Annual report on the administration of the Privacy Act, 2024 to 2025 - Employment and Social Development Canada

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1. Executive Summary

Advancing Trust, Transparency, and Digital Modernization at Employment and Social Development Canada (2024 to 2025)

Employment and Social Development Canada (ESDC) is responsible for developing, managing, and delivering social programs and services, including some of Canada's largest, such as Employment Insurance (EI), the Canada Pension Plan (CPP), and the Passport Program. Given its mandate, ESDC collects and controls a large volume of personal information, involving a range of collection, use, retention, and disclosure activities, as well as coordination with an array of partners and stakeholders. Privacy management continues to be a core component in delivering ESDC's programs and priorities, whether through program delivery, validation of the identity of individuals, conducting research and analysis, or carrying out integrity operations.

Strengthening access to privacy services

In 2024 to 2025, ESDC reaffirmed its commitment to the Government of Canada's Trust and Transparency Strategy by advancing a proactive approach to access to information and privacy. Guided by the leadership of the Corporate Secretary and Chief Privacy Officer, ESDC's Access to Information and Privacy (ATIP) Operations Division and Privacy Management Division (PMD), in collaboration with regional partners, successfully managed a growing volume of requests while maintaining high service standards and by providing strong privacy management support.

During the year, ESDC received 22,451 privacy requests, an increase of 3.2% from the previous year, and achieved an 82.8% compliance rate, as a measure of the percentage of all files that were closed either within the initial 30 days or during an extension period. In addition, the Department processed a record volume of 2.21 million pages for exemptions and exclusions, of which 2.07 million pages were disclosed. In terms of record disposition and disclosure, ESDC processed 4,753 requests in which all aspects of a record were disclosed, accounting for 20.3% of all requests.

To reduce reliance on formal requests and improve client service, ESDC continued to promote digital self-service options, including My Service Canada Account (MSCA) and Canada Revenue Agency My Account. These platforms empower Canadians to access their personal information directly, supporting a more efficient and user-friendly experience.

Embedding Privacy in Digital Transformation and Artificial Intelligence Governance

The Department takes pride in delivering programs and services to Canadians at key stages of their lives. As a steward of large volumes of personal information, ESDC continues to embed privacy protection into all aspects of program delivery, research, and digital innovation. In 2024-2025, the Department expanded privacy training and awareness, ensuring staff are equipped to manage personal information responsibly and ethically.

In preparation for the implementation of the Artificial Intelligence (AI) Strategy for the Federal Public Service 2025-2027, particular emphasis has been placed on supporting the responsible use of artificial intelligence. ESDC prioritized privacy-by-design in AI initiatives. The PMD, in collaboration with the Chief Data Officer Branch, conducted assessments to identify and mitigate privacy risks, ensuring that AI adoption remains transparent, accountable, and human-centric.

Another major transformation initiative, the Benefits Delivery Modernization (BDM) program, is reshaping how the Government of Canada delivers benefits, placing Canadians at the centre of service design. Through BDM, Canadians can expect a simplified and user-friendly digital interface, a single sign-in experience, increased access to self-service, reduced wait times, streamlined applications, and faster benefit payments. To ensure privacy-by-design principles are embedded in BDM's architecture, ESDC has dedicated privacy resources to work closely with the project team. Privacy advice is integrated into the design process, and detailed privacy impact assessments (PIA) are conducted for each release.

Looking Ahead

Modernization of ATIP operations is anticipated to drive long-term efficiencies in the coming years, enhancing ESDC's ability to respond to information requests more effectively. ESDC is on a path towards a more proactive stance on ATIP management, in addition to an ongoing commitment to continuous improvement in service delivery, all while adapting to the evolving needs of Canadians in a rapidly changing digital landscape.

By aligning with the Government of Canada's principles of openness, accountability, and responsible innovation, ESDC is well-positioned to meet the evolving needs of Canadians in a dynamic digital landscape.

2. Introduction

Presentation of the report

Section 72 of the Privacy Act requires the head of a federal institution to submit an annual report to Parliament on the administration of the Act following the end of every fiscal year. This is ESDC's annual report to Parliament on the administration of the Privacy Act for the 2024-2025 fiscal year.

There are no ESDC wholly owned subsidiaries or non-operational institutions on which to report.

Purpose of the Privacy Act

The purpose of the Privacy Act is to extend the present laws of Canada that protect the privacy of individuals with respect to personal information about themselves held by a government institution, and to provide individuals with a right of access to that information.

These rights of protection and access are in accordance with the principles that individuals should have a right to know why their information is collected by the Government, how it will be used, how long it will be kept and who will have access to it.

About ESDC

The Department of Employment and Social Development Canada, commonly referred to as ESDC, is the Government of Canada's department responsible for developing, managing, and delivering social programs and services. The mission of ESDC, including the Labour Program and Service Canada, is to build a strong and more inclusive Canada, to support Canadians in helping them live productive and rewarding lives and to improve quality of life for Canadians. ESDC's fulfills its mission by:

ESDC is led by one Minister, supported by five deputy ministers responsible for its day-to-day operations, budget, and program development.

With over 41,000 employees, ESDC is one of the largest departments within the Government of Canada. Operating across Canada, 73% of its employees work outside the National Capital Region.

Organization of ESDC (as of March 31, 2025)

Mission: The mission of Employment and Social Development Canada, including the Labour Program and Service Canada, is to build a strong and more inclusive Canada, to support Canadians in helping them live productive and rewarding lives and to improve Canadians' quality of life.

Minister:

Deputy Ministers:

Employment and Social Development

Responsible for policy development and program design and management for:

Branches:

Labour Program

Responsible for labour issues affecting federally regulated industries in Canada, including:

Branches:

Service Canada

Provides Canadians with services and information in person, online, by phone and by mail and is a single point of access to ESDC and other Government of Canada programs. It is responsible for providing:

Branches:

Internal Enablers

3. Organizational context

ESDC's Corporate Secretary and Chief Privacy Officer

ESDC's Corporate Secretariat Branch is responsible for issuing and overseeing the implementation of the Department's privacy management policy and providing privacy advice and guidance. It also processes ESDC's privacy requests in the National Capital Region. These activities are conducted by the ATIP Operations Division, with functional support from ESDC's four regional branches, and the PMD (see Figure 2). During fiscal year 2024-2025, ESDC prepared for organizational changes to support the anticipated introduction of new ATIPXPress processing software and national workload management, which are expected to launch in the coming year.

The Corporate Secretary heads the branch and is ESDC's designated Chief Privacy Officer (CPO). The CPO is the Department's functional authority on all privacy matters, including privacy request processing and the management of personal information. The CPO provides strategic privacy policy advice and maintains ESDC's privacy management program, which includes the assessment of privacy risks, determination of compliance with privacy legislation, policies, and standards, and the delivery of privacy training, all of which are crucial in implementing a privacy-by-design approach.

Access to Information and Privacy Operations Division

The ATIP Operations Division administers the Access to Information Act and the privacy request components of the Privacy Act for ESDC. It leads and advises on the processing of all ESDC requests under the Access to Information Act, performs line-by-line reviews of records requested under the acts, and delivers training and awareness sessions to departmental employees on their administration. The Director of ATIP Operations is ESDC's designated ATIP Coordinator.

During the fiscal year, the responsibility of processing requests continued to be shared between the ATIP Operations Division and the Department's four regional branches: Atlantic, Ontario, Quebec, and Western and Territories. The ATIP Operations Division was responsible for coordinating ATIP activities in ESDC's branches and regions, which include:

The ATIP Operations Division is composed of an intake unit and ATIP processing teams. At the end of the 2024-2025 fiscal year, there were approximately 31 ATIP Operations employees.

Figure 1: Organization of the Privacy Function in ESDC
Diagram of the access to information and privacy function at ESDC
Text description of Figure 1

Corporate Secretary and Chief Privacy Officer's office

  • ATIP Operations Division:
    • ATIP Intake
    • ATIP Processing
  • Privacy Management Division:
    • Compliance Review and Advice
    • Policy and Risk Assessments
    • Incident Management and Legal Disclosures
    • Strategic Advice and Planning
  • Additionally, the structure shows regional ATIP Operations, which include:
    • Western and Territories Region ATIP Operations
    • Ontario Region ATIP Operations
    • Québec Region ATIP Operations
    • Atlantic Region ATIP Operations

Regional privacy operations

During the 2024-2025 fiscal year, the regional branches played a key role in fulfilling the Department's Privacy Act responsibilities. There were approximately 58 employees in the regions with ATIP processing duties. A network of liaison officers and managers within each region supports the processing of privacy requests and provides advice and guidance directly to program areas while coordinating with ATIP Operations Division.

Privacy Management Division

The PMD is ESDC's centre for privacy policy expertise and is the Department's focal point for authoritative privacy advice. In addition, the PMD:

In doing so, the Division leverages privacy-by-design approaches that integrate privacy considerations in the early stages of new programs, projects, and initiatives. As the Department's privacy centre of expertise, the PMD provides strategic privacy policy and analytical advice to the CPO and ESDC's senior leaders.

