[Letter by Stephen Pender, President of the Graduate Students' Union, University of Toronto]

Karel Swift
University Registrar
University of Toronto

7 December 1998

Dear Karel Swift,

On 2 November 1998, at an Open Forum organized by the Identity Technology Working Group, I urged the University of Toronto administration (through you and Jack Dimond in his role as Privacy Commissioner) to answer several important questions regarding policy about and the implementation of the so-called "Smart" card. In my intervention at that forum, I stated explicitly that, as the president of the Graduate Students' Union, the University of Toronto administration should "publicly report the results of the "Smart" card trial, the contract with Cybermark and publish as widely as possible a policy governing the implementation and use of the "Smart" card across the university." While the information from the University Registrar disseminated at the forum did state that "the University is undertaking to put in place comprehensive guidelines and procedures to assess any new applications of smartcard technologies" (Procedures for new students to be issued a TCard, Office of the University Registrar, page 2; emphasis mine), students have not yet seen "guidelines" or "procedures" for the existing applications of the card. Unless I missed the public relations blitz, I am disappointed the administration has not chosen to clarify its position publicly on either "Smart" card policy or its implementation. Sharing information, working collectively with those for whom your work has lasting, quotidian importance does not seem to obtain with respect to the implementation of the "Smart" card. Whether or not one agrees with the need or technological efficacy of the card, one must admit that the process of student participation, consultation and implementation has been rather poor.

The Graduate Students' Union is deeply concerned about policy questions and implications raised by the card, the ongoing problem posed by the card's inability to register voting in student government elections and the privacy questions the card raises. In particular, our constituency has expressed its dismay about the cost to students for the cards (a mandatory fee of approximately seven dollars), the astonishing lack of information about the card available from those who issue it (library staff --- who of course are not to blame for this situation) and the absence of a mechanism for refunding money loaded onto the chip (we know of at least one situation wherein a card was recalled but the money loaded on the card was not refunded). We are also concerned about the process with which the card was issued, apparently voluntarily, to students last year. That said, I have several direct questions about
(1) the card itself,
(2) the decision to purchase and implement the card and the technology,
(3) financial concerns,
(4) privacy, security and elections and
(5) the university's leadership role with respect to this technology.

I trust you will answer these questions promptly, since the card continues to be issued --- and data continues to be collected which may contravene the university's own policy on privacy.

(1) The card itself:

(2) The decision to purchase and implement the card and the technology:

(3) Financial concerns:

(4) Privacy, security and elections:

(5) The university's leadership role with respect to this technology:

The above questions do not, of course, represent all of our concerns with respect to this technology; rather, these are the questions that must be addressed before continuing the implementation and use of the card. I trust you will respond to these questions as soon as possible in at least two ways: first, obviously the GSU would like specific, detailed answers made publicly; second, I urge you and other members of the implementation committee to make all past and future documents and decisions public as well.

Finally, since students are or will be the majority of "Smart" card users, we should participate in every future policy and implementation decision in a meaningful manner (that is, for example, inviting accountable members of student governments to sit as equal members on the implementation committee).


Stephen Pender

Jack Dimond
J.R.S. Prichard
Adel Sedra
Andrew Clement/ITWG