Hidden Cameras in Public Spaces: The Quiet Erosion of Privacy in Canada Through "Anonymous" Facial Analytics

AVA Technology

December 12th, 2025

Jason LaFace

As Canadians navigate busy public hubs like Toronto's Union Station, many are unknowingly having their faces scanned by digital billboards equipped with cameras. This technology, known as Anonymous Video Analytics (AVA), claims to collect only aggregated, non-identifying data—such as estimated age, gender, and attention metrics—for tailoring advertisements. But beneath the assurances of anonymity lies a troubling reality: this is biometric data collection without meaningful consent, in spaces where citizens have no practical way to opt out.

As Canadians navigate busy public hubs like Toronto's Union Station, many are unknowingly having their faces scanned by digital billboards equipped with cameras. This technology, known as Anonymous Video Analytics (AVA), claims to collect only aggregated, non-identifying data—such as estimated age, gender, and attention metrics—for tailoring advertisements. But beneath the assurances of anonymity lies a troubling reality: this is biometric data collection without meaningful consent, in spaces where citizens have no practical way to opt out.

This isn't new territory. In 2020, federal and provincial privacy commissioners investigated Cadillac Fairview for embedding similar AVA technology in mall directory kiosks, capturing images of over five million shoppers without proper consent. Regulators found that even if images are deleted quickly and data aggregated, the process involves generating biometric representations of faces—unique patterns that could, in theory, enable re-identification if combined with other datasets.

From a legal standpoint, Canada's Private Sector Privacy Law (PIPEDA) and provincial equivalents require organizations to obtain meaningful consent for collecting personal information, limit purposes to what's reasonable, and minimize data risks. Yet AVA deployments often skirt these by claiming reduced privacy expectations in public settings and true anonymity. However, experts and regulators have repeatedly questioned this: processing facial geometry to infer age or gender is inherently biometric, and re-identification risks persist, especially in low-traffic scenarios or when data is shared with third parties.

What's particularly alarming is the absence of government oversight or public disclosure. There has been no widespread announcement from federal or provincial authorities about the proliferation of AVA in public infrastructure. Citizens pass through these spaces daily—transit stations, malls, streets—without being informed that their facial features are being analyzed for commercial gain. This silent rollout echoes broader patterns of surveillance in Canada over the past decade, where government agencies have expanded monitoring capabilities with limited transparency.

For instance, revelations from the 2010s onward exposed Communications Security Establishment (CSE) and CSIS activities involving bulk data collection on Canadians' metadata, often incidentally captured during foreign intelligence operations. High-profile cases, such as the use of spyware like Pegasus on domestic targets or warrantless access to subscriber data by law enforcement, have raised flags about overreach. While not directly tied to AVA, these incidents underscore a culture where surveillance technologies advance faster than public awareness or safeguards, eroding trust in both private and public institutions.

The Union Station case has escalated: as of December 2025, Canada's Privacy Commissioner, Philippe Dufresne, has launched a formal investigation following public complaints sparked by social media posts. This probe examines whether the deployments comply with privacy laws, amid calls for stronger regulations on biometric technologies—something many U.S. cities have already implemented through bans.

But investigations alone aren't enough. "Anonymous" or not, this technology normalizes constant facial scanning in everyday life, paving the way for more invasive uses, like linking to payment systems, loyalty programs, or even law enforcement databases. The line between commercial analytics and full facial recognition is thin, and once the infrastructure is in place, mission creep is inevitable.

Canadians cannot afford complacency. We must demand action:

• Contact your MP and provincial representatives to push for explicit bans or strict regulations on biometric data collection in public spaces without express, informed consent.

• File complaints with the Office of the Privacy Commissioner of Canada if you encounter undisclosed AVA or similar tech.

• Support advocacy groups like OpenMedia and the Canadian Civil Liberties Association in their fights for stronger privacy protections.

• Raise awareness by sharing stories and demanding transparency from companies like Cineplex Digital Media and transit authorities.

  
  

Our faces are not commodities for targeted ads. Privacy is a fundamental right, not a relic of the pre-digital age. It's time to reclaim control before surveillance becomes inescapable. Speak up now—before the cameras capture more than just demographics.