Interim report on COVID Alert as a Government Service


Message from the co-chairs

Leveraging digital tools marks a novel approach worldwide in addressing the COVID-19 pandemic. In Canada, COVID Alert is part of that attempt to help limit the spread of the virus using new technology allowing for exposure notifications. Therefore, the Council's work on Pillar 2 sought to explore the use of COVID Alert as a Government Service.

Despite ongoing efforts to control the spread of COVID-19 through numerous public health measures, as well as an accelerated vaccination campaign, the virus is not yet defeated. The advent of new variants complicates our ability to get back to our normal lives. As the economy continues to re-open, it is the view of the Council, that COVID Alert remains a relevant tool for provincial and territorial governments, public health authorities, contact-tracing officials, front-line health care workers and ultimately Canadians.

Notwithstanding, there have been notable setbacks that have limited COVID Alert from reaching its full potential. These include difficulties in streamlining the distribution of one-time keys ( OTK s) within adoptive provinces and territories; provincial and territorial jurisdictions that have not adopted the app, limiting the pan-Canadian use of the app; as well as technical issues that have affected the app's functionality for some users.

That being said, the Council's continued recommendation has been for all levels of government to collectively adopt the app as well as find solutions to the distribution of OTK s that are essential to the app's effectiveness. As economic and social activities increase, provinces and territories should embrace additional exposure notification features, such as venue-based notifications. As the scientific community continues to make progress on the evolving science on COVID-19, COVID Alert remains a relevant digital tool, alongside other tools and measures, in the fight against the spread of the virus.

Executive summary

Pillar 2: COVID Alert as a Government Service

  • Brand trust for Canadians nationwide
  • Positive experience for app users
  • Leveraging of emerging digital solutions

In March 2021, the COVID-19 Exposure Notification App Advisory Council published its First Interim Report of the COVID-19 Exposure Notification Advisory Council. In it, the council examined the first pillar of the work plan, with a focus on increasing the accessibility of the app and reducing barriers to its adoption, usage, and retention. This second interim report examines the second pillar of the Council's work plan and details the Council's advice to the Government of Canada on assessing the COVID Alert app as a government service.

This pillar supports the Council's Terms of Reference program of work as follows:

  • advice on the ongoing development of the app; review of the protocols that govern the operation of the app, and advice on procedures or features to maintain high standards of citizen safety, security, privacy and public health; and,
  • advice on maintaining robust privacy policy and protocols that align with the principles for digital applications set out by Federal, Provincial and Territorial Commissioners of Privacy, and reflect the results of the Government's ongoing engagement with the Privacy Commissioner of Canada.

It is important to note that while COVID Alert's lifespan is tied to the duration of this current pandemic, the lessons learned from this initiative will help inform how the digital government services can be developed to offer Canadians and health care works better tools when dealing with future public health crisis.

The COVID Alert app is Canada's close contact exposure notification service and is one of the tools made available to Canadians to help slow the spread of COVID-19. For COVID Alert to send exposure notifications to users, it requires another user – one who has received a positive COVID-19 test result – to enter an alphanumeric OTK code in the app. The use of the app, along with OTK s to alert users of possible exposure to the virus, is intended to help break chains of transmission and prevent community spread.

To this end, for this second report, the Council focused on two overarching questions to help further enhance the COVID Alert app as a government service. These include:

  • How can the Government of Canada improve the utility and usage of the COVID Alert app, including through the use of aggregate data-driven insights, to ensure widespread and pervasive use of OTK s that allows users to input their positive diagnosis?
  • How can the Government of Canada enhance the functionality of the app through feature integrations, such as QR codes and wearables, to expand the app's services across Canada and drive increased adoption and usage, and should they do so?

Throughout an evolving pandemic, the Council continues to provide expert advice and guidance to the Government on COVID Alert as a government service during this public health emergency. This advice has remained the basis of the first pillar and continues into the third pillar: COVID Alert app as a public health tool.


As the COVID Alert app was initially launched, the Government of Canada simultaneously created the COVID-19 Exposure Notification App Advisory Council, which was tasked to ensure the app meets the highest standards in public health outcomes, privacy, and technology.

In March 2021, The Council published their First Interim Report of the COVID-19 Exposure Notification Advisory Council which outlines Council's recommended strategies to increase accessibility for specific populations; and strategies to reduce barriers and increase adoption, retention and proper use of the app in response to the Pillar One: Social and Economic Determinants of App Adoption, Retention and Use.

