Supervised Consumption Sites Privacy Impact Assessment 2024
Description
The Controlled Drugs and Substances Act (CDSA) prohibits the possession, import, export, production and distribution of controlled substances and precursors, except where explicitly authorized by the CDSA, its regulations or a specific exemption.
To apply for an exemption, Health Canada (HC)'s Office of Controlled Substances collects personal information about specific individuals proposed to work at Supervised Consumption Sites (SCSs). This includes the name, contact information, title, resume, relevant credentials, proposed hours of work, signature as well as a criminal records check issued by a Canadian police force or a document issued by the police force of another country, if applicable.
The information is part of HC's review process for issuing a SCS exemption under the CDSA.
Why was a privacy impact assessment completed?
The SCS Program meets the following criteria established in section C.2.2.9.1 and C.2.2.9.2 of the TBS Directive on Privacy Practices, which require the completion of a PIA for: new programs or activities involving the collection, use, disclosure, retention, or disposal of personal information for an administrative purpose; and when substantial modifications are to be made to existing programs that use personal information for administrative purposes.
More information
This PIA focused on HC's collection, use, disclosure and retention and disposition of personal information involved in the SCS Program.
The PIA identified 5 areas of risk and recommends the following mitigation measures:
- An updated Personal Information Bank (PIB) is drafted and will be registered to accurately reflect current practices.
- A Threat and Risk Assessment (TRA) and a Statement of Sensitivity (SoS) should be developed to align with federal security and privacy best practices. Initial planning for the TRA and SoS is underway.
- A secure online portal or encrypted file transfer method should be adopted to protect personal information during transmission. This work is underway.
- An approved retention and disposition schedule should be developed and implemented with the support of Library and Archives Canada. This work is underway.
- The SCS Program's Privacy Notice Statement (PNS) should be updated to meet federal privacy requirements and reflect current disclosure practices. This work is underway.
Health Canada is developing a new personal information bank for this program.
For more information about this PIA please contact the SCS Program at: hc.exemption.sc@canada.ca