August 16, 2022

Comments on Canada's Approach to Cyber Security

August 16, 2022

Submitted via

Public Safety Canada

269 Laurier Avenue

West Ottawa ON Canada K1A 0P8

RE: Consulting on Canada's Approach to Cyber Security

The Cybersecurity Coalition (“the Coalition”) submits the following comments in response to the public consultation issued by Public Safety Canada (“the Government”),Consulting on Canada’s Approach to Cyber Security (“the consultation”). The Coalition appreciates the Government’s openness in engaging industry on this important topic and looks forward to working with the Government to further explore the adoption of recommendations outlined in this submission.

The Coalition further commends the Government for its global leadership on cybersecurity issues, including engagement in forums such as the UN Government Group of Experts (“UNGGE”), the UN Open Ended Working Group (“OEWG”) and through its early ratification of the Budapest Convention on Cybercrime (“Budapest Convention”).

The Coalition is composed of leading companies with a specialty in cybersecurity products and services. We are dedicated to finding and advancing consensus policy solutions that promote the development and adoption of cybersecurity technologies. We seek to ensure a robust marketplace that will encourage companies of all sizes to take steps to improve their cybersecurity risk management. We are supportive of efforts to identify and promote the adoption of cybersecurity best practices, information sharing, and voluntary standards throughout the global community.

The Coalition has worked with more than 20 governments around the world on the development of national cybersecurity policies, many of which were designed to address issues that are raised in the paper. Given the complexity of cybersecurity, we are acutely aware of the need to effectively address the challenges that you identify, as well as the difficulty of doing so in an effective manner.

We provide the following responses to the survey questions with a view to advancing our shared objective of safeguarding publicly- and privately-owned infrastructure from malicious cybersecurity activity.

The Coalition thanks the Government for its careful examination of these issues. As the conversation around cybersecurity in Canada continues to evolve, we would welcome the opportunity to further serve as a resource on both technical and policy questions to ensure that these proposals are successful in achieving the Government’s objectives.

Respectfully Submitted,

The Cybersecurity Coalition

August 16, 2022

CC: Ari Schwartz, Venable LLP

Alexander Botting, Venable LLP