Global Director and Head of Public Policy, Canada
Facebook Canada Ltd.
Suite 1201, 661 University Avenue
Toronto, Ontario M5G 1M1
Dear Mr. Chan,
This is further to the discussions you had recently with representatives from the Canadian Human Rights Commission (CHRC) and Ontario Human Rights Commission (OHRC).
During these discussions, we advised you of our respective concerns that Facebook’s advertising platform facilitates discriminatory advertising in a manner contrary to Canada’s federal and provincial human rights laws. The federal, provincial, and territorial human rights laws in Canada protect people from discrimination on the basis of factors like age, sex, race, disability, etc. At the federal level, the Canadian Human Rights Act protects people from discrimination when they are employed by, or receive services from, the federal government, First Nations governments, or private companies that are federally regulated. Similarly, in Ontario, the Human Rights Code protects people from discrimination in various areas of provincial jurisdiction, including housing and employment.
The CHRC and OHRC are each mandated to promote compliance with these respective human rights laws, and are concerned by the recent reports of how Facebook’s platform facilitates housing and employment advertising that excludes people on the basis of personal characteristics, like age, sex, or race. This type of targeted advertising enables and exacerbates discrimination against groups that may be marginalized in our country.
We understand from your recent discussions with staff at our respective organizations that Facebook has already made efforts to put in place some technical and educational safeguards globally to try and prevent discriminatory advertising. We also understand that Facebook is now developing additional safeguards relating to housing, employment and credit advertising in the United States as a result of recent settlement agreements with and input from US civil liberties organizations.
We believe that steps should be taken to ensure that comparable additional safeguards are also implemented in Canada, in line with the Canadian federal and provincial human rights laws.
We understand that you would like to engage us, and possibly other expert or stakeholder groups, about the steps that can be taken to address discriminatory advertising on Facebook in the Canadian context. To that end, it would be helpful if you could provide us with information detailing the additional safeguards being put in place with respect to US advertising and the associated timeline for implementation.
We look forward to hearing from you and continuing to engage with you on this issue.
Ontario Human Rights Commission
180 Dundas West, 9th Floor
Toronto, ON M7A 2G5
Canadian Human Rights Commission
344 Slater Street, 8th Floor
Ottawa, Ontario K1A 1E1