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Contributions Program projects underway

On June 23, 2021, the Office of the Privacy Commissioner of Canada (OPC) announced funding for a new round of independent research and knowledge translation projects funded under its Contributions Program. These projects will be completed by March 31, 2022. The OPC will post a summary of completed projects, as well as links to their outcomes, once the projects are completed and reviewed by the OPC.

2021-22 Contributions Program funding recipients

Organization: MediaSmarts
Project title: #For You: A Game About Artificial Intelligence and Privacy Project
Amount requested: $50,000
Project leader: Kara Brisson-Boivin
Province: Ontario

Project summary:

#ForYou: A Game About Artificial Intelligence and Privacy will equip young people to consider and discuss the role of machine learning and recommendation algorithms in their lives and the impacts that these have on their privacy, in a way that is concrete and engaging.

The project places youth in the role of video creators who are attempting to gain a following and monetize their videos on a platform such as YouTube or TikTok.

This educational resource will give youth an opportunity to: 1) reflect on the ways in which they interact with AI in their day-to-day lives; 2) learn more about how AI and algorithms work; 3) understand the implications of AI and algorithms on their privacy, and; 4) learn how to take action to advocate for and design algorithms that are equitable and practice good stewardship of personally identifying information.


Organization: Women's College Hospital
Project title: Commercial Virtual Care Services in Canada: Consumer Data, De-Identification and Privacy
Amount requested: $49,535
Project leader: Sheryl Spithoff
Province: Ontario

Project summary:

The use of commercial virtual care services in Canada has exploded with the COVID-19 pandemic, improving access and transforming care, as well as raising concerns about the privacy and security of personal health information.

This project’s research goal is to describe, analyze and critique commercial virtual care services in Canada. It focuses on how the collection and commercialization of de-identified data affects privacy as well as other risks that emerge with inadequate privacy protections.

Ultimately, the goal of the project is to create new normative frameworks and enhance privacy protections and accountability.


Organization: Association des juristes d’expression française de l’Ontario (AJEFO)
Project title: Get Informed and Protect your Privacy Online
Amount requested: $50,000
Project leader: Andrée-Anne Martel
Province: Ontario

Project summary:

This project aims to create and disseminate Canada-wide legal information resources using plain language on online privacy rights and obligations. More specifically, AJEFO will develop legal news articles, plainlanguage infographics, a video clip, virtual legal information sessions and an educational resource for the general public.

The intensification of online activities and the growing need to connect in order to work, consume, study, interact socially, have fun, and even to understand and deal with legal issues, peaked in 2020, as a result of the COVID-19 pandemic. Yet, in this digital sphere, members of the public continue to take risks every day and often lack information to better protect their privacy.

Faced with this reality, AJEFO will develop clear, simple and accessible information to empower Canadians and enable them to better control and protect the dissemination of their personal information online. Available in a variety of formats, these resources developed entirely in French will enable the general Francophone public across Canada to know, understand and defend their online privacy rights.


Organization: Canadian Standards Association (CSA Group)
Project title: Privacy for Wellness Wearables: Emerging Trends and Power Dynamics in a Grey Area
Amount requested: $50,000
Project leader: Nicki Islic
Province: Ontario

Project summary:

This research and knowledge translation project focuses on the privacy implications of wellness wearables.

There has been a rapid increase in uptake of commercial health and wellness apps and wearable devices. By enabling the active and passive collection of consumers’ sensitive health-related data, these apps and devices pose substantial privacy risks (e.g. the creation of behavioural profiles for prediction, data breaches, etc.). As both commercial and health products, they occupy a regulatory grey area that allows for increased data sharing, cross-border transmission and storage and other risks to intimate data.

The project supports the development and understanding of privacy rights for those developing standards, policies, and guidance related to this field.


Organization: Institute for Information Systems Engineering (CIISE), Concordia University
Project title: Privacy Report Card for Online Solutions Targeting Seniors
Amount requested: $49,740
Project leader: Mohammad Mannan & Amr Youssef
Province: Quebec

Project summary:

According to the World Economic Forum, 70% of seniors are now online. Many Canadian seniors track their medical conditions with remote monitoring health devices. Internet of Things (IoT) devices that provide services such as GPS tracking, automatic fall detection, as well as many other medical alert solutions are readily available in the Canadian market that focus on the elderly population and their caregivers. Hundreds of mobile apps, specifically designed for the elderly and their care givers are available on different app stores.

