Data for Good
Leveraging TELUS data against COVID-19
TELUS is committed to assisting in reducing the spread and impact of the COVID-19 virus. We recognize that we hold a great deal of critically useful data in this regard, specifically network mobility data. We want to share this data for the benefit of Canadians without compromising our long standing commitment to respect the privacy of our customers.
Long before COVID-19 changed our reality, TELUS contemplated the use of its data for the social good. We developed and published our data Trust Model on our website, binding us to core principles of Accountability, Ethical Use and Transparency. We remain, as always, committed to those principles, including the rigorous review of all proposed uses of data.
Similarly, long before COVID-19, TELUS was committed to leveraging the value in data in ways that preserve privacy. We have worked with leading thinkers in de-identification and aggregation and have developed models to allow us to derive insights from our network mobility data without compromising personal privacy. Our TELUS Insights team focuses on delivering the most valuable benefits of data, using privacy protective methodologies, and has achieved Privacy by Design Certification. We have always been transparent with our customers about this and our other data-related practices, and we strive to assist our customers in understanding how we handle their data. For example, when we talk about de-identified data we mean that it cannot be traced back to an individual; when data is aggregated, it is compiled into large data pools. For more information about this process read Data Analytics at TELUS.
We are accountable to Canadians and to our customers for how we use data and when we use data and we see it as our responsibility to use it to help save the lives of Canadians during this COVID-19 crisis. We annually produce Transparency Reporting as part of our Sustainability Report whereby we disclose the number and type of requests and orders for personal information that we receive from government organizations and law enforcement and we will continue to do so. During this unprecedented public crisis and time of uncertainty, we wish to be even more timely and transparent about how we will be using network mobility data, and, more importantly, how we will not. For that reason we have chosen to share the ethical use commitments that we have developed to support our sharing of data to assist in the battle against COVID-19.
We are putting an expiry or sunset clause on the COVID-19 related data sharing arrangements we describe below, unless otherwise required by applicable law. These arrangements are currently expected to expire on March 31, 2021. Unless otherwise compelled by law, in all cases of data sharing, TELUS will require a commitment ensuring that any use of the insights or data sets will be limited to the purposes described below.
TELUS will continue to put its customers and their privacy first and will not adjust or relax any of its rigorous data sharing policies in respect of personally identifiable information of its customers. In general, for COVID-19-related purposes, as for other purposes, we will NOT share customer personal information unless compelled by law to do so. To the extent that our governments or health authorities believe that our data can help them serve a clearly articulated public purpose, we welcome such compulsion and will assist.
Example: If TELUS were asked to locate or identify individuals who are in a closed public park, we would require a lawful order from a public authority.
TELUS will share insights from strongly de-identified and aggregated network mobility data with our governments, health authorities and academic researchers where such insights can assist in initiatives to flatten the curve of COVID-19, stem its spread, lessen its health and economic impacts, coordinate health care, or contribute to studies that could prevent or mitigate future phases of COVID-19 or other pandemics. TELUS will provide these insights free of charge.
Example: TELUS would share with the government that its data shows that 30% fewer people are using a particular highway or going to grocery stores. It might also share that groupings of greater than 20 have reduced by 80%, without revealing any personally identifiable data.
TELUS will provide supervised and guided access on our platform to sets of strongly de-identified network mobility data to researchers and data scientists working for or on behalf of our governments, health authorities or academic institutions where such access and data can assist in initiatives to flatten the curve of COVID-19, stem its spread, lessen its health and economic impacts, coordinate health care, or contribute to studies that could prevent or mitigate future phases of COVID-19 or other pandemics. This access will be subject to resource availability at TELUS and to tight contractual restrictions on use, sharing, scope of purpose and length of retention. There will also be specific and legally binding restrictions to prevent attempts to re-identify the data. TELUS will provide this access free of charge.
Example: TELUS has a platform where they could allow data scientists to access strongly de-identified TELUS network mobility data so that it can be analyzed in conjunction with other data, such as the number of positive diagnoses in that region in order to find correlations in the data that could help our governments and health authorities develop public policy and determine where to allocate much needed resources.
TELUS may provide insights from or access to strongly de-identified and aggregated network mobility data to third parties (commercial entities, innovators or others) who are developing solutions, products or services designed to flatten the curve of COVID-19, stem its spread, lessen its health and economic impacts, coordinate health care, or contribute to studies that could prevent or mitigate future phases of COVID-19 or other pandemics. TELUS will carefully select such third parties to ensure that their work is tightly aligned with the stated public purposes. Access will be subject to resource availability at TELUS and to tight contractual restrictions on use, sharing, scope of purpose and length of retention. There will also be specific and legally binding restrictions to prevent attempts to re-identify the data. As always, we will require strict adherence to the contractual restrictions in order for data sharing to continue. TELUS will determine whether to charge for such data sharing on a case-by-case basis depending on a number of factors, including whether the third party is commercial in nature and how broadly Canadians may benefit from the initiative.
Example: We may share data indicating the aggregate numbers of people in different types of businesses to allow think tanks or banks to better predict the economic impact of COVID-19.
TELUS will not share real-time insights from strongly de-identified and aggregated network mobility data where it is reasonably possible that such insights could be used to identify the underlying individuals without being legally compelled to do so by a valid order.
Example: While we may share an insight that certain locations showed congregations of individuals during the previous week or even yesterday, we would not do so in real-time or near real-time as such individuals could then become identifiable to law enforcement. We recognize that in these cases, context matters deeply. With a valid legal order, however, we would provide such information.