Privacy Impact Assessment Summary – Four Country Conference High Value Data Sharing Protocol

The Four Country Conference (FCC) High Value Data Sharing (HVDS) Protocol is an initiative for sharing biometric information between the FCC member countries – Canada, Australia, the United Kingdom and the United States – for immigration purposes. New Zealand, which became a new member of the FCC in June 2009, making the forum the Five Country Conference, is considering legislation to join the protocol initiative in the near future.

Citizenship and Immigration Canada (CIC), the Canada Border Services Agency (CBSA) and the Royal Canadian Mounted Police (RCMP) are covered by the privacy impact assessment (PIA), with the latter providing fingerprint services and expertise to CIC and the CBSA. The PIA for this initiative will be updated prior to implementation with New Zealand.

Under the HVDS Protocol, each country will share approximately 3,000 cases per year for fingerprint searching against the biometric information of each FCC country. In Canada, approximately 2,800 refugee claimant cases, drawn from a representative sample, will be shared, while the remaining 200 will be immigration enforcement cases.

The purpose of the data sharing is to assist the countries in managing their immigration programs more effectively. Such collaboration will deliver significant benefits to the Government of Canada and Canadians:

• greater confidence in genuine refugee claimants and improved ability to detect fraudulent claims through identity and immigration case information;
• improved ability to remove from Canada individuals whose identities or nationalities were previously either unknown or uncertain; and
• improved safety for Canadians through better detection of people with criminal histories or who pose other risks to the public that would affect their immigration case.

Safeguarding Personal Information

A detailed PIA was carried out by a third party in the spring of 2009 to ensure that the HVDS Protocol initiative complied with privacy requirements, including the Privacy Act and related policies. The PIA set out several recommendations with a view to mitigating privacy risks. CIC, the CBSA and the RCMP have agreed with all the recommendations and have already implemented measures to manage the risks, or are in the process of doing so.

The protection of personal information is important to the Government of Canada and FCC partner countries. Comprehensive privacy safeguards have been developed. They include:

• ensuring that all fingerprints remain anonymous and cannot be linked to an individual unless a match is detected between countries;
• destroying fingerprints once the search has been completed (i.e., no fingerprint database is being compiled);
• exchanging additional information that is relevant, proportionate and lawful (e.g., name, date of birth and travel document number) only when fingerprint matches are made; and
• using encryption and other security tools to protect files that are shared.

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