The Division is organized into four functional groups consisting of a privacy policy and risk assessment unit, a privacy compliance and advisory services unit, an incident management and legislative disclosures unit, and a small strategic advisory and planning unit. At the end of the 2024-2025 fiscal year, the PMD had 36 employees.

Service Agreement with Accessibility Standards Canada

ESDC has a memorandum of understanding to provide ATIP services for Accessibility Standards Canada, an independent departmental corporation in the Department's portfolio. Established under the Accessible Canada Act, Accessibility Standards Canada is mandated to contribute to the realization of a Canada without barriers on or before January 1, 2040. Privacy services that are provided include request processing, annual reporting advice and statistics, liaison functions, and training. ESDC also furnishes, when required, analysis and advice for PIAs, information-sharing arrangements, disclosures, contracting, legislative and policy compliance, and the management of security incidents involving personal information.

4. Employment and Social Development Canada's privacy regime

Legal framework for privacy

ESDC operates within one of the most complex privacy regimes in the federal government, requiring the effective application and navigation of a myriad of privacy laws and policies. Its legal obligations are set out in the Privacy Act and in the personal information protection provisions found in the Department of Employment and Social Development Act (DESDA). Moreover, with the many collaborative efforts with which ESDC is involved to deliver national programs and services, legal interoperability with Government of Canada organizations, the provinces and territories, and municipal governments is always an important requirement.

The Privacy Act is the federal law that protects personal information under the control of federal public-sector institutions. Extending from the Charter of Rights and Freedoms, the Act is a key foundation piece for preserving the privacy interests of individuals in Canada. It sets the rules for the Government's management of personal information by providing a framework that establishes the requirements for federal institutions on how they can collect, use, retain, and disclose personal information.

The collection and use of personal information by federal institutions are based on lawful authority or legal authorization. Federal institutions can only collect or use personal information with a sufficiently direct connection to legally authorized programs and activities.

Personal information under the control of a government institution cannot be disclosed without the consent of the individual, except in specific circumstances. These include uses that are consistent with the purpose of the original collection, when authorized by federal legislation, to comply with legal instruments, such as subpoenas and court orders, in circumstances where there is a clear benefit to the individual, and where there is a public interest that outweighs the invasion of privacy. Importantly, the Act gives individuals the right to request access to their own personal information held by a federal institution and the right to request a correction to their information when it is inaccurate. The Privacy Act also establishes the Privacy Commissioner, an independent agent of Parliament who oversees the Act's implementation and has powers to receive and investigate complaints.

The administration of the Act by federal institutions, including ESDC, is supplemented by policies and directives. These are issued by the President of the Treasury Board or an authorized delegate.

In addition to the Privacy Act, the management of personal information by ESDC is undertaken in accordance with the statutory obligations in the Department's enabling legislation. DESDA describes the rules for personal information controlled by ESDC and is applied in tandem with the Privacy Act. DESDA sets out the requirements for:

Where the Department delivers services to the public on behalf of other federal institutions and jurisdictions, or when delivering select services for the Government of Canada, the partner's privacy regime, normally the Privacy Act, will apply instead of DESDA.

Privacy Act Delegation Order

Section 73 of the Privacy Act empowers the head of an institution to delegate any of the powers, duties, or functions assigned to that person by the Act to employees of that institution, typically through a delegation order. This instrument assigns the powers, duties, and functions for the administration of the Act that have been delegated by the head of the institution and to whom that delegation has been assigned.

The current Privacy Act Delegation Order, which was approved by the Minister of Employment and Social Development in March 2024, is reproduced in Annex A.

Departmental Policy on Privacy Management

The Departmental Policy on Privacy Management supports a robust privacy regime for the protection and judicious use of personal information by ESDC. Supplementing Treasury Board Secretariat (TBS) policies, directives, and standards, the ESDC policy contextualizes these privacy obligations for the Departmental operating context. It codifies the requirements for the management and protection of personal information, articulates clear and universal privacy policy principles, and specifies roles and responsibilities for the management of personal information, including discrete functional responsibilities and accountabilities. The policy also sets out ESDC's Privacy Management Framework, outlined below, designates the CPO, and establishes the Department's privacy governance mechanisms.

The expected results from the application of the Departmental Policy on Privacy Management include the sound management and safeguarding of personal information by the Department; the implementation of robust practices for the identification, assessment, and management of risks to personal information; and the establishment of clear accountabilities with effective governance structures and mechanisms to protect and manage personal information under ESDC's stewardship.

Privacy Management Framework

ESDC's Privacy Management Framework promotes a proactive approach for the management of personal information by fostering the integration of privacy practices in all departmental functions and privacy by design into the program, system, and business process architecture. The Framework consists of five elements:

The Framework is a clear and succinct foundational element for establishing and operating a comprehensive privacy program in the Department.

Privacy governance at ESDC

ESDC uses a committee structure to support privacy governance, risk oversight, and decision-making. The Department's primary governance body for privacy and the safeguarding of personal information is the Data and Privacy Committee (DPC), which is co-chaired by the CPO and the Chief Data Officer. The DPC is mandated to provide oversight on the management of personal information entrusted to the Department and the management of enterprise data resources. The DPC supports the implementation and maintenance of ESDC's data strategy and privacy management programs, provides oversight on risk management processes for the management of data and personal information, and promotes a departmental culture that recognizes that data is a business asset that should be maximized while respecting the privacy rights of Canadians.

The DPC reports to the Assistant Deputy Minister-level Enterprise Management Committee (EMC). The EMC serves as the Department's horizontal oversight and decision-making body for the implementation of enterprise strategies, plans, policies, and guidelines related to the management of risk, data, information, technology, and security, as well as corporate finances and resources.

5. Policies, procedures, and initiatives

The breadth and scale of ESDC's activities mean that it is responsible for managing one of the largest personal information holdings in the Government of Canada. The delivery of programs and services by the Department involves the collection, use, and disclosure of large amounts of data. Often, detailed, and sensitive personal information is required to determine program eligibility or to deliver benefits and services. Along with its broad mandate and the responsibility to manage immense volumes of personal information, ESDC must operate within a complex privacy legal regime that includes not only the Privacy Act and DESDA but also involves the specific statutory requirements of the Department's federal and provincial government partners.

Throughout 2024-2025, ESDC continued to use and promote a proactive, risk-based approach to privacy management and sought to adapt its activities and processes to the needs of the changing privacy landscape. It applied its privacy lens to the large number of departmental initiatives, some of which will involve the large-scale collection, use, and disclosure of personal information.

Privacy assessments and compliance reviews

In accordance with the TBS Directive on PIAs, ESDC must conduct a PIA before establishing any new or substantially modified program or activity involving the administrative use of personal information. PIAs are used to identify and assess privacy risks, as well as to develop plans to reduce or eliminate those risks. Among federal institutions, ESDC is an innovator in the methods used to conduct privacy assessments. For example, to support its privacy by design approach, ESDC employs a suite of tools, which includes full PIAs, Privacy Analyses for Information Technology Solutions (PAITS), and privacy protocols when personal information is not used for an administrative purpose. PAITS is an assessment methodology that is focused on an IT solution or system and is used to identify privacy risks and assess impacts on privacy in the solution's design, procurement, or acquisition stages.

In 2024-2025, ESDC completed 12 PIAs and prepared significant updates for 2 others. Of particular note, this included a PIA of Old Age Security (OAS) on BDM. BDM aims to replace aging legacy systems with a single modern and secure platform for OAS, Employment Insurance (EI) and Canada Pension Plan (CPP). The OAS program was the first to be onboarded to the new BDM platform. Copies of the PIA reports were provided to TBS and the Office of the Privacy Commissioner (OPC). Information on these assessments is found in Annex B of this report and on ESDC's website at Privacy impact assessments.

Several privacy protocol reviews for the Department's policy analysis, research, and evaluation activities were also conducted. This past fiscal year, seven such reviews were completed for these initiatives involving non-administrative uses of personal information, compared to 10 during 2023-2024.

DESDA and its related regulations set out strict parameters for making personal information that is under the control of the Department availableFootnote 1. ESDC's privacy policy requires that all such information sharing agreements or arrangements with federal institutions, other orders of government, and service delivery providers are verified. Information Sharing Agreements are an essential tool for effective privacy management at ESDC.

These instruments are assessed to ensure they have the necessary terms and conditions for the use, disclosure, protection, and disposal of personal information. Moreover, the implementation of information-sharing agreements requires the endorsement of the appropriate privacy authority designated in the DESDA Delegation Order, which is normally the CPO or the Executive Director of PMD. Similarly, all procurement documents are required by policy to be examined by PMD to verify compliance with statutory and privacy policy requirements. This past fiscal year, 48 information-sharing agreements and 157 procurement instruments were reviewed in detail.