However, very little is known about the costs of using these devices or applications in terms of a new source for privacy leakage and security/safety risks. This project examines, through a comprehensive and systematic technical/experimental investigation, the security and privacy risks associated with such solutions that are commonly used by many Canadian elderly citizens and their caregivers.

The project will produce a public report card for online solutions designed for seniors and the elderly, summarizing the findings of the research investigation and presenting recommendations for improving these solutions in terms of effectiveness, security and privacy. The findings of this report will be provided online free. The project will also produce an academic paper detailing the full methodology and results, and technical recommendations.


Organization: Department of Information Systems and Quantitative Management Methods, School of Management, Université de Sherbrooke
Project title: Guide for Creating a Secure Digital Identity Framework as Part of a Cloud-Based Digital Organizational Transformation
Amount requested: $47,443
Project leader: Pierre-Martin Tardif
Province: Quebec

Project summary:

Canadian companies manage the digital identity of many people, such as clients and staff, which poses challenges in terms of personal information protection and legal compliance, in a context of de facto transnational cloud-based data storage. However, scientific knowledge in the field is still limited and most often dispersed across several disciplines, which limits the ability of organizations to securely implement digital identity.

This research project will identify and evaluate innovative practices to create a Guide for creating a secure digital identity framework as part of a cloud-based digital organizational transformation. More specifically, it aims to answer the following research question: How do we implement a digital identity within a company while respecting the privacy of Canadians in accordance with the legal framework in which data are collected, stored and shared through cloud-based resources?

This research will identify and evaluate innovative practices in this area and highlight best practices. Lastly, the Guide that will be produced will make this knowledge available to Canadian companies to facilitate its applicability.


Organization: Institute for Information Systems Engineering (CIISE), Concordia University
Project title: Privacy Design Landscape for Central Bank Digital Currency
Amount requested: $26,450
Project leader: Jeremy Clark
Province: Quebec

Project summary:

There are many technical complexities involved in designing a central bank digital currency (CBDC) but one of the most complicated of the design parameters is privacy. This research project has one main deliverable: to produce an in-depth study of the design landscape for privacy in CBDCs, both for an academic audience and for a general audience.

To ensure the results have technical depth, the research explores suitable designs through experimentation, such as cryptographic protocol design and blockchain smart contracts (all code artifacts released free and open source with performance measurements).

This project does not take a normative position that a CBDC ought to be deployed in a modern economy. Rather, it takes the position that CBDCs are a possibility. The project affirms that privacy must be a starting point for designing a CBDC, not an afterthought.


Organization: Surveillance Studies Centre, Queen's University
Project title: Deeper Learning? Marketing, Personal Data and Privacy After Surveillance Capitalism
Amount requested: $49,407.78
Project leader: David Murakami Wood and Stephen Thomas

Province: Ontario

Project summary:

The researchers behind this project propose that the model of “surveillance capitalism” is already out of date. Sparked partly by the demands of the European General Data Protection Regulation (GDPR), they argue that we are seeing the emergence of new models of marketing using open-source intelligence, more time- or topic-limited types of personal data, and AI models, particularly Deep Learning. These models may not use less data but they do use data that is claimed to be less personally identifiable, while generating more lucrative outcomes for their marketing users.

The project thus asks five questions: 1. How do these models work? 2. How widespread is their use already? 3. Are the claims of their advocates justified, and what are the implications for privacy? 4. Are Canada’s current privacy laws and regulations capable of dealing with these models and their privacy implications? 5. What changes to law and regulation might be needed to do so?

The purpose of this project, in producing a report, technological walk-throughs and regulatory scenarios, is to increase knowledge and understanding within government, Parliament, and regulators of the actual and potential future practices of corporations regarding the collection, use and analysis of data, how these practices affect life chances and choices, and what options are available to protect human rights, particularly privacy.


