Citizen Lab submission to Office of the Privacy Commissioner of Canada on draft guidance for processing biometrics

Citizen Lab’s submission to Canada’s OPC on Draft Guidance for processing biometrics urges clearer definitions that treat biometric data as personal information, expanded guidance on sensitivity (intrinsic/immutable traits, inferences, exclusion risks, family/community impacts, and human-rights harms), consistent use of the term “biometric data,” clarification of the sequencing of assessment criteria, and stronger openness measures including public transparency and disclosure of technology vendors; it aligns with prior OPC facial recognition guidance and emphasizes accountability, accuracy, bias, and democratic oversight.