Cybersecurity Will Not Thrive in Darkness: A Critical Analysis of Proposed Amendments in Bill C-26 to the Telecommunications Act

• The nature of the information that may be revealed by biometric data: We would recommend further elaboration of the discussion of the heightened sensitivity of the information that some forms of biometric data can reveal. [...] For example, the World Bank notes that in deciding the set of biometrics to use, special attention needs to be given to issues of accuracy and accessibility, given the potential for biometrics programs to be exclusionary to some segments of the population. [...] Recommendation 4: Assessing the Appropriateness of the Biometrics Program Potential clarification in regard to whether there is any interpretive significance to be attached to the sequence of the criteria used to assess the appropriateness of the biometrics program (i.e., Sensitivity, Necessity, Effectiveness, Proportionality, and Minimal Intrusiveness). [...] In that instance, for example, the order of the topics for assessment was different, and placed the “proportionality” assessment at the end of the list. [...] In that sense, the “must” and “should” recommendations that follow are designed to provide information only to individuals, with the exceptions of the two recommendations regarding the post of the privacy policy for organizations, and specified public reporting for public institutions.