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This privacy impact assessment (PIA) is intended to assess privacy risks within the Canada Border Services Agency's (CBSA) planned demonstration of facial recognition (FR) technology, currently beginning in early 2016. This project is divided into two phases. The demonstration phase will last for six months and will use facial recognition technology to match travellers against a database of previously deported persons (hereinafter referred as the "Previous Deportation Database" or PDD). This will be followed by a three- to six-month lab evaluation phase where the technology's performance will be assessed. The CBSA has no definitive plans to deploy this technology for full-time operational use. The solution described in the PIA is a demonstration to test the efficacy of FR software in an operational border context. The success or failure of the project will assist CBSA senior management in making further testing decisions regarding FR technology use within the border context. The CBSA recognizes that any future testing or use of FR technology will require an additional PIA.
This PIA has been drafted using the CBSA Policy on the Overt Use of Audio-Video Monitoring and Recording Technology (AV Policy) and the Policy on the Use of Wireless Technology, as well as the associated Directives, the Privacy Act and the Privacy Regulations, and the Immigration and Refugee Protection Act (IRPA) as references. This PIA addresses only the Faces on the Move (FOTM) project, which is completely separate from the CBSA's existing use of Overt Audio/Video surveillance. The AV Policy was implemented on August 15, 2011, revised in November 2012, and updated again in July 2013. The most current version of the policy is dated November 2013. No audio will be collected or used in this project.
The CBSA has identified thousands of international travellers who have been denied entry to Canada or who have been deported after being admitted into Canada. These travellers have been deemed inadmissible for reasons such as national security, criminality, health grounds, misrepresentation, and non-compliance with the IRPA. Many of these inadmissible travellers try repeatedly to re-enter Canada. The CBSA uses a list containing the names of previously deported persons and other, similar lists to identify inadmissible travellers at ports of entry (POEs). Often these inadmissible travellers seek re-entry into Canada using false identity documents, or seek entry after obtaining new legal travel documents following a legal name change done in their home country. Name-based lists, such as those currently in use, have inherent limitations for reasons such as fraudulent identity documents and name changes. Some of these limitations can be overcome using biometric technologies.
Although FR technology is widely available for a variety of applications, the use of FR with live video has not yet been tested in an operational environment by a Canadian law enforcement body. The CBSA is planning to conduct this demonstration to assess whether this technology solution is effective, feasible, accurate and reliable for identifying inadmissible travellers in a busy POE environment.
The CBSA plans to deploy multiple project-specific cameras in the CBSA-controlled area of a POE. The cameras for this project will not be connected to the existing camera network that supports video surveillance at this POE. Also, the project cameras are connected to the project's FR server and associated applications, but not to existing CBSA information systems.
Areas and activities that may be monitored or recorded include, but are not limited to: approach to Primary Inspection Line (PIL) booths, PIL interviews, travellers traversing the CBSA-controlled area, etc. This technology will not be used in Customs Controlled Areas outside the CBSA's traditional processes.
These cameras will record and store images of travellers' faces. No audio will be collected or used in the FOTM project. A dedicated FR system will compare these "live-capture" images with a database containing images of persons who have previously been deported or removed from Canada. The system will notify CBSA officers when a match is detected. Following a human review of the match, an officer will be dispatched to find the traveller to refer them to secondary inspection. Some cameras, known as "scene cameras", will also record video of the areas under surveillance. The purpose of these video recordings is to show what the traveller is wearing,what they are carrying and who they are with, therefore making it easier for the CBSA to identify and find the traveller when he/she is identified by the system and confirmed as a match to a person of interest.
As the CBSA has no guarantees that an individual in the PDD will arrive at the POE during the project, volunteer CBSA employees will have their photographs and fictitious bio-data elements stored in the FR system as well.
After six months of operation, the equipment will be re-located from the POE to the CBSA's Science and Engineering Directorate (SEO) lab in Ottawa, where further tests will be conducted to measure and possibly improve the system's performance.
Protecting your Personal Information
In order to carry out its mandate, the CBSA must collect a wide variety of personal information. The collection of this information is required in order for CBSA officers to make admissibility decisions regarding persons who wish to enter Canada. Although the CBSA is already using overt video surveillance, this technology demonstration will involve putting that information to a new use that supports the CBSA's admissibility determination processes. The differences between the current AV program and the Faces on the Move demonstration are in the manner in which the information will be used and the retention periods.