The Government of Canada has taken action on these recommendations, in some cases immediately after being discussed. A number of these recommendations and changes are also relevant to enhancing the tool as a government service. These include: turning the app on/off, clearing the exposed state, support for additional languages, increasing the app's functionality on older Apple and Google operating systems, and reorganizing display screens and messaging features, among others.

While the Council supports the fact that the COVID Alert app aims and can provide valuable public health benefits, it also recognizes that challenges persist in terms of achieving its potential. Some of these challenges have remained a focus for the Council such as the need for pan-Canadian participation, and the efficient distribution and use of OTK s within participating provinces. Both factors persist and continue to be the driving factors that limit the efficacy of the app. Additionally, some technical challenges were identified where COVID Alert is not working as intended on certain smartphones, specifically on Android phones, limiting the app's ability to achieve its full potential.

There are nine provinces and territories who have adopted the app with the last jurisdiction to join being Northwest Territories in November 2020; the app continues to be unavailable in Alberta, British Columbia, Nunavut and Yukon. More than 6.9M Canadians have downloaded the app, and more than 63,000  OTK s have been entered.

From the above and expanding on the observations and recommendations in Pillar One, the Council further examined ways to improve the delivery of the COVID Alert app as a government service. As a result, the following recommendations were provided by the Council as part of Pillar Two:

  1. Addressing the utility and usage of the COVID Alert by:
    1. Improving the rollout of aggregate metrics data collection, through strategies which would provide broader data-driven insights on the adoption / use of the app while continuing to protect user privacy; and
    2. Strongly recommending that the Government of Canada escalate and intensify its efforts to ensure that OTK s are provided automatically at the time of diagnosis, including an examination of the potential centralization of OTK distribution, and further engagement with Provinces and Territories.
  2. Enhancing the current and future functionality of the app through new features:
    1. Quick Response (QR) codes, which would enable venue-based exposure notifications, allowing users to be notified by public health authorities should an exposure risk be later identified; further supporting the efforts of public health authorities; and assisting in the safe re-opening of the economy;
    2. Investigating possible COVID Alert integrations with wearable devices.

The advice of the Advisory Council addresses the key considerations, challenges, and opportunities related to the Government of Canada's continued updates and feature integrations for the COVID Alert app. Furthermore, the advice generated by the Council serves not only to immediately impact the effectiveness of the app, but also to help provide a framework and guiding principles for future digital services provided by the Government of Canada.

Pillar Two: COVID Alert as a Government Service – Setting the Stage

Addressing the utility and usage of the COVID Alert app

Additional In-app Metrics

As the app was launched, it was intentionally designed to proactively alleviate privacy concerns by providing very limited data to the government. This approach generated a positive initial reception by Canadian privacy expertsFootnote 1 and was an important factor in initially encouraging Canadians to adopt the app. Health Canada ( HC ) has continued to provide regular public updates on how many people are using COVID Alert, which provides the total number of downloads and total number of OTK s used. However, the initial decision to roll out the app in a manner that captured very limited data remains a challenge. By significantly limiting the collection of data, it is difficult to judge the performance of the app, and thus evaluate its impact and effectiveness at addressing transmission vectors of COVID-19 across Canada.

As a result, the Government of Canada began to explore options to collect additional data to better monitor the app's performance and address a number of issues raised about limited data availability, while continuing to preserve user privacy, including:

  • Measuring the performance of the app: the number of downloads and total number of OTK only account for a small portion of activity performed by the app. They do not account for notifications which are issued to advise Canadians on next steps when they have been exposed to a positive COVID case.
  • Encouraging app uptake: Additional information on app usage and activity may better enable the Government of Canada to observe differences in the uptake of the app across jurisdictions, and focus efforts to increase awareness and adoption of COVID Alert.
  • Encouraging provincial and territorial adoption: Some provinces and territories expressed concerns that without additional metrics in the app, it would not be possible to estimate the app's contribution to curbing the pandemic, or chances of too many "false positive" rates. From these, some had previously indicated that more empirical evidence could encourage them to reconsider their decisions not to adopt COVID Alert.

The ability to quantify the effectiveness and accuracy of the app provides a means to help address these concerns.

