Canada's Privacy Commissioner, commenting on the House of Commons TRAN report on automated
vehicles in May of 2018, likened autonomous vehicles
("AV") to "smartphones on
wheels". While apt, the comparison is a significant
understatement. The volume of information generated by the daily
activities of even the most enthusiastic user of smartphone
technology pales in comparison to the torrent of data created by
the average SAE Level 3, 4 or 5 AV over the course of just a few minutes of drive time. A significant
amount of this data may qualify as personal information for the
purposes of Canadian privacy law.
Privacy law is a moving target and if you are building a
business model around AV technology and expect to use even a
fraction of the personal information generated by AVs, you will
need to take developments in this area into account. Below, we
highlight selected features of and recent developments in Canadian
privacy law that you should be aware of and may want to