Through the use of closed-circuit television (CCTV) technologies, as described in the PIA on the Overt UseofVideo Monitoring and Recording Technology that was submitted to the Office of the Privacy Commissioner (OPC) in November 2013, the CBSA is capturing the physical images of travellers or members of the public (although these images are not currently being used to support admissibility decisions), in addition to the other elements of personal information already collected. Within the CBSA, only those employees who require access to video recordings or photographs as part of their duties are allowed access to this information as per CBSA policies and procedures.
Some personal information collected through the Faces on the Move demonstration may be used in support of the CBSA's admissibility determination process. As a result, photographic and video records (excluding FR templates and related data) may be disclosed internally to CBSA personnel. Within the context of this time-limited technology demonstration, photographic and video records will not be shared with any external stakeholders.
Any access to or disclosure of facial photos, scene camera recordings, or PDD records will be governed by the provisions of the AV Policy.
The retention practices for the Faces on the Move demonstration will be governed by the provisions of the AV Policy, with some variances. In particular, facial photographs, some scene camera recordings, and POD records must be retained until the end of the project. All records will be destroyed at the end of the project, except for records that were used for an "administrative purpose" (e.g., where a match was verified and a traveller was identified and diverted to secondary screening). Any records used for an administrative purpose will be retained for two years following the date of last use in accordance with s. 4 of the Privacy Regulations.
Right of Access
All records, regardless of storage medium, will be stored either in a locked cabinet (container or a safe) or in a secure room designed in accordance with specifications approved by the Infrastructure and Information Security Division of CBSA.
Records will be securely retained in accordance with established policies and guidelines, and may be disclosed within the CBSA. For the duration of this time-limited technology demonstration, records will not be shared with external organizations.
Individuals may formally request access to their personal information, or access to corporate records related to or created as a result of the Faces on the Move project by contacting the Access to Information and Privacy (ATIP) Division. In addition to the requirements specified on the Treasury Board of Canada Secretariat Personal Information Request form, individuals requesting information described by this bank must provide the subject and date of correspondence, incident and location and legal authority for those acting on behalf of an account holder or estate.
If individuals have concerns about the collection, use, disclosure or retention of their personal information, they may issue a complaint to the CBSA ATIP Division. Complaints should be made in writing, and include their name, contact information, and a brief description of their concerns.
To make a compliment, comment or complaint, the CBSA has made available a feedback form to help us to understand our clients and improve the delivery of our programs and services.
The CBSA posted a Video Recording and Monitoring Privacy Notice on its external website on November 19, 2012. This Privacy Notice states:
Video Monitoring and Recording
The Canada Border Services Agency (CBSA) uses video monitoring and recording technology to fulfill its mandate and to increase its ability to protect the public, and to protect employees and assets of the Agency. The use of video monitoring and recording technology is an integral part of the CBSA's security framework and operations management.
Cameras monitor and record CBSA operations at ports of entry and inland offices. Areas and activities that may be monitored or recorded include, but are not limited to: primary interviews, secondary examinations, interactions at CBSA information counters, cashier counters, commercial counters, detention cells, and interview rooms. Cameras may also monitor the movement of travellers and goods from one point in a CBSA operation to another, for example, from primary to secondary.
Use of Recordings
The CBSA collects personal information using overt video monitoring and recording technologies at ports of entry and inland CBSA service locations, to carry out the mandate of the CBSA under the authority of the Canada Border Services Agency Act. Recordings may be used to investigate suspected offences related to border legislation, and may be used as evidence in court proceedings. Recordings may also be disclosed as permitted by legislation to the Canadian Security Intelligence Service, the Royal Canadian Mounted Police, and/or to municipal, provincial or local law enforcement agencies to investigate or enforce federal laws.
Retention and Disposal
Any new or replacement video monitoring and recording equipment must be able to retain recordings for no less than 30 days. Recordings that are used by the CBSA shall be kept for two (2) years following the date of their last use.
Upon expiry of the above retention periods, recordings are permanently deleted/overwritten, or in the case of removable media, recordings are physically destroyed.
Access to Information
Individuals have the right to access their personal information and the right to ensure their personal information is appropriately protected under the Privacy Act. The information collected is described in Info Source under the Overt Audio-Video Surveillance Personal Information Bank CBSA PPU 1104.
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