OPC Takes Aim at Biometrics – What  Canadian Advertisers Need to Know 

Biometrics are moving from hype to real-world use in digital out-of-home (DOOH) and retail media. They’re mainly used for anonymous audience analytics (e.g., presence, dwell, age-range estimation) and sometimes to trigger dynamic creative insertion. In Canada, regulators classify biometric information as sensitive data, and Québec mandates advance notification before the use of biometric systems.  If you’re planning or buying media that touches cameras or biometric inferences: ensure you build privacy into the brief, ask the right vendor questions, and document consent paths—especially for Québec. 

What counts as “biometrics” in digital advertising? 

In advertising, biometrics typically means computer-vision analytics that infer attributes from faces or bodies (e.g., a likely age range, attention time, or traffic volumes). While fingerprints or iris scans are common in security, they’re rarely used in ad targeting. Regulators consider biometric information highly sensitive because it’s closely tied to a person’s body and difficult to change. 

Even “anonymous” facial analysis can fall within biometric guidance if it uses facial characteristics to classify people. 

Biometric Potential with DOOH and Retail Media  

Audience Measurement – On-premise cameras estimate traffic, attention, and sometimes age-range to calibrate impressions and verify delivery. IAB’s July 2025 DOOH Measurement Guide discusses computer vision, “presence of person,” and the privacy implications of audience data in DOOH. 

Dynamic creative – Some platforms can vary creative when a screen detects a likely adult audience or a certain level of attention (subject to consent and local rules). 

The use of biometrics is not new. One notable example of biometric technology used in DOOH advertising was Pattison Outdoors’s “Head-Turning Matrix” campaign for Mazda. The activation used a combination of crowd detection and facial recognition technology to monitor passersby and record when they turned their heads toward the display, effectively tracking impressions in real time. 

Planning and Buying – DOOH networks may offer “presence of person”, attention time, or age/gender estimates to optimize loops and dayparts, or to trigger dynamic creative (e.g., different creative when the screen detects a likely adult audience). The 2025 DOOH Measurement Guide outlines standard definitions and urges transparency, MRC-aligned methods, and privacy compliance. 

Regulatory Considerations 

Biometric technologies can enhance measurement in DOOH and retail media, but in Canada they come with elevated compliance requirements. The Office of the Privacy Commissioner of Canada has expressed concerns and recently released guidelines on their use, emphasizing that biometrics should be treated as sensitive information by default. Organizations should plan for Québec’s specific regulatory requirements and adopt a privacy-first approach to system design, including on-device processing, aggregated reporting, and prohibiting image retention. To support the industry, IAB Canada has published a policy brief outlining some of the OPC guidelines and the implications for consent.