Executive summary of the Privacy Impacts Assessment
This report examines the privacy impacts associated with the Young Canada Works (YCW) initiative.
About Canadian Heritage
Canadian Heritage (PCH) was established as a federal department in 1995. Its mandate is to promote Canada’s culture, history and heritage, and to protect Canadian identity and values. Canadian Heritage also has the responsibility to build strong communities, including Youth.
About Young Canada Works
Young Canada Works (YCW) is the Canadian Heritage initiative of the Government of Canada’s Youth Employment and Skills Strategy (YESS), a horizontal program led by Employment and Social Development Canada and delivered in collaboration with eleven federal departments, agencies, and Crown corporations, including PCH. The YESS is part of the Government’s commitment to help youth gain the skills and work experience needed to make a successful labour market transition. YCW provides opportunities to students and graduates for short-term job and internship in the areas of heritage, arts, culture, and official languages. Participating employers receive funding to supplement wages to hire these employees/graduates.
On the YCW online application website, students create profiles, search for employment with approved employers, and express interest in job opportunities. Concurrently, eligible Canadian employers in the fields of arts, culture, heritage and official languages apply for wage subsidies from the initiative. Employers create accounts on the website, apply for funding for positions, receive notification of approval, hire students, and complete required forms using the YCW online application. A third user-type, non-governmental organizations known as Delivery Organizations (DOs), administer the initiative for a certain business sector or region. The DOs administer funding for jobs; evaluate and approve positions; and report expenditure and participant demographic information back to PCH.
Purpose of this privacy impact assessment
PCH is named in the Schedule to the Privacy Act and is subject to the privacy policies and directives of the Government of Canada. Under the Treasury Board of Canada Secretariat’s (TBS) Policy on Privacy Protection, all federal institutions subject to the Privacy Act are required to undertake an assessment of the privacy impacts associated with the development or design of new programs or services involving personal information. Privacy Impact Assessments (PIA) are also required when personal information is used as part of a decision-making process that directly affects an individual.
PCH has the responsibility of funding the DOs, supporting stakeholders throughout the process and reporting to Employment and Social Development Canada (ESDC) for the YESS strategy. This involves the collection of personal information for the purpose of an administrative decision about an individual. Therefore, the purpose of this PIA is to mitigate all privacy risks link to this process.
The YCW initiative is delivered through PCH Official Languages Branch and Heritage Group programs, which are accountable for their respective program results linked to YCW. The PIA was completed under the direction of the Young Canada Works Secretariat (housed in the Community Building and Youth Branch), which is the administrative coordinator of the YCW initiative and liaison with ESDC (YESS). The Secretariat coordinates common delivery tools, including the database, and reporting related to the YCW initiative.
Scope of the Privacy Impact Assesment
This PIA is for the administration of an activity. Only personal information, with no contextual sensitivities, is collected directly from the individual and employers via an interactive web application, and this information is stored in the application’s database. YCW also collects employment equity information from students who voluntarily submit this information. The personal information is disclosed to Delivery Organisations and employers to manage the program and ESDC for the purpose of reporting for the YESS Strategy. The activity occurs every year. This activity uses personal information for external administrative purposes and affects certain individuals. No enhanced identification methods or surveillance are used. The personal information is transmitted using wireless technologies. The privacy risk for this activity is evaluated as medium.
Summary of recommendations
After analysis of privacy risks, the ATIP recommended the following improvements, all of which have been addressed by the program:
- Submit the drafted Personal Information Bank to the Treasury Board (TBS) for registration and inclusion in the PCH chapter of Information about Programs and Information Holdings.
- Regular monitoring visits to DOs to be conducted by PCH officials, as per the terms of the Contribution Agreements.
- Coordinate Access to Information and Privacy training for YCW staff.
- Update privacy notices as advised by ATIP, so that it can include the minimum requirements set by TBS in the Directive on Privacy Practices.
Management has fully addressed all three of the recommendations made by ATIP. With the recommendations implemented, the resulting residual risk on the YCW system is low.
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