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Privacy Policy – COVI app

Thank you for downloading the COVI app by COVI Canada (“COVI Canada”) and helping Canada’s response to COVID-19. Download and use of the COVI app is strictly voluntary. No third party may compel download or use of the app and no individual shall be denied access to any place or service on the basis that they have not downloaded or are not using the app. All information generated from the use of the app is for the exclusive use of the app user. No third party may request access to information generated from the use of the app, including to deny access to any place or service.

Who is COVI Canada?

COVI Canada is an independent, not-for-profit organization created to manage the data collected by the COVI app and oversee its ongoing development, following the initial development of the application through a coalition of Canadian researchers, data scientists, privacy experts, software developers, behavioural psychologists, epidemiologists and healthcare professionals led by Mila – The Québec Artificial Intelligence Institute. Please visit covicanada.org for more information.

What is the purpose of the COVI app?

The COVI app aims to use artificial intelligence-based contact tracing and risk assessment of exposure to COVID-19 to alleviate the outbreak. In a nutshell, the COVI app uses tracing history gathered through your use of the COVI app (i.e. when and where your device has encountered another device using the app), as well as demographic and health-related information you provide, to assess your risk of COVID-19 exposure and recommend courses of action to take in light of your risk score. This is done in order to contain the spread of the disease by giving you advice (e.g., begin to monitor symptoms carefully and/or seek out official testing) if your own risk level changes in light of having come into contact in the past with another user who is now known to present high risk of spreading infection.

The purpose of the COVI app is not to blame or identify particular users, but rather to provide them with the information they need to minimize the risk of being contaminated by the virus or contaminating others.

This COVI app was developed with a strong focus on privacy and uses a technology that, while tracing contacts between app users, is designed not to reveal the identity of app users behind such contacts or any other identifiable information about such users. COVI Canada is independent of the government and only shares aggregated and statistical information collected through the COVI app with public-health authorities, as further detailed in this Privacy Policy.

What personal information does the COVI app collect and why?

“Personal information” generally refers to any information about an identifiable individual. It does not include information that is aggregated or de-identified so that it can no longer identify you.

The COVI app does not collect your name or other direct identifiers, but it does collect the following information:

  • Demographic, health-related and behavioural information you provide. The COVI app collects demographic information (age and gender), health-related information (health conditions and symptoms), and behavioural information (e.g. if you are using a mask), which you provide when you install the COVI app and may update as you use it.
  • Geolocation and contact ID information collected through your use of the COVI app. The COVI app collects geolocation information and information related to your contact with other COVI app users based on your device’s GPS position and/or randomly generated IDs through your device’s Bluetooth function (or similar technologies allowing the collection of information about device location and/or proximity with other devices).
  • Test results you provide. If you have tested positive for COVID-19, you may input your official test result in the COVI app.
  • Information we collect automatically about your use of the app. The COVI app collects information about how you interact with the app, which is accessed by us for data analytics purposes. This information allows us to understand how widely the app has been adopted and how its features are being used. Some of this analytics information, such as information that tells us whether the recommendations made by the COVI app are having an impact on users’ risk score, will only be collected and used by us if you opt-in to allowing COVI Canada to access your information as further described below.
  • Additional information about which we may inform you as we continue updating the COVI app. As we continue to develop and update the COVI app to respond better to the COVID pandemic, we may develop new features that require the collection of additional information. In this case, we will inform you of new personal information being collected and we may seek your express consent when necessary.

Your demographic information, health-related information, behavioural information, geolocation and contact history inform the COVI app of your risk of exposure (for instance, your risk will vary depending on whether you report symptoms to the app, whether you were in contact with someone who has tested positive, or the frequency at which you leave your residence and the places you visit). Because the accuracy of this information is crucial for the proper assessment of all app users’ risk of exposure, when users sign up for the app, we request that they undertake and commit to providing accurate information.

If you provide consent through the COVI app, COVI Canada accesses this information by giving each user a randomly generated pseudonym, which means that we cannot link it to a particular and identifiable app user. We use this information only for purposes related to protecting public health and containing the spread of COVID-19. Granting us access to this information is optional. While this information is necessary to train our artificial intelligence-based risk assessment model (i.e. improving our prediction engine) and ensure that the COVI app is able to assess users’ risk of exposure as accurately as possible, we estimate that a sufficient proportion of users will decide to grant access to us and participate in the COVI app’s effort to contain COVID-19.