The decision to collect additional data from the app followed extensive consultations with Council as well as the Office of the Privacy Commissioner, provinces and territories, Apple, and Google. Some members of Council noted concerns about the perception of "surveillance creep", whereby the public perceives that adding additional protocols and updates introduced in the app could be initially perceived as invasive. The decision to collect additional aggregate data through the app may be a contributing factor to the perception of risks to privacy, regardless of the intention to continue protecting user privacy and not collect any personal data about individual app users. Council members indicated that there needed to be clear communication in order to avoid harming public trust and reducing the adoption of the app by individuals who identify privacy as their primary concern with its usage.

As a result, to enable better understanding of the performance of the app, while preserving the app's privacy-protecting approach, on February 9, 2021 the Government of Canada announced that the app would be updated to collect aggregate metrics on:

  • The number of active users and downloads per province or territory;
  • The number of exposure notifications sent;
  • The number of users who enter an OTK after receiving a notification; and,
  • Technical performance to help ensure the app is working correctly.

Efforts to optimize the distribution of one-time keys

As of May 31, 2022, more than 63,000Footnote 2 app users have entered OTK s following a positive COVID-19 diagnosis in order to notify others that they may have been exposed. This estimate represents the number of Canadians that satisfy a few conditions: have downloaded the app, get tested for COVID-19 and test positive, obtain an OTK and enter that key in the app to notify others of possible exposure. Considering there have been over 2,777,000 COVID-19 casesFootnote 3 in adoptive provinces and territories, the number of OTK s entered represents a small number of the actual COVID-19 cases. The Government of Canada has been engaging and encouraging provinces and territories to review and adjust OTK processes since fall 2020. The data suggest that there is a significant and urgent need to continue to enhance the overall process of OTK generation and distribution.

Approximately 69% of OTK s provided are entered into the app to notify others of possible exposure. This demonstrates that if app users who test positive are subsequently provided an OTK , they are very likely to enter it into the app.

Presently, the 10-digit alphanumeric OTK s are provided to the app users following a confirmed positive diagnosis either via telephone, directly by a public health official, or via a secure portal. The act of a user entering the OTK into the app launches the exposure notification process. This distribution process falls within provincial and territorial jurisdiction. While provinces and territories that have adopted the app have been responsive in adding processes for providing OTK s as part of their public health response, each jurisdiction has implemented the provision of OTK s in different ways, yielding distinct processes for the issuance of OTK s. The Council notes variations in public health scripts, information technology systems, and secure online portals between different participating jurisdictions has an impact on the provisioning and submission of OTK s.

Similarly, there are technology-related considerations related to the Google / Apple Exposure Notification ( GAEN ) framework that also limit the widespread generation of OTK s. Per the GAEN frameworkFootnote 4 , an individual can only upload their OTK to notify other users of a potential exposure after one or more of the following conditions are met:

  • A user has been confirmed by a medical provider to have tested positive for COVID-19;
  • A health authority authorized a user-initiated self-reported positive case based on symptoms (if supported by the app).

These current conditions therefore place the entirety of the OTK distribution on health authorities within participating provinces and territories.

International Comparisons

In 2021, HC conducted an international analysis of various countries' healthcare frameworks, which similarly used the Google / Apple Exposure Notification ( GAEN ) framework for their exposure notification app service. It is important to note that healthcare frameworks vary internationally from centralized, "semi-decentralized", and decentralized depending on the national government relationship to sub-national government health authorities.

Within decentralized healthcare systems in the United Kingdom ( UK ) and the United States ( US ), many jurisdictions have chosen to distribute OTK s either verbally via telephone or through an SMS message. Each jurisdiction has varying and particular approaches regarding the lead organization that distributes the OTK . In some US and UK jurisdictions ( e.g. Scotland), health professionals at the national and state level are tasked with providing OTK s, while other jurisdictions have relied on local health authorities ( e.g. Ireland), including enabling doctors who initially performed the COVID test to subsequently provide OTK s.

Some countries offer unique options for OTK distribution. In Japan, a healthcare centre provides an option for users to obtain test results and OTK s through SMS or email. In Germany, users can use QR codes they receive during their test to retrieve results and voluntarily upload their temporary keys after the app verifies the user's positive test result. In Cyprus, a user has the ability to export their location data to contacts of their choice.

