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On December 9, Transport Canada quietly introduced a new mandatory privacy notice and declaration tied to pilot medical examinations, then made it effective the very next day.

With no advance warning or stakeholder consultation, roughly 60,000 licensed pilots across Canada were suddenly required to consent to the collection and review of their most sensitive personal health data or risk losing their medical certification; with it, their ability to fly.

One commercial pilot says the scope and coercive nature of the policy raise serious privacy and civil liberty concerns that extend far beyond aviation.

“There was no lead time. There didn’t appear to be any stakeholder consultation,” he said. “Our union was very surprised by it. Even Transport Canada doctors were surprised—they didn’t know it was coming.”

Unlike the previous declaration, described as a short, focused paragraph, the new notice authorizes access to an expansive range of medical information. This includes laboratory results, pharmacy records, and entire medical record systems, without clear limits on timeframe or scope.

“It says ‘including but not limited to’ and then proceeds to list everything I can personally think of when it comes to medical health,” the pilot explained. “There’s no start date. There’s no end date. And it authorizes Transport Canada to collect information from third parties, which also aren’t defined.”

The implications are largely unprecedented. It means that theoretically, anyone, past or future, could access a pilot’s entire medical history. Since health data cannot be reset like a credit card, its value on the black market is staggering.

The partially anonymous pilot stresses that his objections are not about evading medical scrutiny. “We care deeply about fitness to fly and public safety,” he reiterated. “This isn’t about getting out of proper screening. It’s about proportionality, oversight, and consent.”

What has further fueled distrust is the timing and method of rollout. It was done during the Christmas season, when there is limited staffing at both Transport Canada and pilot unions, and was buried in dense, fine-print government documentation.

“If you don’t sign it, your medical is discontinued,” the pilot said. “You don’t get stamped. You don’t fly, anywhere in Canada. That’s coercive pressure when your livelihood is on the line.”

Transport Canada has since circulated a revised privacy notice, narrowing third-party access and softening language around suspensions. However, pilots organizing through PilotsCanada77.com argue the revisions still leave the door open to unacceptable data overreach.

Federal MP Dan Albas has formally called for the policy to be suspended pending a full privacy review, citing both the lack of consultation and the magnitude of the data being demanded.

For the pilot who spoke out, the issue extends beyond aviation.

“If this were another industry, I’d still be concerned,” he said. “We need to think about the trajectory. If this is a test case for broader biometric or medical surveillance, Canadians should be paying attention.”