The Internal departmental demand for other types of privacy services remains high. For example, initial reviews of programs and projects, along with the privacy analysis of software applications generated large volumes of service requests. ESDC completed 95 such reviews in 2024-2025. The number of general privacy inquiries and requests for service from internal clients totalled 263 during the reporting period. ESDC also prepared 84 privacy notices and consent forms.

Notable examples of some of the PIAs conducted during the fiscal year are provided below:

Benefits Delivery Modernization Program

In the last two fiscal years, the Department completed three privacy assessments related to OAS on BDM, as follows: Release 1 focused on migration of the International Operations Foreign Benefits and Liaison work to the new Cúram platform, Release 2 focused on supporting OAS applications requiring the assistance of a Social Security Agreement, and Release 3 for the implementation to support all OAS clients (Domestic Eligibility and Entitlement Rules) and the full implementation of the End-to-End OAS Solution. Releases 2 and 3 took place simultaneously and were deployed in March 2025, building on Release 1 as the foundation.

To ensure that privacy by design principles are maintained in BDM's architecture and implementation, ESDC has dedicated significant privacy resources to work closely with the program team. Privacy advice is being integrated into the BDM design, while detailed privacy analyses and risk assessments are conducted for individual program components.

The canadian Dental Care Plan

ESDC completed three PIAs for the Canadian Dental Care Plan (CDCP). A privacy notice statement explaining the program's handling of personal information and privacy rights was also prepared for clients.

The CDCP is administered by Health Canada in collaboration with ESDC through Service Canada, the Canada Revenue Agency (CRA), and a third-party contractor. The CDCP helps ease financial barriers to accessing oral health care for up to nine million uninsured Canadian residents with an annual family income of less than $90,000. ESDC's primary roles are to administer member applications and renewals, provide information on eligibility, and deliver client support for applicants via various communication channels.

Canadian Digital Service

In 2023, the Canadian Digital Service (CDS) joined ESDC as an initiative. CDS aims to enhance whole-of-government service delivery by building digital products for use across government that address common needs for delivering services to the public, offering digital expertise, and improving the public's experience on Canada.ca. From a privacy perspective, the strategic vision for this initiative is to ensure that services are protected, secure and reduce the risk of fraud, while remaining a digital service enabler for the Government of Canada.

In addition to its core digital products, such as GC Notify, GC Forms, and GC Design System, CDS is also building an enterprise digital credential program that is focussed on modernizing the Government of Canada's authentication and credential management infrastructure through two new enterprise software products: GC Sign in and GC Issue and Verify. GC Sign in will provide a single, secure user-friendly way to sign in to federal services. GC Issue and Verify will allow government departments to issue and verify digital versions of physical credentials they already provide today, like work permits and boating licenses. These products will be optional, privacy-focussed and designed for accessibility.

New Treasury Board Secretariate Policy and Directives

In October 2024, TBS issued its revised Policy on Privacy Protection and Directive on Privacy Practices, which introduced significant changes to the requirements around PIAs, privacy protocols, risk mitigations, personal information banks, privacy definitions and privacy considerations for programs among others. These included new mandatory templates for PIAs, new guidelines for privacy protocols making them mandatory, ensuring institutions utilizing personal information for an administrative purpose have a personal information bank in place, mandatory annual review of risks identified in previously completed PIAs to ensure mitigation measures are implemented, new definitions for a substantial modification, as well as a program or activity and the mandatory requirement that institutions demonstrate that privacy considerations are incorporated at the design stage of programs and activities.

ESDC launched a review of its own templates and procedures to ensure that they were aligned to the new policy requirements. New ESDC templates were established to meet policy requirements and bi-annual risk follow-up exercises for the Department are conducted on an ongoing basis.

The updates to the Directive on Privacy Practices also included new and more precise mandatory direction related to contacts, agreements and arrangements. This direction is supported by the Guidance on Preparing Information Sharing Agreements Involving Personal Information - Canada.ca. ESDC manages and extensive number of programs and engages in extensive information sharing. To provide assurances that Information Sharing Agreements (ISA) are effectively managed and compliant with TBS policy, ESDC's Internal Audit and Enterprise Risk Management Branch conducted an audit in 2024 on ESDC's ISAs.

The audit aimed to enhance the management of ISAs and Information Sharing Agreements by focusing on four key criteria: Roles and Responsibilities, Guidance and Support, Agreements and Expertise, and Management Oversight. The goal was to provide assurance to senior management regarding the effectiveness of ISA management and compliance with TBS policy.

Following the audit, the Internal Audit and Enterprise Risk Management Branch made five key recommendations related to updating departmental policies, guidance and templates, updating existing ISAs to align to TBS requirements, enhance methods for assessing risk and improve the ISA repository. These recommendations aim to bolster ISA management and ensure adherence to relevant policies, ultimately enhancing information-sharing practices within the Department.

ESDC has developed an ISA Management Action Plan (to address and implement the above recommendations. An overarching departmental policy is in development that will clarify responsibilities for all stakeholders involved in the ISA process. New tools are also in development which will improve ESDC's risk-based approach when assessing future ISAs with plans to apply these tools retroactively to previously completed ISAs. This project will be ongoing until 2028 with plans of implementing key deliverables by the end of 2025.

ATIP Modernization

ESDC continues to modernize its ATIP infrastructure and processes to create a modern regime to meet the needs of the evolving ATIP landscape and increasing volume of requests. The modernization program consists of three key areas that gained momentum in 2024-2025:

It is anticipated that these modernization efforts will be completed by 2026, and benefits will be realized over the course of the next three fiscal years. While use of new tools, such as Artificial Intelligence (AI), will support efficiency gains moving forward, potential use of AI to support processing ATIP request will however not lead to the replacement of specialized trained ATIP officers.

ESDC's Privacy and Artificial Intelligence Initiatives

ESDC continues to explore opportunities to leverage AI as a tool in the effective and efficient achievement of its mandate, and privacy considerations are taken seriously in this endeavor. Departmental governance is in place to ensure compliance with TBS's recent Directive on Automated Decision Making. During the fiscal year, ESDC update its Privacy Checklist and PIA templates to include AI considerations for the projects that use this technology. PIAs have been conducted to assess and advise on privacy considerations.

Timeframe monitoring

Given the Department's decentralized approach to processing privacy requests, it currently does not employ centrally directed monitoring of the time taken to process personal information requests, limits to inter-institutional consultations, or reviews of frequently requested types of information. ESDC's regional offices manage most of the privacy requests (personal information requests and requests for the correction of personal information) for the Department and prepare periodic reports concerning new requests, workload, and status updates regarding on-time performance for privacy requests. Performance reports are generated by the regional offices on a monthly, quarterly, and yearly basis.

As the Department continues to modernize the privacy request function, standardization and compliance monitoring will be a major focus so that Canadians receive consistent, reliable access to information and privacy responses.

6. Performance overview

This section provides key statistics and analysis on ESDC's request processing performance during the 2024-2025 fiscal year. Most of the charts and tables below provide four-year comparisons that show the Department's trends for that metric in administering requests under the Privacy Act. The Department's detailed statistical report on its administration of the Privacy Act is found in Annex C. Please note that some totals may exceed 100% due to rounding.

Requests by calendar days taken to complete

The on-time compliance rate is the percentage of requests responded to within their legislative timelines, including requests for which the Department invoked legislative extensions. Last fiscal year, ESDC's compliance rate for closing requests within 30 days (or 60 days after an extension) continued to improve, increasing from 74% in 2023-2024 to 83% in 2024-2025.

Figure 2: Number of Privacy Act requests processed within and beyond legislated timeframes
Chart showing Figure 2 Number of Privacy Act requests processed within and beyond legislated timelines
Text description of Figure 2

The image represents a graphical representation of the number Privacy Act requests processed within and beyond legislative timeframes for the past 4 years.

For 2021 to 2022

  • 58% of requests were processed within legislative timeframes, 42% were processed beyond

For 2022 to 2023

  • 70.8% of requests were processed within legislative timeframes, 29.2% were processed beyond.

For 2023 to 2024

  • 73.5% of requests were processed within legislative timeframes, 26.5% were processed beyond

For 2024 to 2025

  • 82.8% of requests were processed within legislative timeframes, 17.2% were processed beyond

Completion times

The majority of completion times are within 30 days, as noted in Figure 4. The large volume of requests received by ESDC continues to be the primary reason for extensions.

Figure 3: Privacy Act access requests by calendar days taken to complete
Chart showing Figure 3 Privacy Act access requests by calendar days taken to complete
Text description of Figure 3

The image represents a graphical representation of the number of calendar days taken to complete requests received under the Privacy Act for the past 4 years.

