Dear Premier Horgan,
Thank you for your letter of June 16, 2020 regarding the collection of race-based and disaggregated data. I appreciate you reaching out for my advice on this important and timely issue.
As you know, on June 5, 2020 I joined human rights commissioners from across the country in calling for the collection of such data. The collection and analysis of health data that includes race and Indigeneity are critical to identifying inequalities, advancing human rights in Canada, and effectively combatting the impact of the COVID-19 pandemic. Similarly, across government and public entities, the collection of disaggregated data will serve to strengthen public policy by recognizing and accounting for the impact of systemic inequality and racism.
You have flagged a number of important considerations in your letter, including the need to collect multiple and intersecting data points such as class and gender, as well as the need to guard against the risks of increased stigmatization. I share your concern and focus on these issues and I will be keeping them foremost in mind in my advice to you.
I appreciate the urgency of your request given the need for the collection of such data related to the ongoing pandemic. I am similarly mindful of the need to be thoughtful and consultative in determining the best path forward on the collection, use, storage and release of disaggregated data, particularly with those communities most impacted by systemic racism and other forms of inequality. I will certainly consider your requested date of September 1, 2020 as we determine how best to move forward with providing this advice to you, and I will stay in touch with you about our expected date of delivery.
I look forward to providing you with advice about the human rights implications of disaggregated data collection and recommendations for action. In addition, Commissioner McEvoy has asked me to confirm his willingness to, consistent with his Office’s role and long-standing practice, offer his comments on the privacy- and transparency-related aspects of this work as it proceeds.
Human Rights Commissioner
CC: Dr. Bonnie Henry, Provincial Health Officer
Mr. Michael McEvoy, Information and Privacy Commissioner