Project Arachnid Privacy Statement

August 22, 2018

Overview

Project Arachnid is a platform designed to reduce the public availability of child sexual abuse material¹ (“CSAM”) on the internet, thus reducing the revictimization that occurs for victims each time an image/video depicting CSAM is made available online.

Project Arachnid is operated by the Canadian Centre for Child Protection Inc. (the “Canadian Centre”). The Canadian Centre is a registered Canadian charity dedicated to the personal safety of all children, and it operates Cybertip.ca, Canada’s national tipline to report the online sexual exploitation of children.

Federal privacy legislation in Canada, namely the Personal Information Protection and Electronic Documents Act (PIPEDA), applies to personal information that is collected, used and disclosed in the course of commercial activities. While Project Arachnid is not operated in the course of commercial activities, nor is it operated for a commercial purpose, the Canadian Centre believes that maintaining the privacy of personal information is of the utmost importance and accordingly it adheres to the spirit of PIPEDA in its operation of Project Arachnid.

This privacy statement is being made available to identify the purposes of Project Arachnid, describe the nature of the information that may be processed through Project Arachnid (which is not generally personally identifiable information), and provide information about who has access to information and why, who information may be shared with and why, and the security safeguards in place to protect information. Given the non-commercial nature of Project Arachnid and the purpose for it, this statement does not follow the traditional format of a privacy policy and instead provides information to assist interested parties to better understand the system.

Purpose of Project Arachnid

The Canadian Centre recognizes that survivors of child sexual abuse who were recorded continue to be revictimized by the continued public availability of images/videos depicting their abuse, and that the lack of control over such images/videos is one of the most difficult aspects to overcome. The Canadian Centre also recognizes that children are victimized each day by the creation of new images/videos showing their abuse. As such, the primary purpose of Project Arachnid is to reduce the public availability of CSAM on the internet by detecting where CSAM is being made available and, in most cases, issuing a notification to the entity hosting the CSAM requesting its removal. An ancillary and directly related purpose of Project Arachnid is reducing the continued victimization of the children who are depicted in such images and videos. The Canadian Centre believes that reducing the public availability of CSAM on the internet will provide psychological relief to all victims and survivors of CSAM, contribute to restoring their dignity and privacy, and enhance their current and future personal security interests.

Personal information commitment

The Canadian Centre is accountable for all information, including personal information, which is processed through Project Arachnid and is under its control. It has designated a privacy officer who is accountable for the Canadian Centre’s compliance with privacy principles. The Canadian Centre will not use information generated through the operation of Project Arachnid (whether that information is considered personal or not) for purposes that are inconsistent with the Purpose of Project Arachnid as set out above.

Type of information used in the operation of Project Arachnid

The primary type of information that is used in the operation of Project Arachnid is images/videos that are, or are reasonably suspected to be, CSAM. For each image/video that is detected by Project Arachnid:

• The image/video is reviewed to determine if it depicts CSAM.
• The assessment that is made is recorded and retained, along with the first name of the individual(s) who performed the assessment.
• A unique hash value is created. A hash value is a unique algorithm that helps to distinguish one image or video from another.

Generating and using hash values helps to reduce duplication in the assessment process, as once a hash value is created, the system will recognize the same image/video should it be detected again. This allows for the automation of internal processes, such as the generation of notices to the service providers hosting content assessed as CSAM. It also helps to ensure limited human resources can focus on assessing images and videos detected by Project Arachnid that have not yet been assessed rather than re-reviewing media that has already been assessed. The first name of the individual(s) who performed the assessment is retained for quality assurance purposes, and to facilitate prompt resolution of conflicting opinions on assessment.

Personally identifiable information

If an individual’s face or unique/distinguishing features appear in an image/video that is assessed as a result of being detected by Project Arachnid, it is possible that individual would be personally identifiable to someone who knew the individual at the time the image/video was created. However, the vast majority of the individuals depicted in CSAM are unidentified. This means that their actual identities (and current physical location) are not known to police nor known to the agencies around the world that operate hotlines such as the Canadian Centre’s Cybertip.ca. As such, the actual identities and the physical location of the individuals who appear in the images and videos detected by Project Arachnid and assessed by analysts is not information that is known to the Canadian Centre. To the extent the Canadian Centre may have information about an individual depicted in a particular image/video of CSAM, or series of images/videos of CSAM related to a particular individual or group of individuals, within Project Arachnid, such information would be limited to the information that is apparent from the image/video (e.g., the sex of the child), whether or not that child has been identified by law enforcement, and a generic identifier associated to the images/videos that relate to that child or children. Any personal data that is collected, used, disclosed or processed through the operation of Project Arachnid is done so for the Purpose identified above, which the Canadian Centre believes is in the public interest and is necessary in order to protect the vital interests of the individuals depicted in CSAM. The Canadian Centre does not collect, keep, use or share personal information beyond that which is necessary for the Purpose, and it takes care to ensure all personal information it does have is as accurate as it can be in the circumstances.

