Response to Toronto Police Service's consultation on the draft governance for the acquisition and use of AI technology

Abstract

The Toronto Police Services (TPS) is setting national precedent. We welcome the process to engage in public consultation around artificial intelligence procedures and recognize that the Toronto Police Services are doing what, to our knowledge, no other police force in Canada have yet completed.

Our submission:
1. Recommends a more comprehensive public consultation mechanism throughout the review process;
2. Raises concerns about the adequacy of the Artificial Intelligence Technology Committee to the goals of transparency and accountability;
3. Recommends the TPS adopt best practices for algorithmic or artificial intelligence impact assessments;
4. Encourages more attention to bias and harm;
5. Recommends clarification regarding the exceptions for disclosure; and,
6. Recommends advancing the auditing frameworks necessary for a robust procedure.

These recommendations are preliminary at best. As we discuss, the limited nature of the consultation and specific details directly impede our ability for meaningful feedback. As such:
We strongly call upon the TPS to extend this public consultation process, and at minimum consider an expert discussion session to engage with feedback and consider improvements to this Procedure.

Keywords: artificial intelligence, technology, police, governance, Canada