AI-Assisted Remote Reporting for Immigration Enforcement Conditions

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Your rights

• Right to Be Informed of AI UseIndividuals are informed of AI use before enrollment. The CBSA discloses that ReportIn uses automated facial recognition software. AI use is disclosed to users as confirmed in the register. Plain-language notice is posted through all service delivery channels (Internet, in person, mail, or telephone) as required by the AIA Impact Level 2 requirements.
• Right to a Human ReviewEvery report is reviewed by a trained CBSA ATD Monitoring Centre Officer (ATD MCO). If a facial comparison fails, the case escalates to an ATD Monitoring Centre Supervisor (ATD MCS), and then to a Regional Inland Enforcement Officer (IEO) who may interview the individual in person before any detention decision is made. The ATD MCO — not the system — makes the final match determination.
• Right to an Explanation of a DecisionWhere a decision results in denial of a benefit or regulatory action, individuals are entitled to a meaningful explanation in plain language covering: the role of the system in the decision; the training and client data used; the criteria applied to evaluate the data; the system output and how to interpret it; the principal factors leading to the decision; and available recourse options. This is required under AIA Impact Level 2 and the Directive on Automated Decision-Making.
• Right to ContestIndividuals who fail a facial comparison or location match may challenge the determination through a three-tier recourse process: first with the ATD Monitoring Centre Officer, then with the ATD Monitoring Centre Supervisor, and finally with the Regional Inland Enforcement Office. At each level, the individual has an opportunity to provide additional information or evidence, including in-person participation in an investigation.

Risks and safeguards

• Civil liberties harmFacial recognition applied to a vulnerable population (immigration detainees and those on enforcement conditions) could produce false negatives leading to unnecessary detention, or create surveillance chilling effects on movement. The algorithm is a trade secret and difficult to interpret. Mitigations: 100% human review of every submission through a three-tier escalation (ATD MCO → ATD MCS → Regional IEO); the app is voluntary; Privacy Impact Assessment completed; Privacy Commissioner consulted; AWS contract prohibits secondary use of personal data; third-party bias evaluation by Credo AI showed 99.9% match rate across six demographic groups; plain-language notice provided through all service delivery channels.
• Reputational harmA false facial comparison failure could stigmatize an individual as non-compliant, potentially triggering investigation and detention. The algorithm may misfire due to image angle, blur, or demographic factors. Mitigations: ATD MCO makes the final match/no-match decision (not the algorithm); if one of five photo views fails but others pass, the officer can still record an overall match; the individual is given the opportunity to provide information or evidence during any investigation (e.g., if they have had facial surgery); the reference photo can be updated to reflect legitimate facial changes.