Facial recognition (FR) technology has the potential to significantly improve the speed and scale of police-operated mugshot databases. However, the use of FR technology by law enforcement raises legal, privacy, and ethical questions that are not fully resolved by Canada’s current laws relating to the identification of criminals.

Recently, the Information and Privacy Commissioner of Ontario (IPC) issued its guidance document titled Facial Recognition and Mugshot Databases: Guidance for Police in Ontario (the Guidance). The Guidance is non-binding, and through it, the IPC seeks to clarify the privacy obligations of Ontario police services that already use or are planning to use FR technology in connection with mugshot databases.

Deeth Williams Wall has prepared an Advisory, which offers (i) an overview of the Guidance; and (ii) a checklist to assist those who need to action the IPC’s recommendations for implementing a FR mugshot database program.

Click below to review the full advisory:


Summary By: Elisabeth Symons, Olalekan (Wole) Akinremi, Imtiaz Karamat, Victoria Di Felice



24 03 20

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