Alternatively, countries such as Denmark, Norway, and Estonia do not use OTK s but instead allow users to use their country's public health online portal to upload their positive result without an OTK . Health authorities in these jurisdictions ensure that only users who test positive can share their information through a digital signature provided within the app to login to public websites.

Based on the number of app downloads as a proportion of smartphone users, when compared to other countries, Canada had a lower level of app uptake than some of its European counterparts. Roughly 28% of smartphone users in on-boarded Provinces and Territories had downloaded the COVID Alert app. Countries such as France, Germany, and the United Kingdom had experienced greater success in the adoption of their apps, with roughly 34%, 45.6%, and 37.8% of smartphone users having downloaded their apps, respectively.

However, Canada's level of uptake was better than that of New Zealand, which used a similar notification app. Approximately 136% of New Zealand's population owned a smartphone, only 20% of their overall population had downloaded the app. This accounted for roughly 15% of the smartphone users in the country.

The Council is aware that the Government of Canada continues to seek concurrence of provinces and territories to design and implement solutions to improve OTK distribution. The Government of Canada also continues to engage with a number of international partners on best practices on the design and implementation strategies of OTK s, and to gain a better understanding of which methods best optimize their distribution.

Enhanced and emerging technologies to increase app effectiveness

Venue-Based Notifications

Despite ongoing promotional efforts and enhancements to the COVID Alert app, the rate of new downloads has continued to slow down since January 2021. A similar pattern has been observed in other countries using exposure notifications apps. This trend may coincide with the start of vaccination programs.

Similarly, some provinces have noted limitations of COVID Alert to support contact-tracing at venues and events based on its current abilities. As a result, some provincial and territorial governments have requested the app provide a technology-based functionality to issue venue-based exposure notifications. This functionality could relieve burdens on participating venue operators by simplifying data collection requirements, and could also assist contact tracing efforts by public health authorities by enhancing records of places visited by users.

As provinces and territories mandate closures of specific businesses in an effort to limit COVID-19 transmission, it is widely acknowledged that the full reopening of the economy will require additional safety measures. Despite the continued ramp-up of Canada's inoculation campaign for COVID-19, the COVID Alert app could potentially play a role as residents begin to regain confidence in the safety of public spaces.

This is particularly important as research continues on the transmission of the virus by vaccinated people who get infected, especially as variants such as Delta can impact the first dose effectiveness. Currently, the Public Health Agency of Canada ( PHAC ) maintains the same recommendations for contacts of COVID-19 cases regardless of vaccination status or vaccine rollout progress.Footnote 5 Recommendations will be updated as needed based on new evidence regarding vaccine effectiveness and coverage in Canada, including whether vaccines are capable of preventing infection and/or transmission among those immunized, as well as new information regarding vaccine effectiveness against variants.

Canadians who have been vaccinated will still need to be aware of possible exposures, and are encouraged to take proper precautions to protect others. In addition, vaccinated individuals likely to frequent higher exposure risk venues could benefit from COVID Alert notifying them of possible exposure in order to guard against symptoms and protect their communities. There is also the population of Canadians who may choose not to be vaccinated that would benefit from the COVID Alert notifications at venues.

QR Codes for Venue-Based Exposure Notification

In many countries around the world, the use of QR codes within exposure notification apps has become an increasingly important tool to reduce the spread of COVID-19. QR codes are a type of barcode that can be read by a smartphone camera. QR Code applications, in the context of the COVID Alert app, would enable facilities ( e.g. , retail, salons, bars, gyms) to display a QR code that could be scanned by a COVID Alert app user upon entry. If public health officials later identify that an exposure risk occurred at that venue while the user was present, they can send a notification of possible exposure and that user will receive guidance about what actions to take. This approach preserves privacy since it is voluntary, requires no personal information to be shared with the venue, and does not track the user; the QR code information is only stored on the user's phone.

App users would ideally be able to utilize the app in lieu of providing their personal contact information to businesses as they enter, if participating jurisdictions make the QR Code service an alternative to the manual collection of contact tracing information or third-party applications. This method provides greater privacy preserving safeguards than the aforementioned techniques. Similarly, many businesses would benefit from reducing their burden to directly collect and temporarily retain the personal information of app users who choose to 'check in' via QR code. Unlike QR code systems currently offered in the market, QR codes in COVID Alert would be free and would not require patrons to enter personal information, such as name, email address or phone number.

