Review of the City Authority to Address Traffic and Privacy Issues Regarding Automated Vehicles on City of Toronto's Streets

Automated Vehicles are subject to the same laws as all other vehicles under the Criminal Code, Ontario's Highway Traffic Act and the Toronto Municipal Code. However, many traffic and parking regulations are drafted contemplating a human driver, meaning that tickets must be issued to a human driver. Owner liability, meaning a ticket issued to the vehicle owner instead of the human driver, is already contemplated in many of the City's Municipal Code Chapters that include non-moving violations (parking, stopping and standing). Many moving violations under the Highway Traffic Act and Criminal Code do not contemplate driverless vehicles in this manner. With respect to privacy, the federal Personal Information Protection and Electronic Documents Act governs personal information collected by Automated Vehicles for the purpose of mapping, training or other purposes in the course of operations. The collection and use of data (including personal information) associated with automated vehicle operations is governed through federal and provincial legislative frameworks, which the City does not have legislative authority to override. This report has been developed in consultation with the Executive Director, Municipal Licensing and Standards, and the City Solicitor.