For 2021 to 2022

  • 8,130 (46%) were completed in 30 calendar days
  • 5,009 (29%) were completed in 31 to 60 calendar days
  • 4,438 (25%) were completed in 61 or more calendar days

For 2022 to 2023

  • 12,257 (56%) were completed in 30 calendar days
  • 5,694 (28%) were completed in 31 to 60 calendar days
  • 3,370 (16%) were completed in 61 or more calendar days

For 2023 to 2024

  • 12,410 (60%) were completed in 30 calendar days
  • 4,421 (21%) were completed in 31 to 60 calendar days
  • 3,942 (19%) were completed in 61 or more calendar days

For 2024 to 2025

  • 14,105 (60%) were completed in 30 calendar days
  • 5,811 (25%) were completed in 31 to 60 calendar days
  • 3,472 (15%) were completed in 61 or more calendar days

Active requests

As of April 1, 2025, there were 1,706 active requests carried over from the previous reporting periods, of which 1,636, or 96%, were on track to be processed within the legislated deadlines.

Table 1: Number of active requests that are outstanding from previous fiscal years
Fiscal year during which the open request was received Open requests that are Within Legislated Timelines as of March 31, 2025 Open requests that are Beyond Legislated Timelines as of March 31, 2025 Total
2024 to 2025 1,634 29 1,663
2023 to 2024 0 10 10
2022 to 2023 0 11 11
2021 to 2022 2 12 14
2020 to 2021 0 7 7
2019 to 2020 0 1 1
Totals 1,636 70 1,706

Reasons for extensions

Institutions may apply for an extension beyond the original 30-day statutory time limit in cases where meeting the statutory date is not feasible. The Privacy Act sets timelines for responding to privacy requests and allows for extensions, up to a maximum of 30 days, in any of the following cases:

In 2024-2025, there were 3,890 large-volume requests and two requests requiring internal consultations among others detailed below, which could not reasonably be conducted within the initial 30 days. These requests resulted in ESDC invoking 3,947 extensions. This total is significantly higher compared to the previous fiscal year when the Department invoked 1,323 extensions.

Table 2: Number of Privacy Act requests where an extension was invoked
Privacy ActSection Reason for extension Number of requests for extension
15(a)(i) Interference with operations Further review required to determine exemptions 4
Large volume of pages 30
Large volume of requests 3,890
Documents are too difficult to obtain 9
15(a)(ii) Consultation Cabinet Confidence (section 70) 0
External 7
Internal 2
15(b) Translation purposes or conversion Translation or conversion 5
Total 3,947

Consultations received from other Government of Canada institutions and organizations

ESDC received seven external consultation requests during the 2024-2025 fiscal year, which required the review of 82 pages. These requests originated from Government of Canada institutions and other organizations. The Department closed eight requests for consultations, five of which were completed within 30 days. Four requests resulted in the recommendation to disclose the records in their entirety. The other three were recommended to disclose in part. One request carried over from the previous reporting period was also completed.

Table 3: Consultation requests received from other Government of Canada institutions and other organizations
Types of consultation 2021 to 2022 2022 to 2023 2023 to 2024 2024 to 2025
Consultation requests received under the Privacy Act 3 11 3 7
Additional pages reviewed under the Privacy Act 127 215 25 82
Privacy Act requests for consultations closed 5 12 2 8
Privacy Act requests for consultations closed within 30 days 1 8 0 5

Disposition of completed requests

During 2024-2025, the number of requests that were "all disclosed" was 4,753, representing 20.3% of completed requests, compared with 4,035 and 19.4% in the previous fiscal year. Out of the 23,388 completed requests last fiscal year, only seven files were exempted in their entirety, and none were excluded.

Table 4: Percentage of completed requests for which records were "all disclosed", and percentage for which records were "disclosed in part"
Disposition 2021 to 2022 Number of Requests 2021 to 2022 Percent Age of Total 2022 to 2023 Number of Requests 2022 to 2023 Percent Age of Total 2023 to 2024 Number of Requests 2023 to 2024 Percent Age of Total 2024 to 2025 Number of Requests 2024 to 2025 Percent Age of Total
All disclosed 1,880 10.7% 2,969 13.9% 4,035 19.4% 4,753 20.3%
Disclosed in part 12,058 68.6% 13,633 63.9% 11,157 53.7% 12,793 54.7%
All exempted 4 0.0% 2 0.0% 5 0.0% 7 0.0%
All excluded 0 0.0% 0 0.0% 0 0.0% 0 0.0%
No records exist 3,235 18.4% 3,539 16.6% 4,313 20.8% 4,395 18.8%
Request abandoned 400 2.3% 1,178 5.5% 1,262 6.1% 1,440 6.2%
Neither confirmed nor denied 0 0.0% 0 0.0% 1 0.0% 0 0.0%
Totals 17,577 100.0% 21,321 100.0% 20,773 100.0% 23,388 100.0%

Active complaints

As of April 1, 2025, there were 71 active complaints that still need to be processed, 43 of which were submitted to the Information Commissioner of Canada and 28 to the Privacy Commissioner of Canada.

Table 5: Number of active complaints that are outstanding from previous fiscal years
Fiscal year during which the complaint was received Active complaints with the Information Commissioner of Canada as of March 31, 2025 Active complaints with the Privacy Commissioner of Canada as of March 31, 2025 Total
2024 to 2025 20 4 24
2023 to 2024 16 4 20
2022 to 2023 6 9 15
2021 to 2022 1 10 11
2020 to 2021 0 1 1
Totals 43 28 71

7. Complaints, investigations, and court actions

Under the Privacy Act, individuals may lodge complaints to the OPC about the processing of their requests if they were refused access to their personal information or if they feel there was an undue delay. They can also lodge complaints about personal information handling practices, including the collection, use, or disclosure of their personal information.

Complaints

During the 2024-2025 fiscal year, the OPC accepted 29 complaints about the Department. These included six complaints related to the denial of access to personal information, one complaint concerning the improper collection of personal information, and nine complaints about the Department's handling of time extensions for processing requests. Additionally, there was one complaint alleging contraventions of section 4 to 8 of the Privacy Act, and 12 complaints related to the improper use and disclosure of personal information. Of the complaints received during the reporting period, 17 were resolved through the early resolution process, while five were found to be well-founded. By the end of the reporting period, a total of 28 remained open: four from 2024-2025, four from 2023-2024, and 20 carried over from 2020-2023.

Of complaints deemed to be well founded, two were conditionally resolved, and three were well-founded and resolved.

No privacy complaints were deliberated in the courts during the reporting period.

GCKey Investigations

In August 2020 the federal government publicly announced that fraudulent actors using stolen usernames and passwords had gained access to certain CRA online accounts and other departments' online accounts accessible via the Government of Canada's centralized "GCKey" authentication service and CRA's own login portal. The cyber-attacks focused on accessing and modifying personal information held by CRA and ESDC for financial gain. The attacks successfully compromised the sensitive personal information of tens of thousands of Canadians.

In February 2024, the OPC tabled a special report that outlined recommendations A through F to rectify and prevent a breach of this magnitude from occurring in the future. ESDC accepted all of the recommendations and has since implemented most recommendations and with full implementation expected by fall 2025. ESDC remains committed to safeguarding and protecting the personal information of Canadians through improved authentication measures going forward.

8. Public interest disclosures

Disclosures in the public interest are made by ESDC under subsection 37(1) of DESDA instead of under paragraph 8(2)(m) of the Privacy Act. All such disclosures are reported to the OPC.

During the 2024-2025 fiscal year, the Department made 427 public interest disclosures. ESDC carried out 355 disclosures in its regional branches, most of which resulted from incidents involving individuals who threatened to harm themselves or others. In situations where there is an immediate threat to the safety and security of individuals, Service Canada employees have the delegated authority to make the disclosure. Given the urgency of these incidents, the OPC was notified after the disclosure was made.

The disclosure of personal Information was approved in an additional 72 cases (PMD disclosures). In most of these instances, personal information was made available to locate an individual, such as a missing person, or for a police investigation. The OPC was notified regarding the PMD disclosures before the disclosures were made.

The reasons for these disclosures and the totals for each are described in the following table.

Table 6: Number of disclosures by reason
Reason for disclosures Number of disclosures
Regional disclosures (imminent threats) 355
PMD disclosures (72)
Locate an individual (next of kin, estate related, locate an heir, missing person) 63
Police/Criminal investigation/Wanted individual 4
Other 5
Total 427

9. Material privacy breaches

A privacy breach is defined by TBS policy as "the improper or unauthorized access to, creation, collection, use, disclosure, retention or disposal of personal information." A privacy breach is "material" when it "could reasonably be expected to create a real risk of significant harm to an individual." Significant harm includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record, and damage to or loss of property.

During the 2024-2025 fiscal year, the Department reported 402 material breaches to the OPC and TBS, a 10% increase from the number of incidents in the previous fiscal year (364). In 382 cases, the breach consisted of lost, misdirected, or stolen passports and passport application documents, of which the Canada Post Corporation took responsibility for 329 incidents. ESDC was responsible for the other 53 incidents.

