Sidewalk Labs Releases Detailed Plans for Collaboration with City of Toronto on Quayside Smart City Project, Including Proposed Privacy and Data Protection Framework


By: Suzie Allen

Experts Highlight Data Protection Safeguards, Opportunities, and Risks

“Master Innovation and Development Plan” will be Vetted by City Residents, Officials

Last week, Sidewalk Labs unveiled its proposed “Master Innovation and Development Plan” (MIDP) for Sidewalk Toronto, a project that would design a smart city district in Toronto’s Eastern Waterfront. The proposal will be considered by the government and other stakeholders in the coming months to determine whether to move forward with the project. This proposed public-private partnership between Sidewalk Labs and Waterfront Toronto seeks to promote affordability and sustainability while reducing climate impact and creating new mobility solutions, such as by prioritizing mass transit and pedestrians over vehicles. 

The MIDP as proposed contemplates substantial data collection and use; it also proposes a range of signifcant legal, technical, and policy controls to mitigate privacy risks and promote data protection. In the coming year, Toronto residents and officials will analyze the MIDP and work with Sidewalk Labs and Waterfront Toronto to identify aspects of the proposal that could be modified to promote benefits and reduce risks. 


  • Quayside:  The Quayside site in Toronto covers 12 acres of land that is primarily managed by Waterfront Toronto, a tri-government organization funded by the Government of Canada, the Province of Ontario, and the City of Toronto. Sidewalk Labs has proposed a development plan that includes elements of user-centric design and seeks to promote the health and well-being of residents. For example, Quayside’s streets will prioritize transit, cycling, and walking instead of a car-centered design and the city will have a thermal grid for fossil-free heating and cooling. The plan also articulates inclusiveness for indigenous populations, individuals with disabilities, and other members of the community as a goal of the design. 
  • Scale:  The Sidewalk Labs proposal includes the 12-acre Quayside site, as well as additional land on Toronto’s Eastern Waterfront over approximately a 20 year period.  Public engagement around the Quayside site and the development of the MIDP stretches back to November 2017, and has involved “dozens of meetings with local experts, non-profits, and community stakeholders; and the research, engineering, and design work of more than 100 local firms.” 
  • Roles and Responsibilities: If the MIDP is approved, Sidewalk Labs would have three main roles in developing Quayside: 1) developing real estate and infrastructure systems through partnerships with local developers; 2) providing advisory, technical, and management services to the District Administrator; and 3) serving as a technical advisor, purchasing technology from or partnering with third parties rather than building the technology itself.  
  • Process and next steps:  Waterfront Toronto plans to consult with the public and receive feedback on the MIDP. Once this is complete, Waterfront Toronto will take the evaluation and make a recommendation to the Investment Real Estate and Quayside (IREQ) Committee, which will make a recommendation to the Waterfront Toronto Board of Directors. The Board will then decide whether, and how, to continue to the next phase by deciding to pursue some, all, or none of the elements of the MIDP.

Privacy, Data Governance, and Transparency

The MIDP acknowledges that some of the urban data at the core of the Quayside effort will be personal and/or sensitive, and proposes several key measures intended to mitigate the privacy risks. The MIDP contemplates both include technical controls, such as employing hardware and software solutions that integrate privacy-protective data collection, use, and sharing into the development and operation of the Quayside site, as well as legal and organizational safeguards, such as establishing consistent and transparent processes for using urban data and independent oversight. Key measures include: 

  • Responsible Data Use (RDU) Guidelines:  The MIDP calls for the development of core, high-level principles for responsible data use that apply to all uses of personal data by  Sidewalk Toronto projects. Sidewalk Labs proposed several potential starting points, including: 
    • all technology involved in the Quayside project must have a beneficial purpose for residents; 
    • projects will strive to minimize the amount of personal information collected and retained; 
    • personal data that is collected will be de-identified by default and at the source — that is, on the device collecting the data — whenever possible; 
    • data deemed to be non-personal or sufficiently de-identified will be made publicly accessible by default; 
    • AI systems must address ethical and bias concerns; and
    • personal information will not be sold or used for advertising purposes without explicit consent. 
  • Responsible Data Use Assessment:  To support the implementation of the RDU Guidelines, the MIDP contemplates developing a RDU Assessment as a mechanism for public and private entities to weigh the data benefits and privacy risks of digital products and services prior to deployment. The Assessments would focus on transparency and extending protections to diverse groups and communities, in order to ensure that a particular technology or algorithmic use case does not negatively impact individuals, groups, or communities due to biased decision-making. 

FPF has previously reported on the importance of evaluating both privacy risks and data benefits in its practical guide Benefit-Risk Analysis for Big Data Projects.and outlined the potential harms that can arise from automated decision-making in Unfairness By Algorithm: Distilling the Harms of Automated Decision-Making.

  • Urban Data Trust:  Finally, the MIDP would entrust oversight and accountability of the Responsible Data Use Guidelines and Assessments to an “Urban Data Trust.” This new non-profit entity would manage urban data and technologies independent of Sidewalk Labs and Waterfront Toronto, and would oversee day-to-day digital governance of Sidewalk Toronto projects.  Sidewalk Labs states the data trust concept is intended to build on existing privacy laws while providing an additional protection and review before data-related measures are permitted to go into effect. The trust would also apply to third-party data collection and use. 

Since 2017, Sidewalk Labs has staked out an ambitious vision of the “city of tomorrow.” As Sidewalk Toronto would be fueled in significant part by data from and about Quayside’s residents and visitors, it is essential that clear and consistent standards for protecting personal data be built into the project from the outset. The MIDP sets out one of the most detailed urban data protection frameworks we have seen for any local development project and sets forward a model structure of municipal data.  If the Sidewalk Labs proposal is ultimately approved, it could be the catalyst for similar projects throughout the world, making it imperative to keep privacy as a priority. MIDP describes an intriguing range of proposed organizational, technical, and legal safeguards, and has set the stage for continued discussions with Torontians and with stakeholders from government, industry, academia, and civil society about how to maximize the potential of urban innovation while minimizing risks to individuals and communities.