Algorithmic policing technologies, including facial recognition, have arrived or are coming to Canadian cities and provinces, and they are doing so quickly. We have identified a number of significant policy, practice, and legal deficits related to the use of algorithmic policing technologies in Canada, including imminent or foreseeable impacts to human rights and fundamental freedoms including the rights to privacy, liberty, and equality, expressive and associational freedoms, and others.

Citizen Lab researchers reviewed the consultation materials, including the “Technical Paper” and the “Discussion Guide” associated with the government’s proposal to address what it has referred to as “online harms.” We provide the following comments in response to that consultation process.

Given our experiences, we have specific recommendations for how any federal commercial privacy legislation must be amended to better protect individuals from the predations and power of private organizations. In making our recommendations we have chosen to focus almost exclusively on the Openness and Transparency, Access to and Amendment of Personal Information, and Whistleblower sections of Bill C-11.

In order to contribute to the IPC’s deliberations in the triaging of its strategic priorities, this submission serves to provide particularized input with respect to the IPC’s public interest mandate in the oversight of law enforcement authorities when it comes to the use of algorithmic policing technology in Ontario.