Next-generation law enforcement
Banner: Original artwork by Aedán Crooke of Surface Impression, commissioned for the IPC’s Transparency Showcase.
IPC Goal: to contribute to building public trust in law enforcement by working with relevant partners to develop the necessary guardrails for the adoption of new technologies and community-based approaches that protect both public safety and Ontarians’ access and privacy rights.
Sharing information in situations involving intimate partner violence
In May 2024, the IPC released new guidance on Sharing Information in Situations Involving Intimate Partner Violence (IPV). This guidance was developed in response to recommendation 78 from a 2022 Ontario coroner’s inquest into the tragic deaths of three women at the hands of their former partner. The resulting guidance provides a clear, practical approach, specifically tailored for professionals, to support responsible information-sharing in situations where there's a risk of serious harm to a person’s health or safety.
Based on consultations across the justice, health, and social services sectors, as well as those with lived experience of IPV, the guidance advocates for a trauma and violence-informed approach to information-sharing that increases the security, control, and resilience of victims, survivors, and their families. The guidance specially calls for a culturally sensitive approach that considers historical, cultural, and internal biases to prevent further victimization of historically marginalized communities. The IPC has been heartened by the uniformly positive response to the guidance, and its widespread adoption by organizations across the sector. The guidance is currently featured on the Association of Municipalities of Ontario’s Gender-based Violence Resources for Municipal Elected Officials and the Ministry of the Solicitor General’s Guidance on information sharing in multi-sectoral risk intervention models.
Further to this work, the IPC, together with our FPT counterparts, issued a joint resolution on November 27, 2024, during Woman Abuse Prevention Month, to support responsible information-sharing in contexts involving IPV.
The resolution affirms that Canada’s privacy laws generally permit the disclosure of personal information to prevent injury or loss of life in IPV situations and calls on governments and organizations to develop privacy compliant governance frameworks around disclosure practices. It also highlights the need for training, transparency in disclosure practices, and a culturally sensitive approach when serving marginalized and vulnerable groups. By supporting a better understanding of the conditions under which personal information may be disclosed, this resolution helps alleviate the 'privacy paralysis' that inhibits information sharing and support timely interventions to prevent injury or loss of life.
"Intimate partner violence is a devastating and pervasive reality in our society. We know and respect how seriously professionals take their obligation of confidentiality, but injury or loss of life should never happen because of a hesitancy to share vital information based on a misunderstanding of privacy laws.”
Shaping the future of investigative genetic genealogy
In 2024, the IPC furthered its research and policy work on an emerging investigative tool called Investigative Genetic Genealogy (IGG). IGG involves collecting a DNA sample from a crime scene and comparing it against profiles in private sector DNA databases to search for partial family matches, using new, sophisticated genetic sequencing techniques. Then, using genealogical research and tactical surveillance methods, police begin to narrow down investigative leads in their search for possible suspects. Police are increasingly using IGG to solve serious crimes, but it also raises significant legal, privacy and ethical considerations. Building on insights from the IPC’s Privacy Futures Project in 2023, we engaged directly with interested parties to develop meaningful guidance that balances public safety with fundamental privacy and human rights.
A major step in this effort was a half-day workshop in January 2025 where we convened experts from across Ontario and the US, including forensic scientists, privacy and human rights experts, bioethicists, civil society, victims’ rights advocates, academics, police services, government representatives, and First Nations technology leaders. Participants expressed broad consensus on the need for clear, enforceable standards to ensure IGG is used responsibly. Discussions centred on twelve guardrails we proposed to guide whether IGG should be used and if so, in what circumstances and how. We sought participants’ input on these proposed guardrails, based on established privacy principles and best practices, and their technical feasibility, policy implications, and operational impact.
Based on this feedback, we finalized our guidance, Guardrails for Police Use of IGG in Ontario. The guardrails include the need to ensure lawful authority, necessity, accountability and transparency of IGG investigative tools, together with data security safeguards and procurement guidance to uphold privacy rights of Ontarians. Other guardrails include controls on surreptitious DNA collection, limits on retention of DNA or DNA-derived information, and guidelines for ethical disclosure.
The guardrails include the need to ensure lawful authority, necessity, accountability and transparency of IGG investigative tools, together with data security safeguards and procurement guidance to uphold privacy rights of Ontarians. Other guardrails include controls on surreptitious DNA collection, limits on retention of DNA or DNA-derived information, and guidelines for ethical disclosure.
“The IPC strongly recommends that police services adopt these guardrails if using, or considering using, IGG as an investigative technique, in advance of any explicit legal authority and proper statutory controls in this novel area.”
ALPR: Evolving tech, greater risks
In 2024, the IPC released updated guidance on the Use of Automated Licence Plate Recognition Systems by Police Services to reflect evolving technologies and their expanded uses in law enforcement. ALPR systems, both fixed and mobile, capture and compare large volumes of licence plate data against databases, supporting police services in identifying vehicles with stolen or expired plates and those registered to suspended drivers.
Police services now use this technology for a wider range of law enforcement tasks, including tracking vehicles tied to criminal investigations, monitoring the movements of known offenders, and identifying vehicles involved in serious crimes such as human trafficking and drug smuggling. This broadened use brings risks to both privacy and fundamental human rights.
The IPC collaborated with law enforcement agencies, privacy experts, and civil society to develop best practices for ALPR policies, procedures, and technical controls. The updated guidance highlights key obligations under Ontario’s privacy laws and offers practical advice for using ALPR systems in a way that protects privacy and human rights.
Some of the key recommendations include conducting a thorough privacy impact assessment prior to deploying an ALPR pilot or program, regularly reviewing hotlist databases to ensure they are kept accurate and up-to-date, immediately destroying non-hit data, notifying the public about the location of cameras, engaging and consulting with affected communities, and building in the necessary privacy and transparency requirements in contracts with third party vendors.