Express, informed consent
Explain the purpose and get opt-in before capturing a face.
Canadian privacy law treats biometrics as sensitive, and Quebec adds specific biometric duties. Plan for express consent and careful retention.
Requires meaningful consent; for sensitive data like biometrics, the Privacy Commissioner expects express consent and a clearly necessary, proportionate purpose.
Express consent for biometric verification, and the Commission d'accès à l'information must be notified before a biometric database goes into service (at least 60 days ahead).
Alberta and British Columbia have their own private-sector privacy acts with similar consent and reasonableness tests.
Reporting entities can use biometric-backed methods as part of identity verification under Canada's AML rules.
Explain the purpose and get opt-in before capturing a face.
Document why biometrics are needed and consider less intrusive alternatives.
Notify the CAI before bringing a biometric database into service.
Delete templates once the purpose is fulfilled.
Less sensitive data held, smaller breach impact.
Honour withdrawal and retention schedules in code.
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General information, not legal advice. Last reviewed 2026-09-30. Confirm requirements with qualified counsel.
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