Notifying app users based on when they visited a venue can offer provinces and territories a number of benefits as they take into account the number of reported positive cases at a venue. Provinces and territories will have access to a technology platform to rapidly issue notifications of possible exposure and can vary the advice in exposure notification messages to follow public health guidelines set by their provincial and territorial health authorities and PHAC . Messages can also vary for close contact exposures or venue-based exposures ( e.g. isolating and monitoring for symptoms or getting a COVID-19 test).

As the COVID Alert app continues to be voluntary, there are no requirements to make the QR code system mandatory for businesses. In New Zealand, England, Wales, and parts of Australia it is mandatory for some venues and forms of transportation to display a QR Code. Furthermore, many international COVID-19 apps ( e.g. , UK , New Zealand) use QR codes for notifying users of a possible exposure at a location or event. The UK has credited the addition of the QR Code feature with high uptake and use of their app.

The Council supports the venue-based exposure notification services, through the QR codes, while protecting the public's privacy as a replacement for requiring businesses to capture and store the personal information of customers, depending on the respective requirements within each participating jurisdiction. Furthermore, the Council continues to strongly support the voluntary nature of the app despite the prospective functionality provided by QR code implementation.


In addition to discussing the integration of QR codes, the Council deliberated on potential integration of complementary or wearable devices for instance where a smartphone is not available or cannot be carried. The Council reviewed current pilot projects emerging and covered issues around interoperability of wearables with the COVID Alert app; the target market for wearable integration; and privacy-related considerations.

Wearables were initially thought to offer another near-term option to Canadians who cannot use COVID Alert due to workplace restrictions and/or the cost of a compatible smartphone. Presently, the COVID Alert exposure notification framework operates using Bluetooth on compatible smartphones and tablets only. Adding low cost, easily carried, single purpose complementary devices could expand access to COVID Alert. Research was conducted on wearables to ascertain whether they would be effective tools in circumstances or sectors where it is not practical to have a smartphone, such as manufacturing plants, schools, long-term care homes, construction sites, and aviation. However, there were a number of limitations identified with this technology which complicates their near-term implementation.

Complementary devices are small battery operated Bluetooth devices that may be able to receive and broadcast the same random codes that COVID Alert uses for close contact detection. They are available in a variety of formats which are designed to be easily carried, like bracelets, key fobs, or lanyards.

  1. Wearable devices, such as a non-disposable wristbands or tags emit a sound when users are within six feet of each other; logs of devices that have been in close proximity are kept in order to support future notifications. Air Canada has piloted these wearables in their Systems Operations Control centre and has expanded the pilot to their cargo area in Toronto.

    As of December 7, 2020, the pilot saw a 99% adoption rate from employees in the pilot locations and over 30,000 interactions tracked. According to the company, the integration has been effective. While this technology continues to be developed, updated information on next steps are not known at this time.

    Likewise, Waywayseecappo First Nation in Western Manitoba has piloted the wearable devices and further adopted the technology for use across the community. However, it has proven difficult to integrate COVID Alert into these devices while maintaining its compatibility with the GAEN framework.

  2. Wristbands are low cost, simplified, portable and disposable wearables that utilize Bluetooth technology. These devices were successfully deployed by Hockey Canada at the World Junior Hockey Championship in Edmonton. At this time, there is no additional information on the results of this deployment.

    The Toronto Wolfpack rugby club has also reached an agreement with the device manufacturer to provide the wristbands to fans this season.

Bluetooth devices may be able to share the same codes as COVID Alert, which would theoretically allow them to be integrated. Other devices that use GPS , Wi-Fi, LoRA, or other radio technologies would be more technologically complicated to integrate and may introduce additional technical and/or privacy concerns.

The Government presented their analysis on the potential of wearables technology to the Council. The Council reviewed the following considerations related to the potential integration of COVID Alert within a number of complementary wearable devices:

