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Agents of the State? The Evolving Role of Internet Intermediaries in Public Sector Surveillance

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Samuelson-Glushko Canadian Internet Policy and Public Interest Clinic (CIPPIC)




The various entities through which the majority of our online activities and conversations are intermediated are beginning to play a significant role in defining the public sector surveillance landscape. Through the design of their services and business models, they impact directly on online user privacy expectations and the extent to which these can be asserted against government surveillance. Additionally, through their presence at key structural points in online information exchanges, intermediaries pose a tempting target for policy initiatives aimed at leveraging this location in order to achieve surveillance objectives.

This project examines various facets of this shifting surveillance ecosystem with a focus on the role which intermediaries play within it. Specifically:

  • It examines the competitive, business-related, and policy-driven incentives that guide online intermediaries in creating an architecture that is useful for government surveillance purposes;
  • It attempts to describe newly available data sources held or made publicly available by online intermediaries, to provide a quantitative sense of the extent to which such information is being surveilled, and to describe the utility of such information to public sector decision-makers;
  • It examines specific policy initiatives, governance models, and legislative activity that are impacting on surveillance activities related to intermediaries;
  • It assesses what the proper role for intermediaries should be, in a free and democratic society, with respect to the state’s legitimate need to surveille its citizens.

The report concludes by making various policy suggestions that aim to provide ways in which privacy expectations can be preserved in light of some of the privacy eroding pressures active on online intermediaries identified within it.

This document is available in the following language(s):

English only

OPC Funded Project

This project received funding support through the Office of the Privacy Commissioner of Canada’s Contributions Program. The opinions expressed in the summary and report(s) are those of the authors and do not necessarily reflect those of the Office of the Privacy Commissioner of Canada. Summaries have been provided by the project authors. Please note that the projects appear in their language of origin.

Contact Information

Tel: 613-562-5800 x2553
Fax: 613-562-5417

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