We may de-identify information collected through the COVI app so that it is no longer considered to be personal information and use this information for further research purposes relating to the public health crisis (for instance, to improve the understanding of the disease or to assist public policy strategies during this public health crisis).

Is my personal information shared with any third parties?

We only share limited information from app users as follows:

Service Providers. We only make your personal information collected through the COVI app available to service providers that we may retain to perform certain tasks related to the COVI app, for instance hosting the information or performing security enhancing functions. We require these service providers to limit their access to, and their use of personal information, to what is required to provide their services and require that those third parties adhere to confidentiality as well as security procedures and protections, in compliance with applicable Canadian privacy laws

Aggregated information. We do not share your personal information with government authorities. However, we may extract aggregated information from the information collected (so that it is no longer personal information) and share it with other entities, including public health authorities, but only when relevant to understand and respond to the COVID-19 pandemic. For instance, public health authorities may use this data for the purpose of epidemiological analysis and research (such as making decisions regarding allocation of resources and containment of the virus) and other non-government entities may use it to inform Canadians about the pandemic.

We will otherwise only share information if we are required to do so by law, but will under no circumstances be able to reveal the time and place of your movements.

Can children use the COVI app?

The COVI app is limited to users 13 years of age and over. If you are under the age of 13, you are not authorized to download and use the COVI app. Users who have not reached the age of majority in their province or territory of residence must have the consent of their parent or legal guardian in order to use the COVI app when required by law. In any event, for such users, the COVI app only collects geolocation and contact ID information through their use of the app.

How does the COVI app protect my personal information?

The COVI app was developed with a strong focus on privacy and security. No technology is 100% secure against sophisticated hacking, but the COVI app uses robust measures to protect the privacy of our users.

All information stored by COVI on your device is encrypted, and geolocation information recorded for contact tracing is processed using a hash function to protect it from inspection. The COVI app uses a private messaging system designed to ensure that your tracing information (i.e. when and where your device has encountered another device using the app) cannot be shared with government authorities, users of the COVI App or other third parties, and prevents them from identifying you.

The risk assessment calculation is made directly on your device. Only risk scores are communicated to the messaging system, for use by other users’ copies of the application to calculate their own risk on their own device.

Your test results are never shared with your contacts directly. Those results allow the COVI app to assess the risk of exposure of other users who you may have encountered since you began using the COVI app, but only through recalculating your risk assessment and alerting your contacts that they now face increased risk.

Moreover, we only access demographic and health-related information for training the artificial intelligence-based risk assessment model in a way that is not traceable to the originating user. The COVI app is designed so that nothing that identifies you (for instance, source IP address or other ID associated with you) will be communicated to us.

Where is my personal information stored?

As long as you are using the COVI app in Canada, your demographic information, health-related information, behavioural information, geolocation and contact history will remain in Canada at all times. Like most mobile applications, some technical information about the devices of users who have downloaded the app (such as IP addresses) may be transferred to countries outside of Canada through service providers who are using servers in other countries. Personal information transferred to countries outside of Canada is subject to applicable laws in these countries and may be made available to government authorities under these laws. While this remains a possibility, we are putting strong technical measures in place to reduce the risk of users’ personal information being accessed by governments (our cryptographic protocols are designed to prevent governments from decoding the tracing information being exchanged between devices, even if devices are in different countries).

How long will my personal information be kept?

Users’ personal information will be kept only as long as it is useful to assess the risk of exposure of the COVI app users. For instance, encrypted location information will be deleted from the COVI app on a rolling basis (for now, we are using a 30 day interval, but this is subject to change depending on recommendations by the scientific community regarding the period of contagion). Health conditions, symptoms and demographic information will remain on users’ devices throughout the pandemic as this information is required to calculate each user’s risk of exposure score. Note that you may at all times delete the COVI app, at which time all the information residing on your app will also be deleted.

In any event, once the pandemic has been declared to be over by Canadian public health authorities, all information about users will be deleted from the COVI app while COVI Canada may only retain aggregated or de-identified information.

How can I access or correct my personal information?

You can use the COVI app to update your demographic information, health conditions, behaviour and symptoms so that they remain accurate.

Who can I contact with privacy questions?

If you have any privacy-related questions about the COVI app, please contact us at: privacy@covicanada.org.

Effective date: 24 April 2020