Letter to the Federal Minister of Health, Jean‑Yves Duclos, On Shifting ArriveCAN from Mandatory to Voluntary Use
July 8, 2022
I write to you today to ask that the Public Health Agency of Canada direct the Canada Border Services Agency to shift use of ArriveCAN from a mandatory to a voluntary process.
As evidenced by today’s Rogers outage, we know there is a process that could be used at our borders as an alternative to the use of ArriveCAN.
At this stage in the pandemic, it’s important to adapt and adjust our responses to continually improve our technology stewardship. It was an encouraging sign to see the COVID Alert app decommissioned. In this case, with ArriveCAN, the government can make a different kind of adjustment by allowing those that want to use ArriveCAN to continue doing so, and to also provide another process for those that do not want to use a mobile app/web app. From a responsible technology stewardship perspective, it’s the right choice to extend agency to how we share our information at the border.
In support of this request, please see the following, which was part of the 2020 Joint Statement by Federal, Provincial and Territorial Privacy Commissioners about contact-tracing technology deployed during a public health crisis:
“Consent and trust: The use of apps must be voluntary. This will be indispensable to building public trust. Trust will also require that governments demonstrate a high level of transparency and accountability.”
Shifting the app from mandatory to voluntary use, while opening up an alternative process, still allows the Public Health Agency of Canada to collect and use data as per the Quarantine Act.
The app has never been the driver of that data use, it has only ever been a vehicle to provide it. In future, I hope we’ll do more due diligence on why or why not to use apps in crisis, and if so, how. We need to establish a comprehensive governance framework for decisions about technology that will help guide us through a technology’s life-cycle, a process that was not in place for this app and one we should be creating as soon as possible. We also need to see improvements on transparency, oversight, and accountability.
In closing, we know how much equity matters in public health and public service provision. We need to consider if and how we can create as much comfort and safety for everyone travelling in this moment, and always. I have had several people in my life share fear, uncertainty, lack of technology access, and other issues related to ArriveCAN. Should the government want to continue to use technology in how it modernizes our services, we have to make sure that equity is as fundamentally important as efficiency.
Thank you for your consideration. I’ll be sending a letter to your colleague Minister Mendicino as well as I know the Canada Border Services Agency is the formal business owner of the app.