Licence Plate Readers Are Expanding Across Canada. Is Your Privacy Program Ready?

Across Canada, automated licence plate recognition (ALPR) technology is becoming more common. Once used primarily in policing programs, licence plate readers are now being deployed more broadly to support public safety, traffic management, law enforcement investigations, and other municipal and public-sector objectives. As adoption increases, so too does the public conversation about transparency, surveillance, and privacy.

For public-sector organizations, the question is not simply whether licence plate readers can deliver operational benefits. The more important question is whether the organization has the privacy governance, transparency measures, and accountability processes necessary to support their use. This is where a mature privacy program becomes critical.

The Technology Isn't the Only Privacy Risk

Licence plate reader technology is relatively straightforward. Cameras capture licence plate information and compare it against approved databases to identify vehicles associated with specific law enforcement or public safety purposes. Depending on the configuration, these systems may also collect information about vehicle location, date, time, movement patterns and distinguishing vehicle details.

The privacy risk is often not the technology itself.

The risk emerges when organizations fail to clearly answer fundamental questions:

Why is the information being collected?
Is the collection necessary and proportionate?
How long will information be retained?
Who will have access to the data?
Will the information be shared with other organizations?
What safeguards are in place to prevent misuse?

Without clear answers, public trust can quickly erode, regardless of the program’s intended benefits.

Transparency Is No Longer Optional

One of the most consistent themes emerging from privacy regulators across Canada is the need for proactive transparency when deploying surveillance or monitoring technologies. Public-sector organizations must be prepared to explain not only what technology is being used, but why it is being used and what measures have been implemented to protect privacy. Many organizations approach transparency as a communications exercise rather than a governance exercise. Publishing a webpage or issuing a media release announcing a new technology initiative is not enough.

Meaningful transparency requires organizations to clearly communicate:

The legal authority supporting the collection
The purpose of the program
The categories of information being collected
Retention and destruction practices
Data-sharing arrangements · Individuals’ privacy rights
Oversight and accountability mechanisms When these elements are missing, public concern often fills the information gap.

When these elements are missing, public concern often fills the information gap.

The Privacy Impact Assessment Should Come First

One of the most important tools available to public-sector organizations is the Privacy Impact Assessment (PIA). Privacy commissioners and regulators have repeatedly identified PIAs as a foundational component of responsible ALPR deployment. A properly conducted PIA helps organizations evaluate necessity, proportionality, security risks, transparency requirements, and compliance obligations before implementation begins. Too often, organizations treat the PIA as a compliance document that is completed after decisions have already been made. A strong PIA should do much more. It should help decision makers understand:

Whether the technology is genuinely necessary
Whether less intrusive alternatives exist
What personal information will be collected
How privacy risks can be mitigated
Whether retention periods are appropriate
What public communications may be required.

A meaningful PIA is also a collaboration tool. It should bring together relevant stakeholders early enough to influence decisions, rather than simply documenting decisions already made.

Most importantly, the PIA should show that privacy considerations were integrated into the program’s design from the beginning.

Public Trust Depends on Accountability

Licence plate reader programs often generate concern because they create detailed records regarding individuals’ movements and activities over time. Even if organizations collect that information for legitimate purposes, public confidence depends on their ability to demonstrate accountability.

Accountability includes:

Clear governance structures
Defined roles and responsibilities
Access controls
Audit logging
Staff training
Regular program reviews
Documented retention and disposal processes

Without these controls, organizations expose themselves to privacy complaints, regulatory scrutiny, and reputational risk.

A privacy program should not simply document compliance. It should provide evidence that privacy risks are actively managed throughout the technology lifecycle.

Privacy by Design Matters More Than Ever

As public-sector organizations continue to modernize services and adopt new technologies, privacy cannot be an afterthought.

Whether implementing licence plate readers, artificial intelligence, smart city technologies, or advanced analytics, organizations should be applying Privacy by Design principles from the earliest planning stages. This includes embedding privacy considerations into procurement, project management, governance, and operational decision-making.

The most successful organizations are not necessarily the ones with the most advanced technology.

They are the ones that can effectively demonstrate that privacy, transparency, and accountability have been built into the program from day one.

How Garabyte Can Help

At Garabyte, we help public-sector organizations build practical privacy programs that support innovation while maintaining public trust.

Whether you are planning to implement licence plate readers, conducting a Privacy Impact Assessment, developing transparency documentation, or strengthening your privacy governance framework, we help ensure privacy considerations are embedded throughout the entire project lifecycle.

Because with emerging technologies, success isn’t measured solely by operational outcomes. It is measured by whether the public trusts how their information is being collected, used, protected, and governed.