Is face search legal in Canada?

Canadian law treats a face template as personal information, and in Quebec as biometric information with its own rules. Whether a face search engine may exist, and what it may index, turns on consent and on how narrowly the courts and commissioners read the exceptions for publicly available information. Whether a person may run a search turns on purpose: checking who you are dealing with or finding your own photos is ordinary use, while using a result to harass, defraud or expose someone engages the Criminal Code.

Which laws apply to face search in Canada?

What did the Clearview AI investigation decide?

In February 2021 the Privacy Commissioner of Canada and the Quebec, British Columbia and Alberta commissioners published joint findings on Clearview AI, which had scraped more than three billion images, including Canadians, to sell a face-matching service to police forces. They found the collection happened without knowledge or consent, that the purpose was not one a reasonable person would consider appropriate, and that the 'publicly available' exception did not apply to photos harvested from social media and the open web. Clearview rejected the findings but stopped offering its service in Canada. On 14 December 2021 the three provincial commissioners issued binding orders requiring Clearview to stop collecting images of their residents and to delete the images and biometric arrays already collected; Alberta's Order P2021-12 is dated 7 December 2021 and Quebec set a 90-day deletion deadline. The federal commissioner later found that the RCMP's use of Clearview had also breached the Privacy Act.

The practical rule for engines is therefore clear in Canada: you cannot build a database of Canadians' face templates from scraped photos and treat the web as consent. For users, the findings say nothing against searching your own face, and nothing against a one-off check of someone you are dealing with, but they explain why a service's data handling, retention and deletion practices matter.

What is different in Quebec?

Quebec treats biometrics more strictly than the rest of the country. Verifying identity with biometric characteristics requires the express consent of the person, and any database of biometric characteristics must be disclosed to the CAI no later than 60 days before it goes into service. Law 25 (Bill 64), phased in between 2022 and 2024, added privacy impact assessments, breach notification, a right to de-indexing and penalties of up to the greater of $25 million or 4% of worldwide turnover. A face search engine that indexes Quebec residents' faces sits squarely inside those rules.

Is it legal to search for my own face?

Yes. Uploading your own photo to find where it appears is you exercising control over your own personal information, and it is the use FaceSearch is built for. PIPEDA and the provincial laws also give you access and correction rights against any organisation holding your information, and a right to withdraw consent, which is the legal footing for asking a website to take a photo down or asking a search engine to stop returning it.

Is it legal to search for someone else's face?

For ordinary personal purposes, such as checking a dating match, a marketplace seller or a contractor before you meet or pay them, yes. PIPEDA does not apply to an individual's purely personal or domestic use of information. What the law does catch is what you do next. Section 264 of the Criminal Code makes repeated communication or watching that causes someone to reasonably fear for their safety criminal harassment. Section 162.1 makes publishing or sharing an intimate image without consent an offence punishable by up to five years, and the courts can order the images removed. Section 403 covers impersonating someone to gain a benefit or cause harm. Using a face match to track, contact or expose someone against their wishes moves from a lookup into these offences.

Where do I report misuse, fraud or intimate-image abuse in Canada?

• Romance, marketplace and impersonation fraud: the Canadian Anti-Fraud Centre, online or on 1-888-495-8501, and your local police. The CAFC asks you to report even when no money was lost; it recorded more than $54 million in romance-scam losses in the first nine months of 2025.
• Intimate images of an adult shared without consent: local police under section 162.1, plus StopNCII.org to stop re-uploads on participating platforms. See intimate image abuse.
• Images of anyone under 18: Cybertip.ca, run by the Canadian Centre for Child Protection, and NeedHelpNow.ca for young people trying to get an image taken down.
• A company holding your face without consent: the Office of the Privacy Commissioner of Canada, or the CAI, OIPC BC or OIPC Alberta where a provincial law applies.

Is Canadian privacy law changing?

Slowly. Bill C-27, which would have replaced PIPEDA's privacy rules with the Consumer Privacy Protection Act and created an AI statute, died when Parliament was prorogued on 6 January 2025. The government has since tabled a narrower bill to repeal Part 1 of PIPEDA, the Protecting Privacy and Consumer Data Act, and added a data-mobility right through the Budget 2025 implementation act. Until a replacement passes, PIPEDA and the 2021 Clearview findings remain the operative federal rules, and Quebec's Law 25 remains the strictest regime in the country.

How this applies to FaceSearch

FaceSearch compares the face in your upload with faces on publicly accessible pages and returns those pages. It does not keep your upload beyond the search, never uses it to build a face database, and offers free removal of your face from results by email, which is how we answer a withdrawal of consent. We make no identity claims and prohibit the uses listed above. If you are in Quebec or elsewhere in Canada and want your face excluded from our results, the steps are on remove my photos; how we handle uploads is on privacy by design.