Organization: Faculty of Law, Civil Law Section, University of Ottawa

Project title: Online Exam Monitoring Software During the Pandemic: Seeking to Minimize the Risks to Student Privacy
Amount requested: $28,500
Project leader: Céline Castets-Renard
Province: Ontario

Project summary:

The COVID-19 pandemic forced much of the world’s population to telework. Canadian universities are no exception and the majority of courses and exams must now be completed online. In order to do this, most universities have developed software to monitor exams referred to as “proctors”. These software programs, such as Respondus Monitor, ProctorExam, Examity, ProctorU and Proctorio, offer various solutions. Although we understand the good intentions of universities and teachers, as well as the desire to guarantee academic quality and integrity, these tools do raise concerns. The main concerns relate to the potential infringement of student privacy and the massive collection of personal information.

This research will analyze the main exam monitoring software used in Canada and highlight the privacy risks to students. The goal is to find ways to reduce these risks by making recommendations to legislators as part of amendments to the Personal Information Protection and Electronic Documents Act (PIPEDA) through Bill C-11. The recommendations will focus on specific areas of concern identified through the use of exam monitoring tools.


Organization: Children’s Hospital of Eastern Ontario (CHEO) Research Institute
Project title: A Pan-Canadian Descriptive Study of Privacy Risks from Data Synthesis Practices within the Evolving Canadian Legislative Landscape
Amount requested: $49,404
Project leader: Khaled El Eman
Province: Ontario

Project summary:

Data synthesis is rapidly emerging as a practical privacy enhancing technology (PET) for sharing data for secondary purposes. However, the strengths and weaknesses of this emerging technology are not fully appreciated and need to be evaluated. As well, we need to develop an understanding of how data synthesis would be treated under various privacy regimes in Canada.

This project aims to provide a detailed overview of data synthesis as a PET used to facilitate data sharing within the Canadian context. It is intended to help Canadian organizations understand what data synthesis is, and to provide an assessment of contemporary methods and technologies and how they can be applied under current and proposed regulatory regimes.

The proposed project consists of three main research phases: 1. An overview of data synthesis (environmental scan/literature review); 2. A legal analysis of data synthesis under Part I of PIPEDA and the Consumer Privacy Protection Act (CPPA) component of the Digital Charter Implementation Act, 2020 (Bill C-11), and; 3. Perspectives of Canadian regulators on data synthesis. The research will assess: i) whether PIPEDA and the proposed provisions of the CPPA adequately address data synthesis as a PET to protect individual privacy; ii) identify if there are gaps in both PIPEDA and in the legislative proposal, and the nature of such gaps; and iii) propose solutions to “close the gaps.”


Organization: Faculty of Philosophy, Université Laval
Project title: Thinking About Privacy Rights in Relation to Individual and Collective Rights
Amount requested: $49,508
Project leader: Jocelyn Maclure
Province: Quebec

Project summary:

In the age of Big Data, recent technologies and AI allow for the inference of private attributes from a quantity of data that is innocuous when viewed in isolation, but which, when cross-referenced with other data, can reveal in a probabilistic manner things such as a person’s political opinions, religious beliefs, sexual orientation, lifestyle and health status.

This information, inferred from information that is not necessarily personal, can be used to influence or manipulate behaviour or opinions and to engage in profiling or discrimination. More and more experts are stressing the importance of addressing this relatively new area of privacy and data protection. Some are even claiming a right to “reasonable inferences”.

In their recent work, researchers have shown that the safeguards offered by current and proposed Canadian legislation (Bill C-11) do not adequately protect the privacy of individuals with respect to the risks posed by the use of inferred information. To adequately protect individuals from these risks, they argue there is a need to shift the focus from individual consent-based control of personal data to a regulatory framework for the use of inferences. These researchers have even suggested that certain inferences should be prohibited. The results of their work support the view that the right to privacy is a necessary condition for the exercise of other fundamental rights. However, this proposal faces a major challenge.

On the one hand, certain experts argue that the protection of fundamental rights must not take place within the context of privacy protection, since these fundamental rights can be protected independently of privacy. On the other, some advocates of a distinctive view of privacy – who support the concept of “collective” privacy – argue that the protection of privacy rights must include protection of algorithmic groups, these groups of people who share a generic identity generated by algorithms.

What should we make of this? The researchers will undertake a critical analysis of these two fundamental theses. In their view, this analysis is necessary if there is to be privacy protection based on rights and recognition of the right to privacy in its entirety.


