Special report to Parliament: Investigation of the RCMP’s collection of open-source information under Project Wide Awake
The Office of the Privacy Commissioner of Canada (OPC) conducted a special investigation into the Royal Canadian Mounted Police's (RCMP) collection of open-source information under Project Wide Awake (PWA), triggered by a complaint from MP Charlie Angus. The investigation focused on the RCMP's use of third-party services, specifically Babel Street's Babel X, for collecting personal information from various online sources. The OPC found that the RCMP failed to conduct adequate due diligence to ensure that the personal information collected via Babel X and its data providers complied with Canadian privacy laws, particularly PIPEDA. Furthermore, the OPC determined that the RCMP did not meet its transparency obligations under Section 11 of the Privacy Act, as its Personal Information Bank (PIB) descriptions were inadequate in detailing the types and purposes of open-source information collected. The RCMP did not agree to implement the OPC's recommendations, including ceasing collection from problematic Babel X sources until a thorough review was completed and updating its PIB descriptions with sufficient granularity. Consequently, both issues were found to be well-founded and unresolved.
- 1Whether the RCMP's collection of personal information via Social Studio complied with Section 4 of the Privacy Act.
- 2Whether the RCMP's collection of personal information via Babel X complied with Section 4 of the Privacy Act.
- 3Whether the RCMP conducted adequate due diligence on the lawfulness of collection practices of Babel X and its data providers.
- 4Whether Section 4 of the Privacy Act permits the collection of personal information from a third-party agent that collected, used, or disclosed the information in contravention of a law that third party is subject to.
- 5Whether the RCMP's publicly available descriptions of its open-source information gathering are granular enough to meet transparency obligations under Section 11 of the Privacy Act.
- 6Whether the RCMP's published descriptions clarify limits on purposes for collection under Section 11 of the Privacy Act.
- 7Whether the RCMP's descriptions of open-source information collection and related purposes are adequate under Section 11 of the Privacy Act.
- Due diligence for collection: RCMP failed to ensure compliance with privacy laws
- Transparency obligations: RCMP failed to meet transparency obligations under Privacy Act
- PIB descriptions: PIB descriptions were inadequate
- Implementation of recommendations: RCMP did not agree to implement recommendations
- Complaint outcome: Complaint found well-founded and unresolved
Complaint well-founded and not resolved on both issues
The OPC found that the RCMP failed to conduct adequate due diligence on third-party data sources for Babel X and did not adequately describe its open-source collection in its PIBs, and the RCMP did not agree to implement the OPC's recommendations to rectify these contraventions.
The OPC recommended that the RCMP implement its own PIA recommendations within 12 months, cease collecting personal information via Babel X from sources requiring logins/authentication until a thorough compliance review, apply findings to other open-source intelligence tools, and develop/modify PIB descriptions within 12 months to meaningfully cover open-source intelligence gathering with detailed sources and purposes.
- s.4 Privacy Act
- s.11 Privacy Act
- s.39(1) Privacy Act
- s.18 Royal Canadian Mounted Police Act
- PIPEDA
- PIPEDA Regulations Specifying Publicly Available Information
This summary is for informational purposes only and not legal advice.
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