Guelph Smart City Challenge Prize: Privacy Implications

by Sara Bannerman

By Serguei Tabatchenko, CIPPIC Intern

What is the plan?   

Using the smart city challenge funding, Guelph wants to rethink the current take-make-dispose food model and become Canada’s first technology-enabled Circular Food Economy. Guelph’s final application, called “Our Food Future”, envisions a project implemented through 3 measures: making affordable and nutritious food 50% more accessible, creating 50 new circular businesses and collaborations, and using waste as an economic resource to produce a 50% increase in circular revenue (p 2). Guelph’s video calls these its “3 Bold Goals” that it aims to achieve by 2025.

    Guelph’s geographical location and existing infrastructure make this plan realistic. Located in the “innovation corridor”, the region enjoys a concentration of universities with world-renowned agriculture and agri-innovation programs, and headquarters of high-tech companies as well as provincial agriculture and food organizations (p 2). As well, the project will be supported by collaborations with national and provincial food industry partners like Provision Coalition, Bioenterprise and the Ontario Federation of Agriculture (p 5). Guelph will also work with other smart cities, foundations and think tanks to improve the international development of circular economies (p 2). It’s worth noting that this project involves engagement of Guelph residents, who contributed to the Smart Cities Challenge application by providing input on ideas through a dedicated website (p 11).

What is the tech? What are the privacy expectations?

    To make affordable and nutritious food more accessible, Guelph is planning on implementing asset and behaviour mapping to identify geographic and demographic priorities within the community (p 12). Furthermore, Guelph will use big data analytics, open data portal technology and Geographic Information System (GIS) technology to create a Food Security & Health Action Plan (p 13). These measures raise some concerns over anonymity because behaviour mapping can compromise people’s movement and locations, which carry privacy implications. Furthermore, although Guelph is to use big data analytics for a non-commercial purpose, such activity results in commercially useful data and could potentially be subject to PIPEDA, Canada’s federal private sector privacy legislation, especially if the work is outsourced to a private company (see our project report authored by Keri Grieman, Smart City Privacy in Canada, p 11).

To establish 50 new circular businesses, Guelph will use open governance and promote new partnerships and start-ups through its Civil Accelerator website, where projects can get exposure, feedback and funding from citizens (Our Food Future, p 7). Focusing on open governance is an important factor in Guelph’s smart city development that ensures projects receiving funding will be the most desired, useful and effective ones for the Guelph community. In addition, international smart cities like Barcelona have employed open governance to successfully improve citizen participation and streamline administrative processes, so this move is a step in the right direction (see, e.g.,  Decidim, for example, cited at Our Food Future, p 64).

To increase circular revenue by 50%, Guelph plans on developing new business diagnostics to help organizations and private actors create value from waste by-products. This will involve using the Provision Coalition’s data platform and applying blockchain technology (Our Food Future, p 32). If the Provision Coalition’s data platform serves a commercial purpose and not a public or educational purpose, Guelph would need to make sure subsequent use of the data is compliant with PIPEDA (see Smart City Privacy in Canada, p 8). In addition, Guelph will attempt to create a digital marketplace powered by blockchain technology to help businesses buy and sell carbon offsets (Our Food Future, p 42). Here, privacy compliance will depend on whether facilitation of online transactions is classified as commercial activity. It is likely that unless there is a monetization aspect to Guelph’s administration of the marketplace, collection of user information to ensure proper administration of a municipal service will not require PIPEDA compliance (see Smart City Privacy in Canada, p 11). Commercial entities engaging in marketplace transactions, on the other hand, will plainly fall under the purview of PIPEDA.  Finally, the city will use RFID technology to map the cycle of food waste and create data points for analytical purposes (Our Food Future, p 34). While jurisprudence shows people don’t have an expectation of privacy with regards to their waste or garbage, the city would be wise to de-personalize such data to uphold general expectations of privacy, especially outside the criminal law context.