Yes, you're quite right.
Thank you for mentioning Quebec's Commission d'accès à l'information. We do indeed work very closely with them. Quebec's Bill 25 contains specific provisions regarding the use of biometrics. Quebec therefore has unique obligations in this area.
As far as we are concerned, I'd say that it's important to ensure this balance, particularly with regard to facial recognition. We've already made joint statements on this issue at the federal-provincial level. We're not entirely opposed to the use of this technology. We're not saying it should never be used. However, its use should be regulated and strictly adhered to. These principles of necessity, proportionality and transparency should apply. If it is appropriate to use it, are people aware? Is it sufficiently clear that this technology is being used?
Several years ago, my office issued a decision on this matter concerning Cadillac Fairview. The concern raised was that customers didn't know they were being filmed or were unaware of it.
All aspects and principles relating to privacy must be examined, such as data minimization, transparency and retention. In other words, what is done with this information? Is it stored in databases for a very long time? If so, this increases the risk of privacy violations. I think it's important to have this dialogue.
I would encourage companies to continue raising these issues. If companies facing this problem feel they don't have the necessary tools, they should raise it with the commissioners, including my office. Not only can they do so by filing a complaint, they can also use our advisory services. We want to hear their concerns. Then we can make better recommendations.