The Surveillance Party of Canada (SPOC) is committed to the principle that Canadians should be monitored and tracked as extensively as possible in order to advance critical public policy goals. We believe that our streets and homes can be safer, our health care system more efficient, our educational institutions more effective, our businesses more profitable and technological innovation more vibrant, if public bodies and private corporations were allowed to collect, retain, analyze and disseminate almost any personal data without restriction. After all, if individuals have nothing to hide, then they should have nothing to fear.
We believe that the Canadian public interest and our economic prosperity have been unnecessarily constrained in Canada by overly restrictive, self-serving and pointless privacy laws. We call for the repeal of all such laws.
Our previous privacy policy was developed on June 29, 2023 in conformity with the 2018 Elections Modernization Act, as amended by S. 39 of the 2023 Budget Implementation Act. We have now amended that policy in response to the tabling in March 2024 of Bill 65 (An Act to amend the Canada Elections Act). In this policy, we describe how we collect, use and disclose personal information on Canadian voters and non-voters. We also believe our policy is consistent with the joint guidance issued by the Chief Electoral Officer and the Privacy Commissioner of Canada. We have, however, overridden their advice to craft a policy consistent with so-called “international standards” favoring a made-in-Canada approach better attuned to the security interests of Canadians.
As directed, this policy is written in plain language (really plain language!) and will be made publicly available in both official languages, as one of the conditions of our registration as a federal political party. We will inform the Chief Electoral Officer of any future changes to this policy.
POLICY FOR THE PROTECTION OF PERSONAL INFORMATION
For the purposes of this policy, and consistent with the recent amendment to the Canada Elections Act contained in the recent Budget Implementation Act and Bill 65, personal information means “information about an identifiable individual” (Sec. 384.9)
Further, and according to Sec. 444.2 of Bill 65, SPOC understands that: “In order to participate in public affairs by endorsing one or more of its members as candidates and supporting their election, any registered party or eligible party, as well as any person or organization acting on the party’s behalf, including the party’s candidates, electoral district associations, officers, agents, employees, volunteers and representatives, may, subject to this Act and any other applicable federal Act, collect, use, disclose, retain and dispose of personal information in accordance with the party’s policy for the protection of personal information.”
Accordingly, and in compliance with the requirements of Section 444.4 of Bill 65, (reproduced in italics below) we hereby:
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(a) Designate a privacy officer who is responsible for overseeing the party’s compliance with the policy; and
(b) Include the name and contact information of the privacy officer;
Within the SPOC, it has been challenging to appoint an individual who has either the expertise, interest or desire to perform the role of privacy officer. Anybody who wishes to ask questions about this policy should, therefore, write to our Chief Security Officer, Mr. U.R. Caughtoncam at: security@surveillanceparty.ca. He will make the appropriate judgements about your concerns and possibly respond to your inquiry in a timely fashion.
(c) State the types of personal information that the party collects, retains, uses, discloses and disposes of; and
(d) Explain, using illustrative examples, how the party collects, retains, uses, discloses and disposes of personal information, such as by indicating whether it does so in the context of online activities or through the use of cookies;
The SPOC collects any personal information it can get its hands on or about any Canadian citizen or resident. This may include (but is not limited to):
Basic name and address information provided by Elections Canada in advance of each election. Like other federal political parties (FPPs), we combine this address information with other contact information purchased from Directory services such as Canada 411. Like other federal political parties, we employ this information as the framework for our Voter Relationship Management (VRM) system to which we add personal information from the following sources.
Information collected during canvassing. Our team of canvassers is trained to record your responses to their questions, to enter any other information observed about the household (e.g. the presence of children; the type of car on the property; the presence of an alarm system or security camera; any religious symbols; and any other information that might reveal political leanings, values or attitudes). This information is transferred to our Voter Relationship Management system via our dedicated smart phone app – MINIEYE.
Information scraped from social media. We employ data broker companies to capture personal information entered on social media sites such as Twitter, Instagram, Facebook (Meta), and Tiktok. We believe that this information is public information and can legitimately be harvested and analyzed by organizations such as SPOC.
Information revealed through polls, surveys and petitions — either conducted by ourselves or by third parties.
Information purchased from commercial data brokers. SPOC is particularly interested in individuals who may have purchased: household alarm systems; webcams; nanny cams; and other devices for monitoring people and possessions.
Similar to other FPPs, we use this information to profile the entire Canadian electorate and to score each individual on a 10-point scale ranging from the extreme civil libertarian/privacy advocate on one end of the scale (-5) to the security/surveillance sympathizer (+5) at the other. We use this proprietary profiling system to prioritize our resources, and to identify those individuals who might be most persuadable by a pro-surveillance or pro-security message. We then serve those individuals carefully crafted micro-targeting via social media channels, emails, texts and other media.
