Toronto, ON — The Right2YourFace Coalition, a group made up of prominent civil society groups and scholars dedicated to calling for legislation to regulate the use of facial recognition technology, says new proposed government legislation for privacy and AI falls short and will be dangerous for Canadians.
Among its many failings, Bill C-27—which contains the Consumer Privacy Protection Act (CPPA) and the Artificial Intelligence and Data Act (AIDA)—does not have clear definitions and contains too many exemptions that can leave facial recognition unregulated.
“Facial recognition technology is a powerful and invasive tool that is being used by actors across the public and private sectors, from law enforcement to shopping malls—and there’s little in the way of guardrails to protect us from it,” said Daniel Konikoff.
In a new letter to the Minister of Public Safety and Minister of Innovation, Science and Industry and other affected parties, the coalition points out:
- Biometric information should explicitly be considered sensitive information under the CPPA
- An exemption for “legitimate business purposes” is so broad that consumers will not be protected
- “High impact systems” is undefined
- The government is not proposing to apply AIDA to government institutions including law enforcement and national security agencies
- AIDA is too narrow in scope in how it calculates harm to the point of being ineffective
Though ISED has produced some potential amendments to C-27, many lack concrete legislative language. Consequently, the Right2YourFace coalition must continue to insist on our points.
“The government’s ‘good intentions’ are nowhere to be seen in the actual bill. We need real action to protect Canadians from unregulated and widespread technology that has been a disaster when it comes to racial profiling and other harms,” concluded York University’s Prof. Evan Light.
“The way to pressure test a new law is to see if it will do a better job at protecting people across Canada than the old one. Exceptions in the Consumer Privacy Protection Act and public sector exclusions in the Artificial Intelligence and Data Act mean Bill C-27 fails that test, at a time when invasive facial recognition techology is gaining ground in private and public sector applications alike,” stated Brenda McPhail, member of the Right2YourFace Steering Committee.
-30-
Read the letter HERE.
Links to today’s press conference: HERE (Passcode: Hu3.YxZ^) and https://www.cpac.ca/episode?id=3b549dae-ab27-4f9a-810d-16d1e7b3d036
About the Canadian Civil Liberties Association
The CCLA is an independent, non-profit organization with supporters from across the country. Founded in 1964, the CCLA is a national human rights organization committed to defending the rights, dignity, safety, and freedoms of all people in Canada. For more, visit ccla.org.
About the Right2YourFace Coalition
The mandate of the Right2YourFace Coalition is to create a forum for mutual issue sharing and education regarding the ways that facial recognition technology (FRT) may impact our organizations and broader communities. The Right2YourFace Coalition seeks to ensure that there is a wide range of voices—speaking from a variety of perspectives—available to provide expert advice and guidance to policy makers grappling with this complex and dangerous technology. For more, visit https://right2yourface.ca/about-us/.
Media Contact:
Alex Nanoff
media@ccla.org
613.709.6318
About the Canadian Civil Liberties Association
The CCLA is an independent, non-profit organization with supporters from across the country. Founded in 1964, the CCLA is a national human rights organization committed to defending the rights, dignity, safety, and freedoms of all people in Canada.
For the Media
For further comments, please contact us at media@ccla.org.
English (Canada) 
Français du Canada