Privacy Impact Assessment: Passport Program Transition

On July 2, 2013, primary accountability for the Passport Canada Program (PPTC) was transferred from the Minister of Global Affairs Canada (GAC), formerly the Department of Foreign Affairs, Trade and Development (DFATD), to the Minister of Immigration, Refugees and Citizenship Canada (IRCC), formerly Citizenship and Immigration Canada (CIC), with Employment and Social Development Canada (ESDC) serving as the delivery agent for the majority of domestic passport services on behalf of IRCC. ESDC’s service delivery responsibilities for the Passport Program are restricted to its Service Canada (SC) initiative.

Pursuant to this transfer, IRCC assumed accountability for the Passport Program, including program policy, decisions on passport eligibility, refusal and revocation, and management of service fees through the Revolving Fund. ESDC became responsible for the bulk of domestic service delivery, including in-person and mail application intake, examination and processing, document printing and call centres. GAC continues to provide passport services through its network of points of service abroad.

The objective of the Passport Program Transition Privacy Impact Assessment (PIA) was to identify the business processes that will govern the program as of April 1, 2014. The scope of the PIA is to explain the work flows that have changed, explain the work flows that require additional or expanded exchanges of information between the three departments, and explain how the three departments work together in delivering the Passport Program.

To administer the Passport Program, personal information (including sensitive information) is collected directly from program applicants. There are, however, unique instances where the personal information of a Canadian abroad may be collected from foreign agencies and international organizations to manage certain citizenship and immigration cases. Information collected to administer the Passport Program may be used to make decisions, detect fraud, and conduct criminal investigations impacting employees and certain citizens for external administrative purposes.

The PPTC is a longstanding program that uses multiple information technology (IT) systems which, in some cases, connect directly to other departmental systems. Information may also be printed and may be transmitted using wireless technologies. In the event of any modifications to IT legacy systems, a separate PIA will be conducted.

While facial recognition and microchip technology for enhanced identification methods may be used, the PPTC does not use surveillance technologies for surveillance purposes. To ensure any administrative action is being performed on the correct individual, automated personal information analysis, data matching and knowledge discovery techniques are employed.

The legal authority to process applications and issue passports is provided to the Minister of Immigration, Refugees and Citizenship Canada within the July 2, 2013 amendments to the Canadian Passport Order (CPO).While the entire CPO provides the authority, Section 3 provides the authority for the Minister to issue passports; Section 6 allows the Minister to require an application for a passport to be submitted by applicants; and Section 12 of the CPO allows the Minister to authorize the Minister of ESDC to conduct domestic service delivery. Moreover, Section 34.1 of the Department of Employment and Social Development Act provides the necessary authority to allow ESDC employees to disclose information to support the delivery of the Passport Program, such as tracking lost mail, referring cases to IRCC’s Program Integrity Branch, and verifying one’s date of birth with provincial and territorial Vital Statistics Offices, etc.

To ensure the Personal Information Banks (PIBs) of all three departments consistently reflect how passport services are delivered, IRCC will initiate a PIB evaluation project to ensure all former PPTC PIBs are aligned with Treasury Board Secretariat guidelines/suggestions and the new structure of the Passport Program. ESDC and IRCC will collaborate to address the gaps in existing PIBs and align the PIBs of both departments to reflect consistency where required.

Concerted efforts have been made by all three departments to ensure that the transition of the Program and various issues related to human resources, finance, legal considerations, information technology, accommodations, and business process change have been appropriately addressed, and to assure that the privacy regime of all stakeholders has been adequately represented.

Many of the risks initially identified in the PIA in early 2014 were also identified in prior PIAs of the PPTC. These, as well as any other additional risks that were anticipated as a consequence of the transition, were deemed to be low. These risks have recently been re-examined to ensure that they have been adequately mitigated or that mitigation strategies are in place.

All three departments continue to engage collaboratively in order to manage a Passport Program that optimizes service to Canadians and that it is consistently aligned with international standards.

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