COVID-19 Contact Tracing Debate Highlights Need For Privacy Law Reform: Lessons For Developers And Users

We have been following the COVID-19 crisis and its impact on privacy law over the course of the past few months. It has become apparent during that time that the requirements of the pandemic and the contact tracing debate highlight the need for privacy law reform in Canada, as emphasized by Canadian federal Privacy Commissioner ("OPC"), Daniel Therrien, in a speech before the House of Commons.

In this recent appearance, Commissioner Therrien highlighted six main points as they relate to so-called "contact tracing". These contain important lessons for organizations developing or considering the use of these types of tools:

• Purpose limitation: personal information collected through tracing applications should be used for defined public health purposes and for no other purpose.