Summary#
Bill 74, the Christopher’s Law (Sex Offender Registry) Amendment Act (Information Disclosure), 2025, would amend Ontario’s Christopher’s Law (Sex Offender Registry), 2000. Its stated goal is to allow registry information to be disclosed to prescribed entities for crime prevention or law enforcement; this is a permitted use, not a requirement to disclose information.
- Ministry employees or people authorized by the Ministry may disclose registry information to entities prescribed by regulation.
- Before such a disclosure, the Ministry must enter into an agreement with the entity about the disclosure.
- A prescribed entity may collect, retain and use the information for crime prevention or law enforcement purposes.
- The bill also sets out disclosure to police services and entities that provide policing under other jurisdictions, and allows those entities to collect, retain and use the information for those purposes.
- The bill does not create a new registry or require information to be disclosed to every prescribed entity.
The main Act is not included in the supplied material, so I could not verify these changes against the law currently in force.
What it means for you#
- People whose information is in the registry: Their information could be disclosed to a prescribed entity, but disclosure is not automatic. It must be for crime prevention or law enforcement, and the Ministry must first make an agreement with that entity.
- Prescribed entities: If named in regulations, they may collect, retain and use disclosed information for those purposes. The bill does not require them to request or receive information.
- Police and Ministry staff: The bill allows police service members and Ministry employees or authorized people to disclose information to police services and entities that provide policing under other jurisdictions. For prescribed entities, disclosure is allowed by Ministry employees or authorized people.
- The public: The bill does not change who must register, the information registrants must provide, or create a new public-access process, based on the supplied text.
Money#
No cost estimate or budget information is included in the supplied material.
- The Ministry must make an agreement before disclosing information to a prescribed entity. The bill does not estimate the administrative or staffing cost.
- The bill does not set a fee, fine, or payment.
What is unclear#
- Which entities would be prescribed, and when the regulations would name them.
- What the agreements must cover. The bill allows regulations to govern agreements, but does not itself set detailed terms.
- What safeguards the agreements must provide for storing, retaining, securing or later sharing the information.
- What “crime prevention” and “law enforcement” mean for this disclosure power; the bill does not define those terms.
- How the new disclosure rules interact with the rest of the existing Act. The parent Act was not supplied, so its current rules and protections could not be checked.
- The bill has staged commencement: replacing the existing disclosure subsection would take effect on Royal Assent; the other changes would start on a date set by the Lieutenant Governor in Council.
Case for#
- The bill appears intended to let information reach additional entities when it may be useful for crime prevention or law enforcement.
- A possible argument for the bill is that the Ministry can share information with an entity only after it has made an agreement with that entity.
- The bill limits the permitted collection, retention and use to crime prevention or law enforcement purposes.
Case against#
- One concern is that the bill allows information to go to entities beyond police, while leaving it to regulations to decide which entities qualify.
- The bill does not itself spell out the safeguards or agreement terms for handling sensitive registry information.
- It is unclear how the permitted purposes would be interpreted or monitored, and what would happen if an entity used or retained information outside those purposes.