know they had to write a paper. And it was a hundred percent of your mark and it was a seminar class where most of the classes I introduced them to I basically, it was, you know, a tutorial on privacy law, privacy concepts, all this sort of stuff, but I reserved one class about how to write paper and I would tell them close your laptops, put your pens down, you don’t need to take notes, you just have to listen to me, you have to listen to what I’m emphasizing, okay?

And I’m going to, I’m going to read something to you after the class, I will give it to you. That’s why you don’t have to take notes. And I will tell you how to write a paper and more importantly, how to write a paper for me, because I am, you know, judge, [00:38:00] jury, and executioner. And the point of it, the whole exercise was to get them over that hurdle of, you know, You know, legalese diarrhea, to get them to write more shorter more punchier papers and you know, I think I think the secret of success is a lawyer is to Is to write well and to write with a lot less words I think so, too.

I think that’s a lesson that a lot of us can can learn from for sure so Michael, thank you so much for taking the time to speak with me today about privacy rights and about your career For everyone listening, please make sure to subscribe to Privacy Lawls so that you do not miss the next episode.

Wow. Thank you for having me.