2020-21 Contributions Program funding recipients

Organization: MediaSmarts
Project title: Algorithms, AI, and Awareness: Conversations with Young Canadians about Artificial Intelligence and Privacy
Amount requested: $50,000.00
Project leader: Kara Brisson-Boivin

Project summary:
This project will give young people an opportunity to discuss, reflect upon, and design ways of explaining artificial intelligence (AI), and its impact on privacy, that are clear and meaningful to them. The project will build on previous research findings of MediaSmarts by creating space for youth to learn more about AI and its repercussions on privacy rights, and help design youth-friendly education tools to build awareness and meaningful understanding that will allow young people to better protect their privacy.


Organization: University of Alberta, Health Law Institute
Project title: Privacy and Artificial Intelligence: Protecting Health Information in a New Era
Amount requested: $49,910.00
Project leader: Timothy Caulfield

Project summary:
Artificial Intelligence (AI) is a novel frontier in Canadian healthcare, and one currently without a comprehensive, tailored legal and regulatory framework. The goals of this research project are to: 1) Identify and categorize privacy issues associated with emerging translation and implementation of commercial AI-based technologies in Canadian healthcare; 2) Apply relevant Canadian law, regulation and policy to these issues, including legislation, case law and other legal and quasi-legal doctrines; 3) Assess where the relevant instruments are effective, ineffective or deficient, noting gaps, opportunities and potential areas for improvement, and; 4) Recommend changes to law and policy that will protect the privacy rights of patients while supporting the translation of commercial AI technologies in healthcare.


Organization: ISOC Québec
Project title: Alter Algo: Could Algorithms Be Our Digital Alter Egos?
Amount requested: $50,000.00
Project leader: Destiny Tchéhouali

Project summary:
This research project will examine the perceptions and assess the maturity and trust levels of streaming services of Canadian users – in particular young people – when it comes to the use of their data for the purposes of personalized recommendation algorithms on streaming platforms.

This project will help Canadian streaming service users develop their critical thinking with respect to the mechanisms and operation of recommendation algorithms, and will encourage greater vigilance with respect to the biases and abuses that could guide or affect their online consumption of cultural products. A website will be created to share the research results, written in plain language, and will include video clips of interviews conducted with experts, thus contributing to better public understanding and literacy on issues relating to the impact of artificial intelligence and algorithms on privacy.


Organization: Canadian Standards Association (CSA) Group
Project title: Implications of Artificial Intelligence (AI) on the Privacy Rights of Children
Amount requested: $49,500.00
Project leader: Nicki Islic

Project summary:
CSA Group will conduct a research and knowledge translation project that focuses on the implications of artificial intelligence (AI) on the privacy rights of children. As AI is deployed in a wider array of public and consumer services, children will increasingly face no choice but to interact with AI with little meaningful opportunity for consent from them or their guardians.

By generating new research and knowledge translation approaches in an underserved area, this project will support child-centred design and deployment of AI. It will also fill-in knowledge gaps on the impact of AI on children’s privacy rights for those developing standards, policies, and guidance related to children’s privacy.


Organization: Canadian Anonymization Network (CANON)
Project title: Case Studies and Design Patterns – The Practical Application of De-identification
Amount requested: $19,200.00
Project leader: Khaled El-Emam

Project summary:
Regulators, organizations and innovators of all kinds have expressed interest in the potential role of de-identification in enhancing privacy while encouraging innovation. This project will include the development of a taxonomy for the primary use cases of de-identification along with other resources that will help to create a common understanding of the vocabulary, techniques and outcomes associated with de-identification. The project will also seek to develop a series of practical case studies that set out in-depth descriptions of how de-identification has been used in practice and for which purposes, identifying both successes and challenges encountered. Lastly, the researchers will develop a series of “design patterns” for de-identification, which set out high-level approaches that can be applied to commonly encountered data-sharing scenarios.


Organization: Université du Québec à Montréal (UQAM), IT Department
Project title: Privacy and Ethics: Understanding the Convergences and Tensions for the Responsible Development of Machine Learning
Amount requested: $49,900.00
Project leader: Sébastien Gambs

Project summary:
Machine learning models are now ubiquitous in our society. However, their widespread use also raises serious privacy and ethical issues, especially if their predictions are applied in domains where they can significantly affect individuals. To understand how to best address privacy and ethics responsibly when developing machine learning models, we need to first have a clear view of how these concepts interact with each other. The objective of this project is to investigate this question by following an interdisciplinary approach at the crossroads of computer science, law and ethics.


