CRTC public submissions and privacy

Raw Sugar window and Somerset Street

Quite conveniently, the Canadian Radio-television Telecommunications Commission allows citizens to comment on ongoing matters through their website. Unfortunately, the privacy protections employed in relation to the submissions are lacking. Their website says the following:

The information you provide to the Commission as part of a public process (i.e. comments, interventions or observations) is entered into an unsearchable database dedicated to that specific public process. This database is accessible only from the webpage of that particular public process. As a result, a general search of our website with the help of either our own search engine or a third-party search engine will not provide access to the information which was provided as part of a public process.

This doesn’t seem to be true. Searching for my own name in Google brings up the submissions I made to them opposing Bell’s efforts to introduce Usage Based Billing (UBB). The submission includes my full name, personal email address, and phone number.

I complained electronically to the CRTC about this, but got no response. I then sent a letter to the Office of the Privacy Commissioner, with a carbon copy to them. At the very least, the CRTC should obscure email addresses and phone numbers in a way that prevents robots from harvesting them. For instance, obfuscated email addresses can be made to look normal for standard browsers, but like gibberish for most robots. Alternatively, the CRTC could provide a web contact form that lets people contact submitters, without learning their email address. I have no problem with submissions being made public, in the interest of transparency. If it is going to happen, however, people should be clearly informed about it on the page where they submit the information (not some separate privacy information page) and reasonable efforts should be taken to prevent the inappropriate collection of personal information by either people or automated systems.

[Update: 7 August 2009] The CRTC responded to my complaint, and it seems they have come into compliance with their privacy policy.

Author: Milan

In the spring of 2005, I graduated from the University of British Columbia with a degree in International Relations and a general focus in the area of environmental politics. In the fall of 2005, I began reading for an M.Phil in IR at Wadham College, Oxford. Outside school, I am very interested in photography, writing, and the outdoors. I am writing this blog to keep in touch with friends and family around the world, provide a more personal view of graduate student life in Oxford, and pass on some lessons I've learned here.

7 thoughts on “CRTC public submissions and privacy”

  1. I got an email from Nancy Gauthier at CRTC.

    She says they “have fixed a problem with our database, and information in your comment is now unsearchable as stated in our Privacy Policy. Your comment isn’t indexed by Google anymore. We apologize for any inconvenience this situation may have caused to you.”

    This seems correct. I can’t find it thought Google anymore.

  2. The CRTC ruled in favor this week for usage-based billing. Bell Canada was given a monopoly on lines in Canada, and in exchange they were made to resell to competitors at cost in order to have a functional market. The new CRTC ruling will allow Bell to charge their competitors more money based on individual customer usage. They are now able to implement a 60GB cap on a competitor’s highest speed lines (charging $1.12/GB for overages). The effect on the market seems clear.

  3. Canada’s telcoms regulator gives bloated, throttling incumbent the keys to the kingdom

    Cory Doctorow at 12:15 AM Saturday, Oct 30, 2010

    The CRTC, Canada’s telcoms regulator, had handed Bell Canada, the incumbent former state monopoly, a giant, giftwrapped early Christmas present. Bell — whose infrastructure was built with tax-dollars — is required to share its lines with independent ISPs, so that there can be competition in Canada’s ISP market. Bell itself provides a distinctly inferior sort of retail ISP service, with secret throttling and filtering (“traffic shaping”), as well as bandwidth caps, making Canada one of the worst places to get network access in the developed world.

    But Bell’s competitors have responded by competitive offerings that deliver a neutral network — one that gets you the bits you asked for, as quickly as possible. But that’s not going to last.

    The new CRTC ruling allows Bell to charge the same rates to its resellers that it charges to its retail customers — in other words, a third party ISP will pay the same to buy a line as one of Bell’s customers would (meaning that they have to charge more than Bell charges in order to turn a profit). And Bell will be allowed to impose the same network filters and throttling on these ISPs as it subjects its own customers to.

  4. Canadians: sign petition against mandatory per-byte billing for ISPs!

    Steve from Openmedia.ca sez, “As result of a recent decision by Canada’s telcom regulator, the CRTC, Bell Canada and other big telecom companies can now freely force Internet usage-based billing on YOU and indie ISPs. This means we’re looking at a future where Internet providers will charge per byte, the way they do with smart phones. If we allow this to happen Canadians will have no choice but to pay more for less Internet. This will crush innovative services, Canada’s digital competitiveness, and your wallet. Canadians should sign the Stop The Meter petition!”

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