  • Notification processes: different wearables have different options for advising of notification, including: notifications on the device itself, or notification sent to an email address, phone number, or mobile app. Purpose built solutions could interact with the push notifications for wearable devices. To enter an OTK , users would likely require access to a mobile app or computer;
  • Technology support: COVID Alert currently requires a compatible smartphone with an iOS or Android operating system. Wearable devices cannot currently be integrated onto the GAEN based on Apple/Google framework requirements. GAEN would either need to accommodate, or a wearable platform would need to work inter-operably with GAEN ;
  • Compatibility: Wearables would expand the close contact exposure notification network; wearable users may not benefit from other COVID Alert services such as the QR code service;
  • Privacy and Security: complementary devices typically store user data centrally, not within the device itself for notification processes, personal information that is not required for COVID Alert would possibly be collected;
  • Distance: If the 2 meter 15 minute exposure notification logging guidance were to change or be significantly reduced, the efficacy of these devices would be compromised with a reasonable standard of notification. If the distance were significantly reduced, there would be anticipated issues with the app's accuracy in detecting an exposure risk. Conversely, if the distance were expanded, then the app would potentially notify too many individuals who were not at risk of exposure.

The Council has noted that the actual addressable market for such devices is presently low. Furthermore, the applicability of these devices further narrows when considering that they would specifically target locations where mobile device usage is prohibited or limited.

Council's Advice and the Government of Canada Response

As part of its discussions relating to Pillar 2: COVID Alert as a government service, the Council puts forward two key enhancements: 1) improving the utility and usage of the COVID Alert app and 2) enhanced and emerging technologies to increase app effectiveness.

Improving utility and usage of COVID Alert

  1. One-Time Key Distribution – The Council wishes to reiterate the importance of addressing this issue, and strongly expresses its view that insufficient OTK distribution hinders the effectiveness of the app in accomplishing its core function. The Council has directly expressed the urgency and importance of this issue in a letter addressed to the Minister of Health; the Minister of Innovation, Science and Industry; and the Minister of Digital Government in March 2020.

    The COVID Alert app can be an effective tool to support public health measures, provided that OTK s are widely distributed and used. In line with our mandate, the Council would like to reiterate the critical importance for all levels of governments – federal, provincial, and territorial – to take all necessary actions to distribute OTK s to all individuals that receive a positive COVID-19 test result.

    The Council again urges all levels of government – federal, provincial territorial and municipal to ensure timely notification enabled through the widespread use of OTK s. This coordination is critical to the success of exposure notification applications in breaking the chain of infection.

    The Council recommends that the following options regarding the optimization of OTK distribution be considered and implemented:

    • Standardized Delivery of OTK s via SMS : To optimize the usage of OTK s, a potential option is to ensure OTK s are sent by SMS text message to all individuals who test positive for COVID-19, regardless of whether or not they are users of the app. Council recommends that all levels of governments – federal, provincial, and territorial investigate the possibility to include OTK s within currently existing individualized public health messages (either via email or SMS ) by public health authorities.

      In particular, SMS distribution of OTK s removes the risk of transcription error by the user and eliminates the need for users to manually write down their OTK while on the phone with a public health official. App users will instead be able to input their OTK from the text message into the app. Pursuing this option, through already automated systems, would remove the burden on the individual who tested positive to know how and when to obtain a OTK and remove the burden on public health authority who need to generate the OTK s as part of their process.

      The Council is aware that the Government of Canada is working with provincial and territorial governments to introduce the distribution of OTK s via SMS . The Council is also aware that unique and varying IT infrastructure within provinces and territories will need to be individually assessed to determine capability of automating this function.

    • Magnifying the communications approach to highlight the importance of OTK s: The Council recommends that all levels of governments focus their communication products on highlighting the importance of OTK s and the positive effect COVID Alert can have on the pandemic, especially during the reopening of the economy.

      Notwithstanding the above recommendation, the Council does note that since its last report, the Government of Canada translated the COVID Alert video on how the app works in 16 languages (including English and French), produced and designed a targeted video and social media campaign to promote the use of OTK s, produced and distributed a fact sheet for health workers about the app and OTK s, and updated its website to clarify information pertaining to OTK .

  2. Aggregate Metrics – The Council supports the collection of aggregate metrics that respect users' privacy and simultaneously allow the Government of Canada to better understand the effectiveness and impact of the app. In support of the collection of aggregate metrics, the Council offers the following advice and recommendations:

    • Public engagement and communications on aggregate metrics: The Council notes the continued need to engage with the Canadian public through communications that confirm the continued focus on user privacy, while introducing and explaining the benefits of in-app metrics. Special attention should be provided to vulnerable communities at a higher risk of exposure to COVID-19. The Council noted that certain metrics, such as the number of active users per jurisdiction, may create unease among current and prospective users. The Government of Canada should consider a communication strategy that focuses on addressing the potential concerns related to each of the aggregate metrics that are being collected, including explaining the privacy protections for that information.
    • Public benchmarking of COVID Alert: To help increase the transparency of aggregate data collection, the Council recommends that the Government of Canada make aggregate data available to the general public. The Council has also asked the Government of Canada to brief the Council systematically at meetings of the Council regarding established and emerging insights that are informed by the metrics in order to help inform the Council's recommendations going forward.

