Mark Goldberg


www.mhgoldberg.com





Policy-based evidence making

If you believe a recent survey, 1 in 6 Canadians sent a fax last year to a government department because that agency would not accept scanned documents by email. Perhaps no other data point in the CIRA survey demonstrates that something smells wrong with the methodology or results.

Frankly, I don’t believe that 1 in 6 Canadians sent a fax to anyone last year, let alone sent one with such a specific purpose.

CIRA also reported “In Canada, the appetite to share personal data in exchange for better products and services is low across the board” other than online banking “with 52% of Canadians at least somewhat willing to provide their data if it means better service”. Only 23% responded that way for social media websites. Yet, based on adoption rates in Canada, we know that virtually all of the respondents make use of social media services in exchange for sharing their personal information.

So it seems, as should have been expected, respondents answered with what they thought was the ‘right’ answer, whether or not it was a truthful answer. It is with this in mind that we have to take all of the survey results with a grain (or tablespoon) of salt.

Five questions, numbers 33-37 dealt with cyber security, culminating with one that Strategic Counsel’s report said indicated “Level of Concern about Huawei Technologies Supplying Equipment to 5G Networks”. But the question actually read “As you may know, Huawei Technologies is a large Chinese technology firm that is a global supplier of smartphones and telecommunications network equipment. Huawei supplies equipment to 5G networks, the fifth generation of wireless networks that will eventually replace current 4G networks. How concerned are you, if at all, about potential cyber security risks from foreign-owned network technologies such as Huawei and 5G?”

Try to parse that for a minute, especially in view of the respondent answering the way they thought they were supposed to.

We just finished with 4 other cyber security questions, and those followed more than a dozen questions about privacy and security of personal data. Then there is a complex question that does not mention a few important facts: that Huawei supplies equipment already for some of Canada’s 4G networks, that all of the major equipment suppliers for Canada’s telecom networks come from foreign owned network technologies. Read the question again and consider whether the survey result applies equally to Cisco, Ericsson, Nokia – all of which are foreign owned technology suppliers.

Is the question itself meaningful when the network technologies may come from foreign owned suppliers, but once acquired, the network technologies are Canadian owned? In a number of cases, the software development for these foreign suppliers takes place in Canada. Would that information impact the way someone responded?

CIRA tells us that “Most Canadians are not comfortable with the idea of living in a smart city, and another 18 per cent say they’re not comfortable at all.” Based on the way the question was asked, it’s no wonder. Here is how Smart Cities were described in the survey [Q. 28]: “The term ‘smart city’ refers to a high tech urban area that uses a wide network of internet-connected sensors and technology to collect data and then use insights gained from that data to manage infrastructure, assets, resources and services. This includes data collected from individual citizens, devices and systems. How comfortable or uncomfortable would you be living in a smart city?”

What if the techno-jargon was put into terms like “The term ‘smart city’ refers to an urban area that uses a network of internet-connected sensors to collect data and then use insights gained to provide benefits to residents like reduced traffic congestion, improve energy efficiency and lower maintenance costs. How comfortable or uncomfortable would you be living in a smart city?”

A couple of weeks ago, I described just some of the problems with CIRA’s flawed recent internet traffic data. It is perhaps another unfortunate result of policy-based evidence making, rather than contributing independent information to ongoing discussion of the evolution of Canadian digital policy.

For a non-profit organization, CIRA does pretty well. In the year ending March 31, 2019, it had an ‘excess of revenue over expenses’ of $1.8M on revenues of $26M. That was what was left after giving away another $1.8M to “Community investment programs”. Not a bad profit for a non-profit.

I went back through the financial statements and had trouble finding a ‘down year’. For 2017-18, CIRA made $500K after giving away $1.3M; the year before, it made $300K after giving away $1.3M. Salaries and consulting have climbed from $12M in 2016-17, to $13M in 2017-18, to $14M in 2018-19, while “community investment” keeps rising as well. Notice the trend?

Perhaps it is time to ask why CIRA’s expenditures are at least an order of magnitude higher than what it takes to administer Canada’s phone numbering system under the Canadian Number Administrator.

Maybe it’s time for CIRA’s board to reflect on its bloated budget, reduce the cost of .CA, and return to its original mandate, “to administer the .CA domain space on behalf of Canadian users”.

It may also want to revisit the letter establishing the organization requiring it “put in place an effective structure predicated upon… ensuring an appropriate balance of representation, accountability and diversity on the Board of Directors for all categories of stakeholders.”

It is somewhat telling that the Board of Directors of CIRA has no representation from facilities-based ISPs, the companies that provide roughly 9 out of 10 internet access lines in Canada.

Is it possible that CIRA’s failure to ensure an appropriate balance of representation and diversity on its Board for that category of stakeholder has contributed to its one-sided, off-mandate policy pronouncements?

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