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

13 Pages Posted: 16 Feb 2022

See all articles by Ana Brandusescu

Ana Brandusescu

McGill University

Alan Chan

University of Montreal

Fernando Diaz

Mila

Andrés Ferraro

McGill University

Alex Ketchum

McGill University

Fenwick McKelvey

Concordia University, Quebec

Jimin Rhim

McGill University

Shalaleh Rismani

McGill University

Renee Sieber

McGill University

Jonathan Sterne

McGill University

Yuan Stevens

Toronto Metropolitan University Leadership Lab; Centre for Law, Technology and Society, University of Ottawa; Data & Society Research Institute

Date Written: December 15, 2021

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

Suggested Citation

Brandusescu, Ana and Chan, Alan and Diaz, Fernando and Ferraro, Andrés and Ketchum, Alex and McKelvey, Fenwick and Rhim, Jimin and Rismani, Shalaleh and Sieber, Renee and Sterne, Jonathan and Stevens, Yuan, Comments on the Toronto Police Services Board Proposed Policy on AI Technologies - Montréal Society and Artificial Intelligence Collective (MoSAIC) (December 15, 2021). Available at SSRN: https://ssrn.com/abstract=3987388 or http://dx.doi.org/10.2139/ssrn.3987388

Ana Brandusescu

McGill University ( email )

Montréal, Quebec
Canada

Alan Chan

University of Montreal

Canada

Andrés Ferraro

McGill University

1001 Sherbrooke St. W
Montreal, Quebec H3A 1G5
Canada

Alex Ketchum

McGill University

1001 Sherbrooke St. W
Montreal, Quebec H3A 1G5
Canada

Fenwick McKelvey

Concordia University, Quebec ( email )

1455 de Maisonneuve Blvd. W.
Montreal, Quebec H3G 1MB
Canada

Jimin Rhim

McGill University

1001 Sherbrooke St. W
Montreal, Quebec H3A 1G5
Canada

Shalaleh Rismani

McGill University

Montréal, Quebec
Canada

Renee Sieber

McGill University ( email )

1001 Sherbrooke St. W
Montreal, Quebec H3A 1G5
Canada

Jonathan Sterne

McGill University

1001 Sherbrooke St. W
Montreal, Quebec H3A 1G5
Canada

Yuan Stevens (Contact Author)

Toronto Metropolitan University Leadership Lab ( email )

55 Dundas St W
Toronto, Ontario M5G 2C3
Canada

HOME PAGE: http://ryersonleadlab.com

Centre for Law, Technology and Society, University of Ottawa

57 Louis Pasteur St
Ottawa, Ontario K1N 6N5
Canada

HOME PAGE: http://https://techlaw.uottawa.ca/

Data & Society Research Institute

36 W 20th St, 11th floor
New York City, NY 10011
United States

HOME PAGE: http://datasociety.net

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