      Following the update to the app in February to collect aggregate in-app metrics, the Council has been kept abreast of the progress and notes the current challenges in the collection of metrics, specifically with regards to smartphones where the app is not working as intended. The Council raised the need to clearly articulate the challenges that surfaced following the update to the app in February and the caveats associated with the numbers when publicly communicating these with Canadians. The Council supported the release of the metrics that are now available on the COVID Alert website.

Enhanced and emerging technologies to increase app effectiveness
  1. QR Codes – The Council expresses its support of QR codes to provide venue-specific and privacy-protected exposure notifications. The Council also recognizes it presents a powerful contact tracing feature that enhances COVID Alert as a government service and should be made available to all provincial and territorial governments, including those that have and those that have not adopted COVID Alert to adopt and use this new functionality.

    As pan-Canadian vaccination efforts continue and people begin to gather once again, the Council recognizes the importance of continuing to follow COVID-19 public health measures and guidance, including the use of COVID Alert in order to protect our communities. QR codes offer a unique functionality to instantly notify multiple users of potential exposure to COVID-19, more so within venues that do not currently collect contact information, such as grocery stores, major retailers and sporting facilities. To allow for a smooth introduction of QR codes, the Council makes the following recommendations to the Government of Canada:

    • Continue and sustain engagement with provinces and territories to ensure they are fully committed to the successful implementation of the QR code within their respective public health processes and safe jurisdictional re-opening plans, as an additional tool to help limit the spread of the virus prior to launching this new feature. This engagement will also help to proactively address concerns related to the utility of the app in augmenting provincial and territorial contact tracing efforts by informing citizens though the app to isolate or to go get tested.

      Additionally, provinces and territories should consider the voluntary venue-specific QR codes as an alternative, where appropriate, for businesses required to collect visitor information for contact tracing purposes. This would provide both patrons and businesses who are required by legislation to collect contact information with a more privacy-centric option for gathering this information, and also help public health authorities rapidly notify individuals of potential venue-based exposures.

    • Consider specific design, marketing, and communications suggestions regarding QR codes, with targeted messaging deployed to address different audiences including provinces and territories, businesses and business associations, and the general public. Messages should focus on the privacy and ease enabled by QR codes while simultaneously expediting the process by which an individual would be notified of a potential exposure.

  2. Wearables – The Council has reviewed and discussed potential integration points between COVID Alert and a variety of wearable devices. Presently, the Council recommends against further integration with wearable devices on a cost-benefit basis and given the actual addressable market for such devices is presently low.


The government service dimension of the app is linked very much to the adoption and use of the service by the general population. As such, discussions and advice provided by Council members were varied across elements for improving existing operations and looking at new features that enhance the service.

While the Council appreciates that the COVID Alert app has not reached its full potential, it also noted that close contact exposure notification services are still relatively new. With privacy as the primary principle of the app, certain features, including data collection to substantiate effectiveness of its use, are limited. While there has been a trade-off in preserving privacy at the cost of obtaining higher quality data, the app has still collected sufficient data to help inform on the efficacy of the service and how improvements could be made to better protect Canadians against the spread of COVID-19.

The Council looks forward to continuing its deliberations on these and other issues, and to continuing to explore key topics under Pillar 3 – COVID Alert as a public health tool.

COVID-19 Exposure Notification App Advisory Council


Jean-François Gagné, ServiceNow

Carole Piovesan, INQ Data Law


Simone Atungo, Vibrant Healthcare Alliance

Dr. Jonathan Dewar, First Nations Information Governance Centre

Dr. Bunmi Fatoye, Winnipeg Regional Health Authority

Dr. Éloïse Gratton, Borden Ladner Gervais

Andrew Harrison, Verily Life Sciences

Dr. Brenda McPhail, Canadian Civil Liberties Association

Dr. Derek Ruths, McGill University

Dr. Margo Seltzer, University of British Columbia