I think the concerns that we have in these privacy principles.... That is one of the other things we're putting in the written record of this proceeding, because there's only so much time today. We will have more on it.
I think the biggest concern for us around voluntary versus mandatory is that, if it's mandatory, this is no longer consensual. The privacy protections that we have in place through PIPEDA and the Privacy Act are insufficient to actually protect Canadians' data. It's really rare that the voluntary piece needs to come in. I think there are huge concerns, taking a step back from the privacy principles that we've put forward, around the effectiveness of these apps, even where they are adopted.
I take your point around the efficacy concerns for adoption rates, but I think the testing that needs to happen needs to come first. The contact tracing needs to come second. This app is really a supplemental piece and a tiny fraction of the puzzle. I think one of the concerns that we have, or one of the things we've been hearing around the voluntary adoption, if the government is to go this way.... All of those privacy principles that we have put forward are done with the intention of making sure there is trust, because if there is no trust in this service, people will not use it, even if it's mandatory. People will leave their phones at home. They will not take them with them.
I think it also puts a huge disadvantage to those who, as we were talking about earlier, are on the other side of the digital divide, who don't have a phone. If this is now something that is being used to give people the permission to leave their houses or ride public transit and you don't have a device, you're now effectively being penalized and left behind even more.