Thursday, March 12, 2015

A volunteer student working group sponsored by the Centre for Innovation Law and Policy (“CILP”) at the University of Toronto Faculty of Law has produced a visual representation of Canadian wireless carriers’ privacy policies.

To demonstrate whether each carrier included certain information in its privacy materials, the nine law students adopted transparency criteria originally developed by Andrew Clement (Professor, Faculty of Information, University of Toronto) and Jonathan A. Obar (Assistant Professor, Faculty of Social Science and Humanities, University of Ontario Institute of Technology) for the transparency stream of their IXmaps Project and their 2013 report, “Keeping Internet Users in the Know or in the Dark: A Report on the Data Privacy Transparency of Canadian Internet Carriers.” (PDF)

The working group used the transparency criteria to analyze publicly available information provided by Canada’s “Big Three” wireless carriers (Rogers, Bell, and Telus) and certain of their related brands and companies (Fido, Virgin, and Koodo) (collectively, “the 3+3”), which collectively control 90% of the Canadian market (PDF). The group evaluated how transparent each carrier is about its treatment of its customers’ personal information and third-party requests for disclosures of that information, as well as its positions on privacy and privacy issues.

The students also worked with Professors Obar and Clement to build on, improve, and update the criteria used to evaluate the carriers, including developing explanations to distinguish full, half, and no stars. The updated criteria are also being used to evaluate over 40 Canadian Internet Service Providers (“ISPs”) in a concurrently released 2014 edition of “Keeping Internet Users in the Know or in the Dark”.

The students evaluated the 3+3 by analyzing not only the carriers’ own websites, but also public statements in press releases, relevant news articles, and recent court cases, and developed their own reports.

Finally, the students created an overview chart. The chart, which scores each carrier using the system of no star, half star, or full star on each criterion, is modelled on IXmaps’ previous “star charts”, which are themselves inspired by the Electronic Frontier Foundation’s star charts in its “Who Has Your Back?” reports. In addition, the chart uses hovertext to make additional information about each score available on the chart page when the chart is viewed online.

See the full report and the chart on the CILP website.