TLDR; 15 Excerpts from the Privacy Commissioner’s Review of Health Canada’s COVID 19 Contact Tracing App

“ our review of the app is based on the information provided to us”

“ we recommended that the government closely monitor and evaluate the app’s effectiveness once it is used, and decommission it if effectiveness cannot be demonstrated”

“in light of the security and other safeguards adopted, the risk of re-identification is very low.”

“ it is unclear whether the law would prohibit organizations from seeking information residing in the app”

“ we noted an element in the Notice and notifications which, in our opinion, was not accurate, and therefore would not result in meaningful consent”…” use of the app should not be characterized as entirely anonymous. Personal data is being de-identified, at certain points, and users rendered pseudonymous, at certain points, but such techniques across the system should not be described as offering anonymity.” (Health Canada and the Government of Canada accepted te recommendation and removed those references)

This deserves a pause. While it is not necessary for the purpose of this review to opine on the validity of the government’s assertion, which may be correct at law, it bears noting that an app, described worldwide as extremely privacy sensitive and the subject of reasoned concern for the future of democratic values, is defended by the Government of Canada as not subject to its privacy laws. This is again cause for modernizing our laws so that they effectively protect Canadian citizens.”

OPC Recommendation: Health Canada should remove from the Privacy Assessment and any other documentation references indicating that the Government of Canada complies with the Privacy Act and with TBS policies on privacy.

“several commercial entities will be able to determine whether individuals have downloaded and used the app. These entities should not be permitted to monitor their customers’ use of the COVID Alert app.”

“considering the complexity of the (Shared Services Canada) agreement (with Amazon AWS) and our limited time for review, we reserve the right to further review this agreement as part of the Government of Canada’s broader cloud-first strategy”

  1. Reform: the Privacy Commissioner really makes it clear that Canadians are not well served by their current privacy legislation.
  2. Dependencies: the app ultimately depends on the platform it runs on, with some opacity as to the use of information by commercial third parties. The Android version of the app, for instance, requires Location Services to be turned on for the app to function, even though the app itself does not collect location information.
  3. Perspective. As you can see from this snapshot of web page trackers, there is much more tracking and collection of personal information during the course of reading an article about the contact tracing app on a media website than there is within the app itself.




Fīat jūstitia, ruat cælum. Personal musings on data protection fails, snafus & oddities, collected & edited by Claudiu Popa; author, educator, booknerd.

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Bad Privacy

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Fīat jūstitia, ruat cælum. Personal musings on data protection fails, snafus & oddities, collected & edited by Claudiu Popa; author, educator, booknerd.

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