The Department continuously applies administrative, technical, and physical measures to reduce privacy breaches. Importantly, through ESDC's privacy training and awareness activities, employees are informed and trained in the handling of personal information, including appropriate use and safeguarding protocols.

Table 7 provides a breakdown of the material breaches by cause and a brief description of follow-up measures.

Table 7: Description of material breaches and action plans
Number of material breaches Nature of information breached Communication and notification Actions undertaken in response
18 Personal information incorrectly shared with third-party individuals via telephone, email, or mail; and/or Documents containing personal information of clients were lost or stolen. When possible, personal letters were sent to affected individuals informing them of the breach.
  • Provided training to employees on proper procedures and best practices for handling personal information, specifically focused on:
    • mailing procedures;
    • indexing procedures; and
    • authentication process when on a call with a client.
  • Reminded employees of the importance and sensitivity of dealing with personal information.
  • Reminded employees of the security requirements when sending or carrying personal information.
  • Modified procedures as needed.
  • Offered credit monitoring to certain affected individuals who were deemed to be at a higher risk of fraud.
2 Employees who made unauthorized access into departmental systems of client information (mostly discovered as part of internal audits conducted on the departmental systems). When possible, personal letters were sent to affected individuals informing them of the breach.
  • Revoked reliability status in both instances, which resulted in the dismissal of the employees as maintaining reliability status is a condition of employment.
  • Reminded employees they should not access information they are not authorized to access.
  • Reminded employees to review the ESDC Code of Conduct.
  • Instructed employees to retake training courses.
329 Passports, passport applications, and documents included with passport applications, lost, stolen, or misdirected, where Canada Post Corporation was responsible for the breach. When possible, personal letters were sent to affected individuals informing them of the breach.
  • Asked individuals to resubmit their applications and reimbursed the cost of new documents, pictures, and postage in some cases.
  • In accordance with standard procedures, passports were cancelled, and new passports were issued at no charge.
  • Searches were conducted by Canada Post Corporation to locate the documents.
  • Offered credit monitoring to certain affected individuals who were deemed to be at a higher risk of fraud.
53 Passports, passport applications, and documents included with passport applications, lost, stolen, or misdirected because of an internal ESDC error. When possible, personal letters were sent to affected individuals informing them of the breach.
  • Asked individuals to resubmit their applications and reimbursed the cost of new documents, pictures, and postage in some cases.
  • Cancelled passports and issued new passports at no charge in accordance with standard procedures.
  • Took internal corrective measures, including reminding employees of the importance of protecting personal information and the procedures for mailing.
  • Conducted thorough searches of the office and mailroom to locate the documents.
  • Offered credit monitoring to certain affected individuals who were deemed to be at a higher risk of fraud.
Total Number of Material Breaches: 402

10. Training and awareness activities

Online privacy training

ESDC has a comprehensive training program to increase knowledge and awareness of appropriate personal information management practices throughout the Department. All employees must maintain a valid two-year certification in Stewardship of Information and Workplace Behaviours (SIWB), which addresses privacy, the handling of personal information, security, access to information, information management, and values and ethics. It is a component of the Department's Essential Training Curriculum and is delivered online. At the end of the reporting period, 6,176 employees had attained SIWB certification during the fiscal year.

To complement SIWB certification, ESDC has additional privacy-relevant online courses in its training catalogue. The "Access to Information and Privacy (ATIP): It's Everybody's Business" course gives employees the knowledge required to protect, use, and disclose personal information daily and teaches them to prevent breaches by seeking guidance or by using good judgment in a timely manner. In the last fiscal year, 4,672 employees completed the course.

New employees take the "Doing Things Right and Doing the Right Thing: Putting the Departmental Code of Conduct into Action" course, which has a significant privacy component. The course helps participants understand the application of ethical behaviour in the workplace and how to use that knowledge to guide them in their day-to-day work and decision-making. The course was taken by 4,683 employees during the 2024-2025 fiscal year.

In-person and virtual training and awareness

Throughout the reporting period, the Department continued to deliver practical, easy-to-understand, and readily available privacy information and guidance to employees to reinforce the application of appropriate personal information handling and safeguarding practices, as well as to provide general knowledge on the philosophical and legislative underpinnings of privacy. The highlight of these activities were privacy-themed information events, and a series of specialized knowledge talks delivered during Privacy Awareness Week in January 2024. In support of Privacy Act request processing, specialized training was provided to key departmental stakeholders and ATIP Operations staff. Overall, 2,823 ESDC employees attended, either in-person or by video, 31 privacy training and awareness sessions offered during 2024-2025. Additionally, a new training module was developed called "Privacy Notice Statements and Consent." This training helps participants understand when to use privacy notices and consent statements. The Department will continue to leverage opportunities for learning going forward in coordination with the Innovation Information and Technology Branch, the Integrity Service Branch and the Chief Data Officer Branch.

Annex A - Privacy Act Delegation Order

The Minister of Employment and Social Development, pursuant to section 73 of the Privacy Act and section 11 of the Department of Employment and Social Development Act, hereby designates the persons holding the positions set out in the schedule hereto, or the persons occupying on an acting basis those positions, to exercise the powers, duties and functions of the Minister as the head of the Department of Employment and Social Development, under the provisions of the aforementioned Acts and related regulations set out in the schedule opposite each position.

This designation replaces all previous designation orders.

Dated, at the City of Gatineau, this 6th day of March 2024.

Original signed by the Honourable Randy Boissonnault, Minister of Employment and Social Development

Department of Employment and Social Development

Department of Employment and Social Development

Privacy Act - Delegated Authorities

Description Section Delegated Authority
Retention of a record of requests and disclosed records to investigative bodies under section 8(2)(e) of the Privacy Act. 8(4)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
Retention of records of uses of personal information 9(1)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Executive Director, Privacy Management Division, NHQ
Notification of the Privacy Commissioner of any new consistent uses of personal information and ensure use is included in the next statement of consistent uses set forth in the Index 9(4)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Executive Director, Privacy Management Division, NHQ
Include personal information in personal information banks 10
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Executive Director, PMD, NHQ
Respond to request for access within 30 days and give written notice and, if access to be given, give access. 14
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Extension of the 30-day time limit to respond to a privacy request. 15
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Decision on whether to translate a response to a privacy request in one of the two official languages. 17(2)(b)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Decision on whether to convert personal information to an alternate format 17(3)(b)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Decision to refuse to disclose personal information contained in an exempt bank. 18(2)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
Decision to refuse access to personal information that was obtained in confidence from the government of a foreign state or institution, an international organization of states or an institution thereof, the government of a province or institution thereof, a municipal or regional government established by or pursuant to an act of the legislature of a province or an institution of such a government, or the council, as defined in the Westbank First Nation Self-Government Agreement given effect by the Westbank First Nation Self-Government Act or the council of a participating in First Nation as defined in the First Nations Jurisdiction over Education in British Columbia Act 19(1)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Authority to disclose personal information referred to in section 19(1) if the government, organization or institution described in section 19(1) consents to the disclosure or makes the information public. 19(2)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager ATIP Operations, NHQ Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Refuse to disclose personal information that may be injurious to the conduct of federal-provincial affairs 20
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Business Expertise Senior Advisor (Regional ATIP)
Refuse to disclose personal information that may be injurious to international affairs or the defence of Canada or one of its allies. 21
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Business Expertise Senior Advisor (Regional ATIP)
Refuse to disclose personal information prepared by an investigative body, information injurious to the enforcement of a law, or information injurious to the security of penal institutions 22
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Refuse to disclose personal information created for the Public Servants Disclosure Protection Act. 22.3
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
Refuse to disclose personal information prepared by an investigative body for security clearance. 23
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Refuse to disclose personal information that was collected by the Canadian Penitentiary Service, the National Parole Service or the National Parole Board while the individual was under sentence if the conditions in the section are met 24
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Refuse to disclose personal information that could threaten the safety of individuals 25
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Business Expertise Senior Advisor (Regional ATIP)
Refuse to disclose personal information about another individual and shall refuse to disclose such information where disclosure is prohibited under section 8 26
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Refuse to disclose personal information that is subject to solicitor-client privilege. 27
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Refuse to disclose personal information relating to the individual's physical or mental health where the disclosure is contrary to the best interests of the individual 28
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Receive notice of investigation by the Privacy Commissioner 31
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
Right to make representations to the Privacy Commissioner during an investigation 33(2)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Executive Director, PMD
  • Manager ATIP Operations, NHQ Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Receive Privacy Commissioner's report of findings of an investigation and give notice of action taken 35(1)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Provision of addition personal information to a complainant after receiving a 35(1)(b) notice. 35(4)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations NHQ
  • Manager, ATIP Operations, NHQ Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • ATIP Officers (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Receive Privacy Commissioner's report of findings of investigation of exempt bank 36(3)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Executive Director, PMD, NHQ
Receive report of Privacy Commissioner's findings after compliance investigation 37(3)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Executive Director, PMD, NHQ
Request that a court hearing, undertaken with respect to certain sections of the Act, be held in the National Capital Region. 51(2)(b)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
Request and be given right to make representations in section 51 hearings 51(3)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
Prepare annual report to Parliament 72(1)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Executive Director, PMD, NHQ

