Draft — to be reviewed by a lawyer specialized in privacy law before launch. This note is the basis for the legal analysis requested in section 14.2 of the master plan; it does not replace it.
What UFStats does
To follow players from one frame to the next, the vision system detects each person on the field and computes, for each detection, an appearance embedding: a short list of numbers that mostly summarizes the colour and shape of the jersey, to tell two nearby players apart. A player is then identified from what the team declares and wears: jersey number, user-confirmed assignment, uniform appearance within the same match.
What UFStats does not do
- No facial recognition: no face model, no face matching, no face database.
- No persistent database of body signatures: appearance embeddings are computed for one match, used to track that match, then deleted when processing ends. They are not written to the database or to the retained result files (which only contain positions in metres and events).
- No re-identification across matches by appearance: that feature (master plan, section 5.6, step 5) stays disabled until a legal analysis approves it.
- No inference of gender, age or origin.
Why we are cautious
- In Québec, a database of biometric characteristics or measurements used to verify or confirm a person's identity must be disclosed to the Commission d'accès à l'information at least 60 days before it is put into service, and identity verification by biometrics requires the person's express consent (Act to establish a legal framework for information technology, ss. 44 and 45, to be verified).
- Silhouette or gait may be considered behavioural biometric characteristics. Embeddings used only during one match, neither retained nor compared to a known identity, should not constitute such a database, but this must be confirmed by a lawyer.
- The Act respecting the protection of personal information in the private sector also governs technologies that can identify, locate or profile a person (duty to inform and allow these functions to be turned off; s. 8.1, to be verified). On-field position tracking must be assessed from this angle.
- Outside Québec, some regimes specifically target biometric identifiers (for example Illinois' BIPA in the United States): to be analyzed before targeting those markets.
Measures in place
| Measure | Where |
|---|---|
| Embeddings computed and kept in memory only while a match is processed | vision worker (track 4) |
No embeddings in analysis.json, tracks.parquet or the database | contracts/* |
| No feature to search for a person by appearance | product |
| Contractual ban on facial recognition by users | terms of use, section 6 |
| Youth mode: no images used for training | migration 20261002110200_training_consent.sql |
Questions for the lawyer
- Do ephemeral appearance embeddings, limited to one match, constitute "biometric characteristics" under the IT framework act? Is a declaration to the CAI required?
- Is tracking player positions on the field "locating" or "profiling" under s. 8.1 (to be verified), and what information must be given?
- Under what conditions could re-identification across matches (same team, same season) be offered: express consent, declaration, maximum duration?
- Are image crops retained for training (consenting adult teams) covered?