Consent

Given the nature of CSAM and the anonymity of victims depicted in CSAM, obtaining consent from the individuals depicted in CSAM for the use of the personal information that is necessary to operate Project Arachnid is not possible. The Canadian Centre believes that the operation of Project Arachnid is clearly in the interests of the victims/survivors of CSAM and that consent cannot, in virtually all instances, reasonably be obtained directly from them. The publication of this privacy statement is intended to provide information to help victims/survivors understand how their information may be used, and why. The Canadian Centre is confident that victims/survivors are now and will continue to be supportive of the purpose of Project Arachnid, particularly in light of the responses that were shared by survivors in the Canadian Centre’s Survivors’ Survey released in 2017 (https://protectchildren.ca/en/resources-research/survivors-survey-results/). To the extent the Canadian Centre has or will in the future connect with victims/survivors of CSAM (either directly or through their lawyers), whose images/videos may be detected by Project Arachnid, the purpose of Project Arachnid and the ways in which personal information may be used or disclosed will be communicated. Victims/survivors, either on their own or through a lawyer or designated support person, will be able to obtain information from, make requests of, and share information with, the Canadian Centre, and the Canadian Centre will make all reasonable efforts to respond to questions or inquiries and address concerns that may be raised by victims/survivors and/or their legal counsel.

Third party involvement in assessment

The Canadian Centre authorizes legitimate and trusted third party entities to contribute to the assessment process that occurs as part of Project Arachnid provided such third party signs a written agreement in advance, and such third party abides by all requirements of such agreement. An example of a legitimate and trusted third party entity is a hotline that is part of the INHOPE network, assesses CSAM as part of its hotline activities, and is carrying out such activities without objection by the Government of the country within which it operates. Such third parties may, upon request, be permitted to use the hash values generated by Project Arachnid to reduce duplication of assessment in its own hotline operations.

Notification process

When an image/video displayed on a URL is believed to contain CSAM, Project Arachnid may generate a notice to the provider hosting such image/video requesting its removal, or to the hotline operating in such country to enable such hotline to make the request. The information shared with the service provider or the hotline is the URL upon which the image/video was detected and the assessment associated with such image/video, along with general information about the assessment process (not specific to the image/video in question). A notice may not be generated in all circumstances; for example, if the host or contact details cannot be determined with reasonable certainty, or if the geographic location of the host is uncertain.

Safeguards and security

The Canadian Centre has implemented and enforces stringent safeguards to ensure the information within Project Arachnid is at all times secured against access by unauthorized parties. The Canadian Centre is also committed to ensuring that the privacy and dignity of all individuals depicted in the images/videos assessed is respected and protected in a manner appropriate to the sensitivity of the information. Examples of the physical, operational, technical and procedural safeguards that are in place include: assessments can only be performed by individuals who are trained to perform assessments and who have undergone appropriate background and other security screening; assessments only occur within physical spaces that are not open to individuals who are not authorized to perform assessments; information associated with the assessment process is not stored anywhere other than Canadian Centre servers located inside Canada that are dedicated for this purpose; all computing systems used to access the system and servers used to retain information are secured against physical, technical or other intrusion. Safeguards are and will continue to be reassessed and updated as needed.

Retention periods

The Canadian Centre does not store personal information longer than is necessary for the Purpose.

Research

Project Arachnid is a huge step forward for victims/survivors of CSAM who have, for years, had to accept that there was little that could be done to curb the online proliferation of their abusive images. Given the innovative approach to tackling this problem through a combination of technology and collaborative assessment efforts, recognizing that the public availability of CSAM is a global problem, and believing that it is in the public interest to ensure data that can assist in addressing the issue is available, it is anticipated that from time to time information used or generated through Project Arachnid will be used to conduct research. To the greatest extent possible, any such research will either be conducted solely by the Canadian Centre, or the Canadian Centre in conjunction with a trusted professional or group of professionals. Either way, any research results will be presented in the aggregate and not include personally identifiable information. Moreover, if third parties are involved in research activities, aggregate information is what is expected to be shared with such third parties in such instances, and in all cases, appropriate contractual, technical and other safeguards shall be put in place to protect any information that is shared.

Questions & access to personal information

Questions about personal information handling practices, and requests to access personal information held about an individual as a result of Project Arachnid can be directed to the Privacy Officer for the Canadian Centre for Child Protection.

As Project Arachnid is an evolving initiative, this Privacy Statement will be updated and enhanced over time.

1. 1 In many jurisdictions, the legal term for CSAM is “child pornography”. ↩