Privacy Regulations - Delegated Authorities

Description Section Delegated Authority
Allow examination of the documents (Reading Room) 9
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Notification of Correction 11(2)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • Team Leader, ATIP Operations, NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Correction refused; notation placed on file 11(4)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ Team Leader, ATIP Operations. NHQ
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • ATIP Advisors (Regional ATIP)
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Disclosure to a medical practitioner or psychologist 13(1)
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ Manager, ATIP Operations, NHQ
  • ATIP Advisors (Regional ATIP)
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • Regional ATIP Advisor
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)
Disclosure in the presence of a medical practitioner or psychologist 14
  • Deputy Minister of Employment and Social Development
  • Deputy Minister of Labour and Associate Deputy Minister of Employment and Social Development
  • Senior Associate Deputy Minister of Employment and Social Development
  • Associate Deputy Minister of Employment and Social Development and Chief Operating Officer for Service Canada
  • Associate Deputy Minister of Employment and Social Development
  • Corporate Secretary and CPO
  • Director, ATIP Operations, NHQ
  • Manager, ATIP Operations, NHQ
  • ATIP Advisors (Regional ATIP)
  • Senior Advisor, ATIP Policy and Programs, NHQ
  • Service Manager (Regional ATIP)
  • Team Leader (Regional ATIP)
  • Regional ATIP Advisor
  • Business Expertise Regional Consultant (Regional ATIP)
  • Senior Consultant (Regional ATIP)
  • Senior Business Expertise Consultant (Regional ATIP)

Annex B - Summaries of completed privacy impact assessments

ESDC completed PIAs over the course of the 2024-2025 fiscal year and significantly updated two previously completed assessments. In addition to standard PIAs, ESDC uses (PAITS, which is a customized PIA focused on an IT solution or system. The purpose of a PAITS is to identify privacy risks and assess impacts on privacy in the solution's design, procurement, or acquisition stages. Its conclusions give assurances to senior management that the protection of personal information has been considered prior to implementation and outlines a mitigation action plan to resolve identified risks. PAITS satisfy departmental and TBS requirements for the fulfillment of PIAs. Of the completed PIAs, five were PAITS. ESDC conducts bi-annual privacy risk follow-up exercises to ensure risks and compliance issues are fully addressed and in a timely manner.

Information on ESDC's PIAs is found on the Department's PIA website.

Canadian Dental Care Plan - Phase 2

The 2023 federal budget proposes providing $13 billion over five years, starting in 2023-2024, and $4.4 billion ongoing, to Health Canada to implement the new CDCP. The CDCP will provide dental coverage for uninsured Canadians with an annual family income of less than $90,000. ESDC is a service delivery partner with one of its roles being an assessor of eligibility. The assessment examines the privacy risks and strategies related to the management and protection of personal information collected in the form of online CDCP applications. The PIA identified two medium risks and no compliance issues.

Integrated Labour System: Federal Mediation and Conciliation Service

The Integrated Labour System was a modernization initiative within the Labour Program to consolidate existing electronic systems, tools and data of various business lines into one central system. This PIA was completed to identify the privacy risks related to Federal Mediation Conciliation Service's collection, use, disclosure, and safeguarding of personal information. The PIA identified five medium risks, two low risks, and three compliance issues.

Canada-Ukraine Transitional Assistance Initiative

The Canada-Ukraine Transitional Assistance Initiative (CUTAI) is a service delivery managed by Service Canada on behalf of Immigration, Refugees and Citizenship Canada. The CUTAI provides Ukrainian nationals fleeing the war in Ukraine with a one-time payment ($3,000 CAD for adults or $1,500 CAD for minors) to assist them during their stay in Canada. The CUTAI expired on June 30, 2024. This initiative involves collecting information from Immigration, Refugees and Citizenship Canada on potential applicants and managing payments. The assessment examines the privacy risks and strategies related to the management and protection of personal information handled by the CUTAI. The PIA identified one medium risk, one insignificant risk as well as one compliance issue.

Canada Pension Plan Program Return to Work Pilot

Canada Pension Plan's Disability Benefits (CPPD) program's suite of return-to-work (RTW) supports are intended to facilitate the transition for beneficiaries who wish to attempt to return to work. The Pilot will run until March 2026 and is expected to engage approximately 750 CPPD RTW clients. The personal information collected will also be used for non-administrative purposes to evaluate outcomes and to inform policy. The assessment identifies privacy risks associated with the collection and use of personal information in the CPPD RTW Pilot which involves a decision-making process that affects certain individuals. There were no privacy risks or privacy-related compliance issues uncovered by this PIA.

Secure Portal for Verified Partners in Children Services Annex to the Electronic Social Insurance Number (PAITS)

The Secure Portal for Verified Partners in Children Services under ESDC will allow authorized and verified Children and Family Services delegated staff across Canada to apply or request confirmation of a Social Insurance Number (SIN), on behalf of children in their care. This PAITS ensures privacy protection measures were considered in the collection of personal information. The analysis focused on the enhancement of the web-based portal for Children and Family Services delegated staff. The PAITS identified one medium risk and one compliance issue.

Cúram (PAITS)

The BDM program was created by ESDC to transform and modernize the service delivery of benefits and services to Canadians. The OAS Release 1 Foreign Benefits and Liaisons is the first to onboard on the BDM Cúram platform. Foreign Benefits and Liaisons form will transfer client information between Canada and foreign country. This privacy analysis for IT solutions identifies the privacy risks associated with the implementation of the core benefit platform, Cúram, to support the onboarding of OAS Release 1 Foreign Benefits and Liaisons. The PAITS identified a total of four medium risks and one compliance issue.

Assault-Style Firearms Compensation Program Phase 1 - Business

The "Assault-Style Firearms Compensation Program Phase 1 - Business" is a multi-institutional PIA led by Public Safety Canada and supported by its partners, the Royal Canadian Mounted Police and ESDC/Service Canada. This PIA aims to facilitate the self-declaration of assuault-style firearm owners; the collection, validation, and destruction of assault-style firearms; and issuing compensation.

Emergency Management Application System (PAITS)

The Emergency Management Application System (EMAS) serves to support ESDC's emergency management and business continuity activities. The EMAS solution will operate as a cloud-based Software as a Service that is accessible across ESDC. A copy of employee personal contact information will be transmitted from ESDC's primary system for digital Human Resources services (PeopleSoft) to EMAS. The assessment examines the privacy risks related to the management and protection of personal information that will be transmitted to and stored in the cloud-based EMAS solution hosted by a third party. The PAITS identified one compliance issue, which has since been resolved.

Integrated Service Strategy and Operations' Pensions Trusted Digital Repository (PAITS)

The Integrated Service Strategy and Operations' Pensions Trusted Digital Repository (PTDR) project will replace the current digital pensions file storage solution-shared drives-with Microsoft 365 SharePoint Online. The PAITS has been completed to identify the privacy risks related to the PTDR, which will involve the configuration of a third-party cloud-based solution to collect and store pensions application information. This PAITS focused on the PTDR that will provide secure storage for the digitized applications and support documents. The PAITS identified two medium privacy risks and one low privacy risk.

Prescribed Presence in the Workplace - Low Onsite Connectivity Monitoring

ESDC will be implementing individual-level, low onsite connectivity monitoring of employees. Using existing ESDC systems, this activity is designed to support managers in verifying employee compliance with the TBS Direction on Prescribed Presence in the Workplace. The assessment examines the privacy risks and strategies related to the management and protection of personal information. The PIA identified two medium risks and one low risk. In addition, there was one compliance issue.

Enhancement to the fraud monitoring capacity as part of the modernization of the Enterprise Cyber Authentication Solution

The Innovation Information and Technology Branch is modernizing the Enterprise Cyber Authentication Solution through the Tech Debt initiative. This initiative addresses the gap between current and required technology, mitigating service delivery risks by upgrading network capacity and updating hardware and software. It ensures ESDC's technology supports existing systems and the new BDM platform, while establishing disaster recovery solutions to minimize service disruptions for Canadians. The Integrity Services Branch seeks authorization to collect and store Internet Protocol (IP) addresses to enhance protection against fraudulent activities. This will help identify the source of online transactions and logins. The goal is to improve IP address storage for accurate data analysis, better tracking, detailed reporting, and real-time activity representation for MSCA users. The assessment examines the privacy risks and strategies related to the management and protection of personal information associated with specific activities, including authentication, account creation, mapping, remapping, etc.; the collection of the telemetry data (IP address, session ID, User Agent, time and date, and the user's windows size); and the safeguarding of the telemetry data.

