Yesterday, the Quebec privacy regulator, the Commission d’accès à l’information (CAI), issued a decision (in French only) regarding a company’s use of a video surveillance system in the cabins of its vehicles. While the company was using cameras facing inside and outside its vehicles, the CAI only addressed the use of inside-facing cameras.
The company’s video surveillance was set to record images of delivery drivers from the moment the vehicle started until 20 minutes after the engine was turned off and included features to generate reports based on predefined incidents occurring inside the vehicle cabins (e.g., use of mobile phone while vehicle is moving, smoking, and possible collisions).
The CAI found that the company did not minimize the collection of personal information and ordered the company to either limit image collection inside its vehicles to a brief window of seconds before and after a detected incident or, if that is not feasible, to stop collecting images inside the vehicles altogether. It also ordered the company to stop collecting images after the engine is turned off and to destroy any recordings not pertaining to the relevant incidents.
While this decision focuses on in-vehicle video surveillance practices, it has broader implications as it underscores the CAI's expectation that organizations in Quebec must rigorously justify the necessity and proportionality of surveillance activities, ensuring that personal information collection is minimized and limited to what is strictly required for real, legitimate, and important objectives.
A detailed analysis of the decision will follow. Please reach out to the Osler Privacy and Data Management Team if you have any questions.
