On January 27, 2025, the Ombudsperson, Marc-André Dowd, sent a letter to the Commission des finances publiques commenting on Bill 82, the Act respecting the national digital identity and amending other provisions.
National digital identity (NDI) aims to offer a simple, reliable solution to verify a person’s identity. Dowd welcomes this initiative. He believes that approaches that use digital technology can help improve the user experience for a large portion of the population. To optimize these advantages and reach more people, the NDI must be intuitive and user-friendly.
Dowd points out, however, that many residents will still need to have traditional methods to access services and verify their identity. They will still want to go in person or use the telephone or the mail. This bill sets out conditions to ensure that organizations will not force their clients to use the NDI to access their services. The Protecteur du citoyen is of the opinion that upholding these measures will be crucial.
Organizations will also have to ensure that their performance requirements do not compromise access to government services for people who do not wish to use the NDI or who are unable to do so.
Finally, Bill 82 bans the Minister from using government digital data for profiling purposes. The Protecteur du citoyen commends this, especially for its protection of potentially vulnerable people.
Dowd concludes his letter by stating that he will monitor the roll-out of the NDI and the proposed regulatory framework, to ensure that the principles of equity and service accessibility are fully upheld.
Letter from the Protecteur du citoyen concerning Bill 82 (PDF, 106 KiB, in French only)
