Right2YourFace Coalition open letter declaring Bill C-27 "dangerous" and calling for FRT moratorium (1 November 2023)

On 1 November 2023, the Right2YourFace Coalition — a Canadian national civil-society coalition anchored by the Canadian Civil Liberties Association (CCLA) and comprising privacy, civil-liberties, academic, and digital-rights organisations — published an open letter addressed to the Minister of Public Safety, the Minister of Innovation, Science and Industry, and the Standing Committee on Industry and Technology (INDU), declaring the government's proposed Bill C-27 "dangerous" for its failure to adequately regulate facial recognition technology (FRT) and explicitly calling for a moratorium on FRT pending adequate legislation. The letter is the corpus's first event anchored in Canada and its first national civil-society coalition action on FRT regulation.

Coalition formation and mandate

The Right2YourFace Coalition launched in June 2023 as a public awareness campaign coordinated by the CCLA and allied civil-society groups, anchored at right2yourface.ca. The coalition's founding position — articulated from launch — was that "the question is not how or when to use facial recognition, but if": a moratorium-first posture arguing that no adequate regulatory framework existed under which FRT use could proceed responsibly. An initial June 2023 open letter called for a federal moratorium on FRT use by federal policing services and Canadian industries, and named Bill C-27 — the government's proposed omnibus privacy and AI legislation — as the vehicle the coalition would scrutinise for legislative adequacy. The November 2023 letter delivered that scrutiny.

The signatories on the November letter were the Canadian Civil Liberties Association, the Privacy and Access Council of Canada, the Ligue des droits et libertés, the International Civil Liberties Monitoring Group, the Criminalization and Punishment Education Project, The Dais at Toronto Metropolitan University, Digital Public, Tech Reset Canada, and the BC Freedom of Information and Privacy Association, with additional signatories listed in the full letter document. Brenda McPhail of the CCLA served as the coalition's primary public spokesperson for the November campaign and as a member of the coalition's Steering Committee.

Bill C-27 and the coalition's critique

Bill C-27 — formally An Act to enact the Consumer Privacy Protection Act, the Personal Information and Data Protection Tribunal Act and the Artificial Intelligence and Data Act — bundled two pieces of legislation directly relevant to the coalition's concerns: the Consumer Privacy Protection Act (CPPA), which would replace Canada's existing federal private-sector privacy law (PIPEDA), and the Artificial Intelligence and Data Act (AIDA), Canada's proposed AI-specific regulatory framework.

The coalition's central critique was structural: the bill "irresponsibly prioritises the rights of businesses over individuals" and had failed to address the Standing Committee on Industry and Technology's own Recommendation 18, which had called for a federal moratorium on FRT use by federal policing services. Brenda McPhail framed the argument pointedly: "Exceptions in the Consumer Privacy Protection Act and public sector exclusions in the Artificial Intelligence and Data Act mean Bill C-27 fails that test" — "that test" being whether the legislation provided protections adequate to the rights at stake when government and private actors deploy FRT against the public.

The letter named five specific structural failures and corresponding legislative demands:

1. Biometric data classification. The CPPA did not explicitly classify biometric information as sensitive data, which the coalition argued would leave it subject to the same consent and purpose frameworks that governed less invasive categories of personal information. The coalition demanded explicit statutory classification of biometrics as sensitive.

2. Legitimate-business-purpose exemption. The CPPA's broad exemption for "legitimate business purposes" lacked meaningful definition, the coalition argued, creating a gap wide enough to permit commercial FRT deployments — in retail, venue management, and employment — without adequate consent requirements. The coalition demanded the exemption be narrowed with FRT-specific restrictions.

3. High-impact system definition. AIDA's obligations for "high-impact AI systems" depended on a definition the bill left to future regulations rather than statute. The coalition demanded the definition be placed in the legislation itself and that it explicitly capture FRT as a high-impact system, rather than leaving that determination to regulatory discretion after the bill passed.

4. Public-sector AIDA coverage. AIDA as drafted applied to private-sector actors but excluded government institutions, law enforcement agencies, and national security agencies — the public-sector actors the coalition regarded as posing the most significant FRT risks. The coalition demanded extension of AIDA's core obligations to those excluded actors.

5. Collective harm assessment. AIDA's harm framework was individual-focused, which the coalition argued was structurally inadequate for FRT's systemic effects. FRT accuracy disparities — documented as "consistent" across racialized individuals, children, elders, LGBTQ+ community members, and disabled people — manifest as collective harms to identifiable populations rather than as disaggregated harms to named individuals. The coalition demanded AIDA incorporate collective harm assessments alongside individual harm calculations.

Moratorium demand and legislative context

Beyond the five structural amendments, the letter explicitly called for a moratorium on facial recognition technology pending enactment of adequate regulatory protections — carrying forward the coalition's founding June 2023 demand into the November Bill C-27 debate. The moratorium-plus-amendment dual structure placed the coalition in a position distinct from simple legislative lobbying: the moratorium demand named a pause, and the amendment demands mapped the legislative path that would justify ending it.

The November 2023 letter was issued during a period when Innovation Minister François-Philippe Champagne was actively proposing amendments to Bill C-27. Civil-liberties groups, including Right2YourFace coalition members, characterised those amendments as insufficient and called additionally for AIDA to be reset and reworked as standalone AI legislation rather than bundled inside a broader privacy reform bill.

Significance for the corpus

The 1 November 2023 Right2YourFace Coalition letter is the corpus's first event anchored in Canada and its first national FRT-specific civil-society coalition action. It extends the corpus's biometric-surveillance advocacy register — which includes the UK's Big Brother Watch-led joint statement on live facial recognition (6 October 2023, three weeks earlier) and the Brazilian Coding Rights anti-FRT campaign — into North America's federal legislative terrain, and specifically into Canada's distinctive bilingual, francophone-and-anglophone civil-society organising space (the Ligue des droits et libertés is Québec's principal civil-liberties organisation, giving the November letter a cross-linguistic coalition dimension unusual among the corpus's biometric-surveillance events).

The coalition's dual-demand structure — moratorium plus specific legislative amendment asks — is the corpus's clearest example of a civil-society coalition simultaneously demanding a regulatory pause and specifying the legislative path that would end it. This is a materially different rhetorical form from the UK joint statement's single "immediately stop" demand, and from the EU AI Act civil-society campaigns' amendment-only posture: it positions the coalition as both a movement actor and a legislative drafter, a combination the corpus would expect to see more of as national AI regulatory processes matured in 2023–24.