Social Insurance Number on My Service Canada Account - Release 2 and 3 (PAITS)

The Social Insurance Number on My Service Canada Account (SINOM) project provides real-time SIN confirmation to clients. SINOM expanded the current SIN-based registration requirements to enable clients who do not have a SIN to register for MSCA using their Birth Registration Number or Unique Client Identifier. SINOM is using a phased implementation approach. In August 2023, it launched its first minimum viable product (MVP 1), allowing digital viewing of SINs on MSCA while still mailing SIN Confirmation Letters. Release 2, in January 2024, offered clients the option of a digital-only SIN during eSIN applications, removing the automatic mailing of confirmation letters. Release 3, planned for May 2025, will provide the SIN Confirmation Letter on MSCA, along with security enhancements and system upgrades. In line with the TBS Directive on Privacy Impact Assessment, the original PAITS for MVP 1 was completed to identify privacy risks related to SINOM's use of personal information in the MSCA registration and authentication process. An addendum was created to document activities for Releases 2 and 3 and to assess any new privacy risks or issues. The PAITS addendum identified one medium risk in relation to Release 3.

Annex C - Statistical reports

ESDC Statistical Report on the Privacy Act, 2024 to 2025

Name of institution: Employment and Social Development Canada

Reporting period: 2024-04-01 to 2025-03-31

Section 1 Requests under the Privacy Act

1.1 Number of Requests Received
Detail Number of Requests
Received during reporting period 22,451
Outstanding from previous reporting period 2,643
Outstanding from previous reporting periods 2,595
Outstanding from more than one reporting period 48
Total 25,094
Closed during reporting period 23,388
Carried over to next reporting period 1,706
Carried over within legislated timeline 1,636
Carried over beyond legislated timeline 70
1.2 Channels of Requests
Source Number of Requests
Online 7,795
Email 3,610
Mail 4,408
In person 25
Phone 20
Fax 6,593
Total 22,451

Section 2 Informal Requests

2.1 Number of Informal Requests
Detail Number of Requests
Received during reporting period 4,342
Outstanding from previous reporting period 1,073
Outstanding from previous reporting periods 1,064
Outstanding from more than one reporting period 9
Total 5,415
Closed during reporting period 3,949
Carried over to next reporting period 1,466
2.2 Channels of Informal Requests
Source Number of Requests
Online 744
Email 695
Mail 1,630
In person 3
Phone 48
Fax 1,222
Total 4,342
2.3 Completion Time of Informal Requests
1 to 15 days 16 to 30 days 31 to 60 days 61 to 120 days 121 to 180 days 181 to 365 days More than 365 days Total
1,052 482 349 337 251 1,291 187 3,949
2.4 Pages Released Informally
Less Than 100 Pages Released 100-500 Pages Released 501-1,000 Pages Released 1,001-5,000 Pages Released More Than 5,000 Pages Released
Number of Requests Pages Released Number of Requests Pages Released Number of Requests Pages Released Number of Requests Pages Released Number of Requests Pages Released
2,708 63,612 1,074 226,744 107 77,107 58 94,017 2 12,532

Section 3 Requests Closed During the Reporting Period

Disposition of Requests Completion Time
0 to 15 days 16 to 30 days 31 to 60 days 61 to 120 days 121 to 180 days 181 to 365 days More than 365 days Total
All disclosed 1,361 1,692 1,141 543 6 5 5 4,753
Disclosed in part 1,798 4,010 4,181 2,733 19 32 20 12,793
All exempted 0 4 2 0 0 1 0 7
All excluded 0 0 0 0 0 0 0 0
No records exist 1,491 2,448 380 74 0 1 1 4,395
Request abandoned 973 328 107 24 1 2 5 1,440
Neither confirmed nor denied 0 0 0 0 0 0 0 0
Total 5,623 8,482 5,811 3,374 26 41 31 23,388
3.2 Exemptions
Section Number of Requests
18(2) 0
19(1)(a) 0
19(1)(b) 0
19(1)(c) 0
19(1)(d) 0
19(1)(e) 0
19(1)(f) 0
20 0
21 0
22(1)(a)(i) 6
22(1)(a)(ii) 0
22(1)(a)(iii) 0
22(1)(b) 42
22(1)(c) 1
22(2) 0
22.1 0
22.2 0
22.3 0
22.4 0
23(a) 1
23(b) 0
24(a) 0
24(b) 2
25 1
26 12,815
27 84
27.1 0
28 1
3.3 Exclusions
Section Number of Requests
69(1)(a) 0
69(1)(b) 0
69.1 0
70(1) 0
70(1)(a) 0
70(1)(b) 0
70(1)(c) 0
70(1)(d) 0
70(1)(e) 0
70(1)(f) 0
70.1 0
3.4 Format of Information Released
Paper Electronic: E-record Electronic: Data set Electronic: Video Electronic: Audio Other
3,678 13,851 7 0 27 7
3.5 Complexity
3.5.1 Relevant Pages Processed and Disclosed for Paper and e-Record Formats
Number of Pages Processed Number of Pages Disclosed Number of Requests
2,212,302 2,078,409 18,993
3.5.2 Relevant pages processed by request disposition for paper and e-record formats by size of requests
Disposition Less than 100 Pages Processed 101 to 500 Pages Processed 501 to 1,000 Pages Processed 1,001 to 5,000 Pages Processed More than 5,000 Pages Processed
Number of Requests Pages Processed Number of Requests Pages Processed Number of Requests Pages Processed Number of Requests Pages Processed Number of Requests Pages Processed
All disclosed 4,275 89,227 469 76,737 7 5,437 2 2,288 0 0
Disclosed in part 7,046 307,930 5,160 1,046,508 409 274,236 165 292,593 13 111,623
All exempted 5 57 1 169 0 0 1 2600 0 0
All excluded 0 0 0 0 0 0 0 0 0 0
Request abandoned 1,436 273 1 236 2 1,311 1 1,077 0 0
Neither confirmed nor denied 0 0 0 0 0 0 0 0 0 0
Total 12,762 397,487 5,631 1,123,650 418 280,984 169 298,558 13 111,623
3.5.3 Relevant Minutes Processed and Disclosed for Audio Formats
Number of Minutes Processed Number of Minutes Disclosed Number of Requests
4,109 4,096 27
3.5.4 Relevant Minutes Processed per Request Disposition for Audio Formats by Size of Requests
Disposition Less than 60
Minutes Processed
60-120
Minutes Processed
More than 120
Minutes Processed
Number of Requests Minutes Processed Number of Requests Minutes Processed Number of Requests Minutes Processed
All disclosed 3 102 1 115 1 257
Disclosed in part 8 249 2 120 12 3,266
All exempted 0 0 0 0 0 0
All excluded 0 0 0 0 0 0
Request abandoned 0 0 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0 0
Total 11 351 3 235 13 3,523
3.5.5 Relevant Minutes Processed and Disclosed for Video Formats
Number of Minutes Processed Number of Minutes Disclosed Number of Requests
0 0 0
3.5.6 Relevant Minutes Processed per Request Disposition for Video Formats by Size of Requests
Disposition Less than 60
minutes processed
60-120
minutes processed
More than 120
minutes processed
Number of requests Minutes processed Number of requests Minutes processed Number of requests Minutes processed
All disclosed 0 0 0 0 0 0
Disclosed in part 0 0 0 0 0 0
All exempted 0 0 0 0 0 0
All excluded 0 0 0 0 0 0
Request abandoned 0 0 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0 0
Total 0 0 0 0 0 0
3.5.7 Other Complexities
Disposition Consultation Required Legal Advice Sought Interwoven Information Other Total
All disclosed 0 0 3 39 42
Disclosed in part 6 0 272 602 880
All exempted 1 0 0 0 1
All excluded 0 0 0 0 0
Request abandoned 1 0 0 42 43
Neither confirmed nor denied 0 0 0 0 0
Total 8 0 275 683 966
3.6 Closed Requests
3.6.1 Number of Requests Closed within Legislated Timelines
Detail Requests Closed within Legislated Timelines
Number of requests closed within legislated timelines 19,356
Percentage of requests closed within legislated timelines (%) 82.76038994
3.7 Deemed Refusals
3.7.1 Reasons for Not Meeting Legislated Timelines
Number of Requests Closed Past the Legislated Timelines Principal Reason: Interference with Operations / Workload Principal Reason: External Consultation Principal Reason: Internal Consultation Principal Reason: Other
4,032 4,027 0 0 5
3.7.2 Requests Closed Beyond Legislated Timelines (including any extension taken)
Number of Days Past Legislated Timelines Number of Requests Past Legislated Timelines Where No Extension Was Taken Number of Requests Past Legislated Timelines Where an Extension WasTaken Total
1 to 15 days 366 42 408
16 to 30 days 657 9 666
31 to 60 days 2,772 8 2,780
61 to 120 days 92 5 97
121 to 180 days 19 3 22
181 to 365 days 24 9 33
More than 365 days 13 13 26
Total 3,943 89 4,032
3.8 Requests for Translation
Translation Requests Accepted Refused Total
English to French 0 0 0
French to English 5 0 5
Total 5 0 5

