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CF Statement Regarding OPC Investigation
Oct 29, 2020


Today, the Office of the Privacy Commissioner of Canada (OPC) released its report and recommendations related to a beta test of AVA (Anonymous Video Analytics) technology that was briefly conducted at select Cadillac Fairview (CF) properties in July 2018. The AVA beta test software was designed to assess the amount of foot traffic at a given site and categorize the general demographics of visitors anonymously.


  • The OPC report concludes there is no evidence that CF was using any technology for the purpose of identifying individuals.
  • The OPC has determined the complaint to be resolved. We have accepted and implemented all the Privacy Commissioner’s recommendations, with the exception of those that speculate about hypothetical future uses of similar technology. We currently have no plans to use the technologies in question.
  • Our WiFi policy is in full compliance with all legal and regulatory requirements and our operations are consistent with industry standards. The OPC report concludes that the privacy concerns related to our WiFi practices were unfounded.


Cadillac Fairview disabled and removed the AVA pilot software more than two years ago, when privacy concerns were first raised by the public. We subsequently deactivated directory cameras and the numerical representations and associated data have since been deleted.  We take the concerns of our visitors seriously and wanted to ensure they were acknowledged and addressed.


The AVA software in our digital directories was being used exclusively to detect the presence of a human face and, within milliseconds, assign the face to an approximate age and gender category. It did not store any images during the pilot program, and it was not capable of recognizing anyone. 


The five million representations referenced in the OPC report are not faces. These are sequences of numbers the software uses to anonymously categorize the age range and gender of shoppers in the camera’s view. If the same shopper crossed the camera’s view again, a new string of numbers would be generated. 


While the focus of this report is of a technology that was disabled and removed more than two years ago, we want to reiterate that we take the concerns of our visitors seriously and are committed to protecting our visitors’ privacy. 


As we continue to enhance the in-mall experience and better connect with our digitally engaged customers, we are, and will always be, deeply committed to privacy and responsible data usage.


We thank the Privacy Commissioner for the report and recommendations on how to further strengthen our privacy practices and agree that the privacy of our visitors must always be a top priority.


For media inquiries:


Jessica Savage

North Strategic

[email protected]