SUBMISSION OF THE PUBLIC INTEREST ADVOCACY CENTRE (“PIAC”)

PIAC points out that the initial reporting stage under the Policy requires that the Chief of Police report to the Board about “how the AI technology operates;” if the Chief cannot explain how the AI system works, the Board cannot form any legitimate basis for approval. [...] Although the Policy provides that the general Section 1 procedures are made available to the public on the Service’s website, there are no provisions that clearly indicates to what degree the public is informed about the details of the Chief’s report to the Board under Section 5. [...] Only Section 8 rather nebulously suggests that the Chief “[w]ill develop and implement a public engagement strategy, commensurate with the risk level assigned to the new AI technology, to transparently inform the public of the use of the new AI technology that collects data about the members of the public or assists Service Members in identifying, categorizing or otherwise making decisions pertain. [...] PIAC also notes that the Policy does not require the Board to inform the public of the termination of any AI tech in use prior to the Policy due to the tech being deemed to be “Extreme Risk.” PIAC submits that the public be notified that an AI system was in use – likely without the public’s knowledge – and then decommissioned due to factors serious enough to likely, or actually, impact individuals. [...] Section 13(c) further instructs that the Executive Director, if the “communication from a member of the public amounts to a complaint, will advise the individual of their right to file a complaint with the Office of the Independent Police Review Director or successor role, or forward the communication to the Chief of Police, as appropriate, and inform the complainant of this action.” It is unclear.