Privacy impact reports 2018-2019

From: Employment and Social Development Canada

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Education Savings Referral Service (June 2018)

Description of program

The Government of Canada encourages Canadians to use Registered Education Savings Plan (RESP) to save for a child’s post-secondary education. ESDC administers through the Canada Education Savings Plan (CESP), two education savings incentives linked to the RESPs; the Canada Education Savings Grant (CESG) and the Canada Learning Bond (CLB). ESDC is partnering with the Government of Ontario to integrate the Education Savings Referral Service (ESRS) which will enable parents of Ontario newborns to request to be contacted by an RESP promoter to learn about and perhaps start the process to open an RESP and request the education saving incentives.

Why was a Privacy Impact Assessment (PIA) completed?

This PIA was completed as the ESRS represents a new collection, use and disclosure of personal information. The ESRS is intended to ease access to the savings incentives and no administrative decisions will be made with the information collected.

The PIA examines the privacy risks associated with the implementation of the ESRS and proposes methods to mitigate these risks.

More information

This PIA focused on ESDC’s collection, use, and disclosure of personal information in keeping with the requirements of the Privacy Act and the Department of Employment and Social Development Act. It is not meant to analyze the administration of the existing education incentive plans.

The PIA identified three medium and no high risks. The mitigation strategies for those were scheduled for completion by March 2018.

The Exchange of Information between Employment and Social Development Canada and British Columbia’s Ministry of Social Development and Poverty Reduction (August 2018)

Description of program

ESDC and British Columbia’s Ministry of Social Development and Poverty Reduction (British Columbia) have proposed to revise the Information Sharing Agreements (ISA) that currently exist between the departments with a new ISA. The new proposed ISA will include the new use of Old Age Security (OAS) information for the administration of the Income and Disability Assistance Programs and the Bus Pass Program.

The new ISA allows the exchange of personal information between British Columbia and ESDC that will result in improving the administration of the provincial Social Assistance and Supplement Programs under the Employment and Assistance Act (EA Act) and the Employment and Assistance for Persons with Disabilities Act (EAPWD Act).

Why was a Privacy Impact Assessment (PIA) completed?

This PIA was completed as British Columbia will be using personal information from ESDC as part of the decision-making process that will directly affect individuals.

More information

This PIA focused on the exchange of CPP/OAS information to determine eligibility and entitlement to the British Columbia provincial programs and the information technology systems required for the data match and the information exchange process.

This PIA identified two medium, 2 low, and no high risks. The mitigation strategies for those are scheduled for completion in the 2018-19 fiscal year.

Death Abroad Data Exchange Initiative – Information Sharing Agreement between ESDC and the Netherlands’ Sociale Verzekeringsbank (SVB) and the Uitvoeringsinstituut Werknemersverzekeringen (August 2018)

Description of program

The Death Abroad Data Exchange (DADE) initiative facilitates the department’s timely suspension and termination of the Canada Pension Plan (CPP) and Old Age Security (OAS) benefit payments to beneficiaries who lived outside of Canada upon their death. This initiative responds to the lack of systematic and timely notifications of death abroad to address the issue of overpayments, which can be difficult to recover from the deceased beneficiaries’ estate or appointed representative.

Why was a Privacy Impact Assessment (PIA) completed?

This PIA was completed to identify the privacy risks as personal information exchanged between ESDC and the Netherland’s SVB/UWV will be used for an administrative purpose.

The assessment examines the privacy risks and associated mitigations related to the management and protection of personal information exchange between ESDC and the Netherland’s SVB and UWV under a proposed Information Sharing Agreement (ISA).

More information

This PIA focused on the legal authorities to conduct the ISA between the department and SVB/UWV, the method of exchange of personal information, data matches and the date flow and processes associated with the implementation of the DADE initiative. The assessment is intended to be used as a basis for future ISAs concluded with different partners under the DADE initiative and will be amended or updated as new ISAs are negotiated.

The PIA identified four medium level risks and no high risks. The mitigation strategies to address these risks were scheduled for completion by the end of the 2018-2019 fiscal year.

Service Canada’s Role in Temporary Foreign Worker Program (TFWP) and International Mobility Program (IMP) Investigations (October 2018)

Description of program

The Temporary Foreign Worker Program (TFWP) assists employers in filling their acute labour shortages on a temporary and limited basis when qualified Canadians and permanent residents are not available, while respecting international trade agreements and other partnerships. The TFWP is jointly managed by ESDC, Immigration, Refugees and Citizenship Canada (IRCC) and the Canada Border Services Agency (CBSA) under the authority of the Immigration and Refugee Protection Act (IRPA) and the Immigration and Refugee Protection Regulations (IRPR). The program has been going through a significant modernization over the last several years. A recent emphasis has been improving the Government of Canada's capacity to conduct integrity investigations to detect misuse and reduce the potential of abuse of foreign workers.

Why was a Privacy Impact Assessment (PIA) completed?

This PIA was completed to address the transition to MS Dynamics which represented a substantial modification to program operations and changed the way personal information was processed by the TFWP and IMP investigations.

The PIA examines TFWP and IMP cases and the stewardship of personal information that will be held by ESDC’s Integrity Service Branch in the context of TFWP and IMP investigations managed in MS Dynamics.

The PIA also focuses on any required amendments to the current information sharing agreement (ISA) between ESDC and IRCC pertaining to the exchanged of IMP investigation information and the changes to the interface of the new case management system.

More information

This PIA focused on the introduction of a new case management system which is a key component in delivering enhanced monitoring of the TFWP Investigations and IMP Investigations.

This PIA identified one medium, four low, and no high risks. The mitigation strategies for those were scheduled for completion in the 2018-19 fiscal year.

Information Sharing Agreement between ESDC and Department of Justice (March 2019)

Description of program

The Family Orders and Agreements Enforcement Assistance Act (FOAEAA), administered by the Department of Justice, is an Act that provides for the release of information that may assist in locating certain persons who are in default of family support orders or who are in violation of custody or access rights. The Department of Justice, is seeking to receive specific personal information from two additional ESDC databases, the Automated Earnings and Reporting System (AERS) and the Report on Hirings (ROH) to help administer the FOAEAA.

Why was a Privacy Impact Assessment (PIA) completed?

This PIA was completed for this information exchange given that it represents a substantial modification to an existing activity where personal information is used or intended to be used for an administrative purpose.

ESDC plans to pursue a two-phased approach for the existing and new information exchanges with Justice Canada. This PIA examines the elements of Phase I: developing an umbrella ISA with an annex that would specifically allow the transfer of AERS-ROH information between ESDC and Justice Canada. Phase II: adding to this umbrella Agreement several other data exchanges currently covered under the 1987 Memorandum of Understanding as separate annexes and developing a PIA for those annexes.

More information

This PIA focused on the privacy risks associated with the sharing of information on matches to the AERS and ROH databases with Justice Canada for the purposes of administering the FOAEAA.

The PIA identified one medium, two low and no high risks. The mitigation strategy is scheduled for completion by Winter 2019.

Additional information

If you would like more information about the above PIAs, please contact:

Employment and Social Development Canada
Corporate Secretariat / Privacy Management Division
140 Promenade du Portage
Phase IV, 12th Floor, mailstop 1203
Gatineau, Quebec K1A 0J9
Email: EDSC.SM.ViePrivee-Privacy.CS.ESDC@hrsdc-rhdcc.gc.ca
Tel.: 1-800-O-Canada
Teletypewriter: 1-800-926-9105

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