Thanks for reading my…

   Thanks for reading my comments. Thanks also for your hard work in putting this together. One issue which the people of Ontario and the people of Canada need to have a conversation about (that the preliminary plan ignores completely) is the use of remote game cameras in parks. These are being put in numerous places in our parks ostensibly to monitor wildlife, but also, as some internal MNRF documents and MNRF activities have implied and demonstrated, people. When we go into the woods, do we always want to be checking over our shoulder? Is it still safe to change out of our bathing suits? Cameras presently are mostly battery operated and have memory cards. There are now models with solar power available that are uplinked via cellular networks. Satellite uplink for use anywhere on the planet won’t be far behind. That’s quite the surveillance network we’ve built! The cameras (look up Reconyx, for example) are well-camouflaged, but that’s usually the closest thing to protection that they have. If they’re found (go online, people find them accidentally all the time!) they’re usually poorly secured by at most thin chains or locks. They’re easy to remove. What happens to the images or the video on the memory cards when someone swipes one of these? Is it encrypted? What if the images and video are of you? Are you OK with this going everywhere online? In one case, a camera was found but the finder left the camera, just going back to take the data off the card every so often without the camera owner knowing. The guy who put the camera there never knew this was happening! Questions remained about whether or not the person who stole the information used it to poach wildlife.

  The Information and Privacy Commissioner of Ontario has a document called “Guidelines for the Use of Video Surveillance” from October, 2015, at:

  https://www.ipc.on.ca/wp-content/uploads/Resources/2015_Guidelines_Surveillance.pdf

  How does the preliminary plan assure compliance with these guidelines? Where is the privacy impact assessment on the use of these game cameras in Slate Islands Provincial Park? There isn’t one, is there? That certainly belongs in the park management plan! The IPC talks about the principle of data minimization, meaning among the best ways to ensure privacy is to not set things up to incidentally gather lots and lots of unneeded and potentially compromising data in the first place. How does the proposed park management plan address this? The park could go a long way toward acknowledging this principle by letting park users know where these things are so that people can be given the choice to avoid them. But then, parks would have to secure the cameras and the data and spend money and time doing that. Is Ontario Parks saving a few bucks at a heavy cost of park user privacy? Yes. Were users consulted? No. Unfortunately, the inconvenient truth is that while parks might claim (in many cases perhaps completely honestly) that cameras are used for wildlife observation, if they capture images of people, they become surveillance cameras. Are park users OK with being under surveillance in parks? Where does it stop? How many can there be? Where can they be? On beaches? At access points? Back-country campsites? Where is the policy that says camera placement will be done in a transparent way that empowers people to make choices regarding whether or not they’ll be camera trapped? Who retrieves data from these cameras? Is that done locally? On a volunteer’s or student’s computer? What happens when data containing personal or identifying information “slips” into the public as information so often does? What happens to data when it’s retrieved? Is it used for law enforcement purposes? If so, there must be a SPECIFIC purpose. The IPC’s document gives some pretty clear guidelines on this. If you read this submission, try not to think about it the next time you slip behind a bush to do what nature makes us all do. Do you have children? How do we know that a camera that is found is a legitimate MNRF/Ontario Parks camera and not a camera placed by a malicious third party to observe people? A simple sticker saying “MNRF” is easily forged and therefore not good enough to identify ownership. Public knowledge of official camera placements is the only way to know.

  We go into parks with an increased expectation of privacy and “aloneness”. Cameras like this ruin it totally when we’re not aware of them or when we don’t have a policy describing their deployment. We should ask: How would we feel if we knew there was one hidden camera in the park? How about 5? How about 70? There’s the rub: If you knew there was one, but didn’t know where it was, there might as well be 1000; the experience of solitude is wrecked either way.

  I get it: These cameras are amazing for research. I totally agree that use shouldn’t be unreasonably limited if it’s for research purposes. The problem is the “hiding” part, and also the part where there’s nothing saying parks and MNRF can’t blanket a place with cameras. Directions about this stuff needs to be in the management plan. People visiting parks to seek solitude need to know where (within 10 meters) cameras are. Simply, if they’re properly secured, parks won’t need to hide them anymore. Conversely, if parks chooses not to secure properly and continues to use stealth to “secure” its cameras, it’s a naked admission that parks doesn’t care about user privacy.

 Conflict arises in the gap between expectation and reality; where’s the discussion of this (and the policy!) in the park plan? There’s an increased expectation of privacy in wild lands. This discussion (or lack thereof) needs to be clearly acknowledged in the plan before the plan is complete. It’s not ignorable and it looks bad on the MNRF and Ontario Parks that they’re doing nothing at all to engage the public on this. At this point it is starting to look like these agencies are deliberately hiding this. This isn’t Yonge Street where there’s a decreased expectation of privacy. This is Slate Islands Provincial Park, somewhere we go to be left alone, and BE alone. The IPC’s document says “If all that has to be done to win legal and social approval for surveillance is to point to a social problem and show that surveillance would help to cope with it, then there is no balancing at all, but only a qualifying procedure for a license to invade privacy.”

  Please read the following about how the MNRF used its cameras under the directive of another totally unrelated Government of Ontario agency specifically to monitor and surveil so as to establish association of parties:

  http://923thedock.com/durham-area-farmer-michael-schmidt-has-a-new-cause/ http://www.owensoundsuntimes.com/2016/09/08/schmidt-cleared-in-camera-case

  When will the MNRF and Parks put this discussion in the open? Why has the preliminary plan not addressed this to *any* degree? In the above, the MNRF had “no comment”. Will this continue by way of the preliminary plan? At the federal level, charges will result based on what has been observed:

 https://www.explore-mag.com/Surveillance_Cameras_in_Canadas_Backcountry

  Will this also be policy in MNRF and Ontario Parks lands? What constrains it?

  The preliminary plan is incomplete if it does not speak to the use of game cameras.

[Original Comment ID: 210031]