Section 4 Disclosures under Subsections 8(2) and 8(5)

Paragraph 8(2)(e) Paragraph 8(2)(m) Subsection 8(5) Total
0 0 0 0

Section 5 Requests for Correction of Personal information and Notations

Disposition for Correction Requests Received Number
Notations attached 10
Requests for correction accepted 3
Total 13

Section 6 Extensions

6.1 Reasons for Extensions
Number of Requests Where an Extension Was Taken 15(a)(i) Interference with Operations 15 (a)(ii) Consultation 15(b) Translation Purposes or Conversion
Further review required to determine exemptions Large volume of pages Large volume of requests Documents are difficult to obtain Cabinet Confidence Section (Section 70) External Internal
3,947 4 30 3,890 9 0 7 2 5
6.2 Length of Extensions
Length of Extensions 15(a)(i) Interference with Operations 15 (a)(ii) Consultation 15(b) Translation Purposes or Conversion
Further review required to determine exemptions Large volume of pages Large volume of requests Documents are difficult to obtain Cabinet Confidence Section (Section 70) External Internal
1 to 15 days 0 0 0 0 0 0 0 0
16 to 30 days 4 30 3,890 9 0 7 2 5
31 days or Greater 0 0 0 0 0 0 0 0
Total 4 30 3,890 9 0 7 2 5

Section 7 Consultations Received from Other Institutions and Organizations

7.1 Consultations Received from Other Government of Canada Institutions and Other Organizations
Consultations Other Government of Canada Institutions Number of Pages to Review Other Organizations Number of Pages to Review
Received during the reporting period 7 78 0 0
Outstanding from the previous reporting period 1 4 0 0
Total 8 82 0 0
Closed during the reporting period 8 82 0 0
Carried over within negotiated timelines 0 0 0 0
Carried over beyond negotiated timelines 0 0 0 0
7.2 Recommendations and Completion Time for Consultations Received from other Government of Canada Institutions
Recommendation Number of Days Required to Complete Consultation Requests
1 to 15 days 16 to 30 days 31 to 60 days 61 to 120 days 121 to 180 days 181 to 365 days More than 365 days Total
Disclose entirely 1 2 1 0 0 0 0 4
Disclose in part 2 0 1 0 0 0 0 3
Exempt entirely 0 0 0 0 0 0 0 0
Exclude entirely 0 0 0 0 0 0 0 0
Consult other institution 0 0 0 0 0 0 0 0
Other 0 0 0 0 0 1 0 1
Total 3 2 2 0 0 1 0 8
7.3 Recommendations and Completion Time for Consultations Received from Other Organizations Outside the Government of Canada
Recommendation Number of Days Required to Complete Consultation Requests
1 to 15 days 16 to 30 days 31 to 60 days 61 to 120 days 121 to 180 days 181 to 365 days More than 365 days Total
Disclose entirely 0 0 0 0 0 0 0 0
Disclose in part 0 0 0 0 0 0 0 0
Exempt entirely 0 0 0 0 0 0 0 0
Exclude entirely 0 0 0 0 0 0 0 0
Consult other institution 0 0 0 0 0 0 0 0
Other 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0

Section 8 Completion Time of Consultations on Cabinet Confidences

8.1 Requests with Legal Services
Number of days Fewer than 100 Pages Processed 100 to 500 Pages Processed 501 to 1,000 Pages Processed 1,001 to 5,000 Pages Processed More than 5,000 Pages Processed
Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed
1 to 15 0 0 0 0 0 0 0 0 0 0
16 to 30 0 0 0 0 0 0 0 0 0 0
31 to 60 0 0 0 0 0 0 0 0 0 0
61 to 120 0 0 0 0 0 0 0 0 0 0
121 to 180 0 0 0 0 0 0 0 0 0 0
181 to 365 0 0 0 0 0 0 0 0 0 0
More than 365 0 0 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0 0 0
8.2 Requests with the Privy Council Office
Number of days Fewer than 100 Pages Processed 100 to 500 Pages Processed 501 to 1,000 Pages Processed 1,001 to 5,000 Pages Processed More than 5,000 Pages Processed
Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed
1 to 15 0 0 0 0 0 0 0 0 0 0
16 to 30 0 0 0 0 0 0 0 0 0 0
31 to 60 0 0 0 0 0 0 0 0 0 0
61 to 120 0 0 0 0 0 0 0 0 0 0
121 to 180 0 0 0 0 0 0 0 0 0 0
181 to 365 0 0 0 0 0 0 0 0 0 0
More than 365 0 0 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0 0 0

Section 9 Complaints and investigations Notices Received

Section 31 Section 33 Section 35 Court Action Total
29 3 5 0 37

Section 10 Privacy Impact Assessments and Personal Information Banks

10.1 Privacy Impact Assessments
Number of PIAs Completed 11
Number of PIAs Modified 1
10.2 Institution-Specific and Central Personal Information Banks
Personal Information Banks Active Created Terminated Modified
Institution-specific 64 2 0 8
Central 0 0 0 0
Total 64 2 0 8

Section 11 Privacy Breaches

11.1 Material Privacy breaches
Number of Material Privacy Breaches Reported to TBS 402
Number of Material Privacy Breaches Reported to OPC 402
11.2 Non-Material Privacy Breaches
Number of Non-material Privacy Breaches 1,072

Section 12 Resources Related to the Privacy Act

12.1 Allocated Costs
Expenditures Amount
Salaries $7,427,275
Overtime $344,028
Goods and services $176,849

Goods and services: Professional services contracts

$155,647

Goods and Services: Other

$21,202
Total $7,948,151
12.2 Human Resources
Resources Person years dedicated to privacy activities
Full-time employees 24.515
Part-time and casual employees 0.970
Regional staff 61.187
Consultants and agency personnel 0.020
Students 1.866
Total 88.558

Supplemental Statistical Report on the Access to Information Act and the Privacy Act

Name of Institution: Employment and Social Development Canada

Reporting Period: 2024-04-01 to 2025-03-31

Section 1 Open Requests and Complaints Under the Access to Information Act

1.1 Number of Open Requests that Are Outstanding from Previous Reporting Periods
Fiscal Year Open Requests Were Received Open Requests that are Within Legislated Timelines as of March 31, 2025 Open Requests that are Beyond Legislated Timelines as of March 31, 2025 Total
Received in 2024-2025 184 44 228
Received in 2023-2024 7 64 71
Received in 2022-2023 2 66 68
Received in 2021-2022 7 41 48
Received in 2020-2021 4 38 42
Received in 2019--2020 5 21 26
Received in 2018-2019 0 3 3
Received in 2017-2018 0 1 1
Received in 2016-2017 0 0 0
Received in 2015-2016 or earlier 0 0 0
Total 209 278 487
1.2 Number of Open Complaints with the Information Commissioner of Canada that Are Outstanding from Previous Reporting Periods
Fiscal Year Open Complaints Were Received by Institution Number of Open Complaints
Received in 2024-2025 20
Received in 2023-2024 16
Received in 2022-2023 6
Received in 2021-2022 1
Received in 2020-2021 0
Received in 2019-2020 0
Received in 2018-2019 0
Received in 2017-2018 0
Received in 2016-2017 0
Received in 2015-2016 or earlier 0
Total 43

Section 2 Open Requests and Complaints Under the Privacy Act

2.1 Number of Open Requests that Are Outstanding from Previous Reporting Periods under the Privacy Act
Fiscal Year Open Requests Were Received Open Requests that are Within Legislated Timelines as of March 31, 2025 Open Requests that are Beyond Legislated Timelines as of March 31, 2025 Total
Received in 2024-2025 1,634 29 1,663
Received in 2023-2024 0 10 10
Received in 2022-2023 0 11 11
Received in 2021-2022 2 12 14
Received in 2020-2021 0 7 7
Received in 2019-2020 0 1 1
Received in 2018-2019 0 0 0
Received in 2017-2018 0 0 0
Received in 2016-2017 0 0 0
Received in 2015-2016 or earlier 0 0 0
Total 1,636 70 1,706
2.2 Number of Open Complaintswith the Privacy Commissioner of Canada That Are Outstanding from Previous Reporting Periods
Fiscal Year Open Complaints Were Received by Institution Number of Open Complaints
Received in 2024-2025 4
Received in 2023-2024 4
Received in 2022-2023 9
Received in 2021-2022 10
Received in 2020-2021 1
Received in 2019-2020 0
Received in 2018-2019 0
Received in 2017-2018 0
Received in 2016-2017 0
Received in 2015-2016 or earlier 0
Total 28

Section 3: Social Insurance Number

Did Your Institution Receive Authority for a New Collection ora New Consistent Use of the SIN in 2024-2025? Yes

Section 4: Universal Access under the Privacy Act

How Many Requests Were Received from Confirmed Foreign Nationals Outside of Canada in 2024-2025? 126

Page details

2025-10-30