Comments on the Privacy guidance on facial recognition for police agencies
In June 2021, federal, provincial and territorial authorities in Canada, including the Commission d’accès à l’information du Québec, issued a notice of consultation and call for comments on a Privacy guidance on facial recognition for police agencies (federal, provincial, regional and municipal) aims to clarify their privacy obligations with respect to their use of facial recognition (FR) technology, with a view to ensuring any use of FR complies with the law, minimizes privacy risks, and respects privacy rights.
As part of this consultation, three OBVIA researchers submitted comments to help improve the document. In particular, they believe that the use of facial recognition by police services needs to be better regulated legally and ethically, beyond compliance with privacy laws, which they believe are insufficient to address the many social issues at stake. They also believe that police services must be trained to deal with issues such as the risks of error, bias, discrimination and mass surveillance. Finally, they underline the fact that the invasion of privacy is most often accompanied by the violation of other fundamental rights. They recommend the elaboration of a reference framework of values aiming to enlighten interventions in the field of public security and to better support the reflection of professionals.
These recommendations were presented jointly by the International Observatory on the Societal Impacts of AI and Digital Technologies (OBVIA) and the Research Chair on Accountable Artificial Intelligence in a Global Context to the Office of the Privacy Commissioner of Canada and the Commission d’accès à l’information du Québec.