Organization: University of Calgary, Department of Radiology
Project title: Deep Learning in Medical Imaging: Risks to Patient Privacy and Possible Solutions
Amount requested: $50,000.00
Project leader: Nils Daniel Forkert

Project summary:
This research project will first investigate how vulnerable deep learning models trained on medical data are to model inversion attacks that reconstruct the training data. In a second step, it will implement and evaluate methods that can protect deep learning models against data reconstruction. The researchers expect that the project will lead to improved awareness of privacy risks by those working in the field of deep learning, and the development of privacy-sensitive deep learning solutions in medicine. As a result, Canadians will be able to benefit from the advancements in deep learning and medicine while ensuring that personal medical data used for training of these models remains private.


Organization: Option consommateurs
Project title: Artificial Intelligence and Privacy: A Consumer Perspective
Amount requested: $49,540.00
Project leader: Alexandre Plourde

Project summary:
The use of artificial intelligence (AI) is putting Canadian privacy legislation, which is struggling to adapt to this emerging technology, to the test. In the face of these challenges, a number of stakeholders are calling for better oversight of AI to ensure its ethical development.

In this project, Option consommateurs will conduct research on consumers and AI. Researchers will begin by documenting the current and future uses of AI by the largest companies offering online services to Canadians, and will then identify the associated benefits and risks to privacy. Lastly, researchers will explore privacy protection rights in relation to AI in Canada and abroad. By identifying the benefits and risks of using AI in business–consumer relations, Option consommateurs hopes to shed some light on potential solutions and on the best ways to strengthen the legal framework.


Organization: Laval University, Faculty of Philosophy
Project title: The Right to Privacy: Conceptual Analysis and Ethical Reflections on its Source, Scope and Place in an Era of Data-Driven Technology
Amount requested: $49,508.00
Project leader: Jocelyn Maclure

Project summary:
This research project will give researchers the opportunity to contribute to current philosophical thinking on privacy protection in Canada through a conceptual analysis of the right to privacy and ethical reflections on its source, scope and place in an era of data-driven technology.

Researchers will examine and bring a modern perspective to the contributions of philosophical thinkers on the right to privacy. In particular, they will seek to identify, through an interdisciplinary approach and on the basis of fundamental Canadian values, privacy inferences stemming from AI that pose an ethical dilemma from a collective and individual standpoint.


Organization: Ontario Tech University, Department of Electrical, Computer and Software Engineering
Project title: Exploring Blockchain for Consent and Privacy Data Management
Amount requested: $49,967.50
Project leader: Qusay H. Mahmoud

Project summary:
This project will explore blockchain technology and experiment with it for enhanced data security and personal information management for individuals, corporations, government entities, and public institutions.

The researchers plan to design and develop a platform where data can be easily, securely and contextually shared across systems, with individuals as the owners of their data and controllers of the flow of their personal information. The proposed blockchain-based platform would reduce the risk of unauthorized access and data manipulation, and benefit everyone from private and public sector organizations to Canadian citizens who would no longer need to spend time filling out forms with information they have provided many times already.

The project will create awareness of privacy issues and promote best practices for protecting the personal information of Canadians through a set of application programming interfaces, and will produce a proof-of-concept prototype of the proposed platform. The results will be disseminated in a variety of ways, including a dedicated interactive website with access to the platform and a conference publication.


Organization: Ontario Tech University, Faculty of Business and Information Technology
Project title: Artificial Intelligence, Machine Learning and Privacy: From Threats to Solutions
Amount requested: $32,468.50
Project leader: Khalil El-Khatib

Project summary:
Despite the fact that there are numerous perceived benefits to developing human-equivalent machine intelligence, there are also a number of public concerns about the technology. This project will explore known privacy risks associated with artificial intelligence and machine learning, identify popular use cases, and create a venue to discuss their privacy-associated risks. Specifically, the researchers will identify use cases of artificial intelligence and machine learning systems where privacy is at risk, survey privacy-preservation technologies for artificial intelligence and machine learning, and create a venue for information sharing on artificial intelligence, machine learning and privacy.


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