Biometrica Compliance with Canadian Privacy Laws (March 2025)
Overview
Biometrica Systems, Inc. operates fully in compliance with Canadian privacy and data protection laws. While Canada does not have a unified national data protection law, applicable federal, provincial, and municipal regulations govern the collection and use of personal and biometric information. Biometrica’s privacy-by-design architecture, human-in-the-loop process, and partnership model ensure compliance across jurisdictions.
Federal: PIPEDA (Personal Information Protection and Electronic Documents Act)
Applicability
PIPEDA applies to private-sector organizations that collect, use, or disclose personal information in the course of commercial activities, with special provisions for security and law enforcement purposes.
Biometrica Compliance
- Biometrica does not collect or process consumer data for commercial activities.
- Biometrica only processes law enforcement-sourced records under authorized partnerships.
- No biometric identifiers, faceprints or other biometric templates are accessed, retained, transmitted, or stored.
- All biometric comparisons occur externally via a NIST-approved third-party provider operating within an isolated black box environment.
- Biometrica’s systems do not access or process personal information subject to PIPEDA unless permitted under the law enforcement exemption.
Quebec: Bill 64 (Act to Modernize Privacy Provisions of Private Sector Act)
Applicability
Quebec’s Bill 64 imposes specific obligations regarding biometrics, consent, and privacy impact assessments (PIAs).
Biometrica Compliance
- Biometrica’s deployment in Quebec would occur solely under contracts with law enforcement or authorized public safety agencies.
- Human-in-the-loop verification meets the province’s requirement for additional safeguards in AI and biometric systems.
- Biometrica does not use generative AI, and has no access to biometrics.
- Biometrica does not perform mass surveillance or engage in general biometric data collection.
- Privacy Impact Assessments (PIAs) are conducted as part of solution deployment.
British Columbia: PIPA (Personal Information Protection Act)
Applicability
Regulates the collection, use, and disclosure of personal information by private-sector organizations.
Biometrica Compliance
- Biometrica qualifies for security service and law enforcement partnership exemptions.
- No biometric identifiers or faceprints are stored, transmitted, or retained.
- Human analyst verification is mandatory for all alerts, limiting the risk of automated decision-making.
Alberta: PIPA (Personal Information Protection Act)
Applicability
Nearly identical to BC’s PIPA, with equivalent restrictions on biometric data usage.
Biometrica Compliance
- Biometrica’s systems function exclusively in conjunction with authorized law enforcement or public safety agencies.
- Human-in-the-loop review and relevance-based alerting prevent indiscriminate biometric processing.
- The system does not engage in mass surveillance or commercial data collection.
Ontario: Municipal Regulations & Frameworks
Applicability
Ontario lacks a province-wide PIPA equivalent but various municipalities (e.g., Toronto) have introduced governance frameworks restricting or guiding facial recognition use.
Biometrica Compliance
- Biometrica does not deploy general facial recognition or mass surveillance systems.
- Sensors do not access, store or transmit biometric templates.
- The system operates under partnerships with authorized security and public safety agencies.
- The Toronto Artificial Intelligence Governance Framework aligns with Biometrica’s approach due to its:
- Human oversight requirement.
- Accountability and audit processes.
- Proportionality and minimization principles.
Cross-Jurisdictional Notes
- Biometrica’s systems follow the principles outlined in Canada’s AI and Data Governance frameworks, including proportionality, necessity, transparency, and human oversight.
- No biometric gallery exists.
- Biometrica operates without direct consumer interaction; all users are trained, credentialed law enforcement, authorized security personnel or vetted and credentialed investigators.
- Biometrica performs Privacy Impact Assessments (PIAs) and would consult with legal counsel where necessary prior to deployment in Canadian jurisdictions.