Similar to other FPPs, we also transfer membership and donor lists to Facebook for the purpose of constructing LookAlike audiences, to whom we target relevant messaging. SPOC collects information about anyone who follows us on Twitter, friends us on Facebook, emails us, or otherwise contacts us through our website. We also capture information on followers and friends (your social graph). Cookies from ourselves, and our third-party data analytical companies, will be logged on your computer whenever you visit our website. These are used to measure audience engagement and to understand how our party can enhance the quality of the services and information provided on our website. Non-personalized ads may then be delivered based on the content you view and your location. Personalized content and ads may be delivered with more relevant results and recommendations, based on your past engagement on our website or online activity more generally. We also use cookies and data to tailor the experience to be age, gender and ethnically appropriate.
In keeping with standard business practice and the prevailing surveillance ethos of “the better we know you, the better we can serve you,” tracking on-line behavior by any means possible is the default. You can turn off the tracking mechanisms, but we advise against this because it is not in our interest, and we believe not in yours either. For this reason we don’t make the “Off” switch easy to find, nor does it disable all forms of tracking. If you insist on proceeding further, go ahead, but it isn’t easy. Besides, you are probably not going to vote for us anyway.
(e) describe the training related to the protection of personal information that is offered to the party’s employees and volunteers who may have access to the personal information that is under its control;
SPOC’s volunteers are trained in various techniques to solicit the personal opinions of Canadians on political issues. These techniques include basic snooping during door-to-door canvassing; subtle encouragements during telephone marketing; and trolling social media sites and chat rooms for likely supporters. As soon as this information is captured, our employees and volunteers are trained in various methods to keep this information strictly under the party’s control.
(f) require the party to protect the personal information that is under its control through physical, organizational and technological security safeguards with a level of protection proportionate to the sensitivity of the personal information;
We regard the information captured by the SPOC as our proprietary data, and therefore take strong measures to protect it from unauthorized access. These measures include: password protected access controls for staff and volunteers; strong encryption when data is in transit and in storage; and physical measures at campaign offices.
(g) require the party to take appropriate steps in the case of the loss of, unauthorized access to, or unauthorized disclosure of personal information that is under its control as a result of a breach of its security safeguards, including by, as soon as feasible, informing the individual whose personal information has been lost, accessed or disclosed if it is reasonable in the circumstances to believe the breach creates a real risk of significant harm to the individual;
In the very unlikely event that a data breach occurs from SPOC, we will inform all individuals as soon as feasible. We will probably do this by means of robocalling or robotexting, using random number generated calling devices. It is unlikely, however, that we would reach a judgement that there would, in the circumstances, be “significant harm to the individual”, based on the sensitivity of the data and the probability that it will be misused (Sec. 444.4 (2)). In any event, that is our call, rather than that of the individual or of any regulator.
(h) require the party to ensure, by contract or otherwise, that any person or entity to which it transfers personal information provides a level of protection of the personal information equivalent to that which the party is required to provide under the policy;
We contract with a variety of organizations to process personally identifiable information on our behalf. We use contractual measures to ensure that the exceedingly low level of protection provided by this policy is also provided by those organizations.
(i) require the privacy officer or their delegate to attend at least one meeting per calendar year relating to the protection of personal information held by the Chief Electoral Officer; and
A delegate of the privacy officer plays a regular game of golf with a senior official in Elections Canada and has the opportunity to discuss the issues described in this policy on those occasions.
(j) prohibit the party, as well as any person or entity acting on the party’s behalf, including the party’s candidates, electoral district associations, officers, agents, employees, volunteers and representatives, from
(i) providing false or misleading information to individuals about the purposes for which the party collects personal information,
This policy declares openly that we collect as much information as possible from as many sources as possible in order to communicate with voters who may, or may not, be sympathetic to our mission. We are careful never to provide “false or misleading information to individuals.” Our purposes are broad, openly stated, and self- evidently designed to capture as much information as possible from Canadians.
(ii) selling personal information under the party’s control, or
We used to sell personal information to various companies in the security industry (as stated in our prior privacy policy). But this was never lucrative, so we are now happy to comply with this new provision.
(iii) disclosing personal information under the party’s control to the public for the purpose of causing harm.
As stated above, we disclose personal information under our control to a variety of organizations for the purposes of communicating a pro-security and pro-surveillance message and agenda. What can possibly be harmful about that?
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Please also note that nothing in the Canada Elections Act, nor any other federal statute, obliges us to allow individuals to access their personal information, and to correct it if it is inaccurate, incomplete or obsolete. Any such requests will be ignored by the SPOC.
Please also note that should we fail to comply with the provisions of this policy, we will be in violation of the Canada Elections Act and subject to an administrative monetary penalty of up to $5000 (Sec. 508.5 (1)). Anyone believing that we have violated the policy may try to complain to the Commissioner of Canada Elections, who is under no statutory obligation to conduct an investigation, or otherwise respond to your complaint.
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Developed and submitted pursuant to Canada Elections Act, S.C. 2000, c. 9, ss. 385(2)(k),385(4), 385.1 (as amended by Bill 65). This privacy policy has been approved by the SPOC board of directors, and approved by legal counsel as being consistent with our obligations under the Elections Act — assuming that Bill 65 is rammed through Parliament in a timely fashion.
For added clarity, this post is “manifestly distributed, transmitted or published for the purpose of parody or satire” (Canada Elections Act, Sec. 481(3))
(AMENDED APRIL 1, 2024)
