Comments on the Toronto Police Services Board Proposed Policy on AI Technologies - Montréal Society and Artificial Intelligence Collective (MoSAIC)

Abstract

This is Montréal Society and Artificial Intelligence Collective (MoSAIC)'s submission to the Toronto Police Services Board 2021 public consultation for its draft policy on the use of artificial intelligence technologies. We provide key recommendations regarding evaluation, explainability, use, procurement, and development of AI and make the following points:

Any implementation of AI technologies by law enforcement needs to begin from the assumption that it cannot reliably anticipate all the effects of those technologies on policing or policed communities and act accordingly in light of these impacts. Toronto Police Services (TPS) policy should approach AI with caution, reflecting a greater rigour and transparency than at present, and with greater rigour and transparency than currently proposed. The TPS must prioritize consideration of and prevent any potential infringements of the Canadian Charter of Rights and Freedoms before they occur. The proposed "Extreme Risk" category is actionable immediately. The long timeline to phase out Extreme Risk technologies (2024) is unacceptable and allows for the continued use of presumably illegal technologies in the Toronto Police Services. An immediate review should be undertaken by the Police Chief to identify Extreme Risk AI technologies in operation. Any Extreme Risk Technologies should be immediately retired, including biometric recognition technologies.

Keywords: artificial intelligence, police, explainability, evaluation, procurement, human rights