Privacy Impact Assessment Summary: Rural Northern Immigration Pilot (RNIP)
Lead Government Institution
Immigration, Refugees and Citizenship Canada (IRCC)
Legal Authority
The legal authority to establish the RNIP is identified in the Ministerial Instructions, which may be created in accordance with section 14.1 of the Immigration and Refugee Protection Act (IRPA), which states:
- For the purpose of supporting the attainment of economic goals established by the Government of Canada, the Minister may give instructions establishing a class of permanent residents as part of the economic class referred to in subsection 12(2) and, with respect to the class that is established, governing any matter referred to in paragraphs 14(2)(a) to (g), 26(a), (b), (d) and (e) and 32(d) and the fees for processing applications for permanent resident visas or for permanent resident status and providing for cases in which those fees may be waived.
The Ministerial Instructions state that the ‘rural and northern community immigration class’ is established as part of the economic class referred to in IRPA, ss. 12(2).
Various sections of the IRPA and the Immigration and Refugee Protection Regulations (IRPR) support the activities of IRCC in the processing of permanent resent applications and the decision-making process; see Part 5 of IRPR (Permanent Residents) and Part 6 (Economic Classes).
Description of the program/activity
The Rural and Northern Immigration Pilot (RNIP) was established on September 1, 2019, to provide a pathway to permanent residency for skilled foreign workers who want to work and live in one of 11 Canadian communities.
Foreign nationals must obtain a recommendation from an Economic Development Organization (EDO) in one of the communities to participate in the RNIP. Each EDO has its own application procedure, and local laws/policies govern it. EDOs collaborate with community organizations to assess the Foreign National against the community’s selection criteria to determine if the Foreign National is an appropriate candidate warranting a recommendation from the EDO.
After assessing an applicant, the EDO provides information on the FN to IRCC, who remains the final decision-making authority on the application for permanent residency. While an EDO recommendation is a requirement for candidates to apply permanent residency, IRCC remains as the final decision authority on eligibility and admissibility criteria for permanent resident applications.
Personal Information Banks
Summary of Risk Identification and Categorization
In its Directive on Privacy Impact Assessment, the Treasury Board has expressed that the PIA must include a completed risk identification and categorization section and make public those risk ratings. A risk rating must be assigned to each risk area named and described in Appendix C of the Directive on Privacy Impact Assessment. The numbered risk scale is presented in ascending order: the first level (1) represents the lowest level of potential risk for the risk area; the fourth level (4) represents the highest level of potential risk for the given risk area. For this PIA, the risk areas and associated risk levels are as follows:
| a) Type of program or activity | Risk scale |
|---|---|
| Program or activity that does not involve a decision about an identifiable individual | Checkbox: unchecked ☐ 1 |
| Administration of program or activity and services | Checkbox: unchecked ☐ 2 |
| Compliance or regulatory investigations and enforcement | Checkbox: checked ☒ 3 |
| Program or activity does involve a decision about an identifiable individuals | Checkbox: unchecked ☐ 4 |
| Criminal investigation and enforcement or national security | Checkbox: unchecked ☐ 5 |
| b) Type of personal information involved and context | Risk scale |
|---|---|
| Only personal information, with no contextual sensitivities, collected directly from the individual or provided with the individual's consent for disclosure under an authorized program. | Checkbox: unchecked ☐ 1 |
| Personal information, with no contextual sensitivities after the time of collection, is provided by the individual with consent to use personal information held by another source. | Checkbox: unchecked ☐ 2 |
| Personal information of minors. legally incompetent individuals or involving a representative acting on behalf of the individual. | Checkbox: unchecked ☐ 3 |
| Social Insurance Number, medical, financial, or other sensitive personal information or the context surrounding the personal information is sensitive; | Checkbox: unchecked ☐ 4 |
| Sensitive personal information, including detailed profiles, allegations or suspicions, bodily samples, or the context surrounding the personal information, is particularly sensitive | Checkbox: checked ☒ 5 |
| c) Program or activity partners and private sector involvement | Risk scale |
|---|---|
| Within the institution (among one or more programs within the same institution) | Checkbox: unchecked ☐ 1 |
| With other government institutions | Checkbox: unchecked ☐ 2 |
| With other institutions or a combination of federal, provincial, territorial, and municipal governments | Checkbox: checked ☒ 3 |
| Private sector organizations | Checkbox: unchecked ☐ 4 |
| International organizations or foreign governments | Checkbox: unchecked ☐ 5 |
| d) Duration of the program or activity | Risk scale |
|---|---|
| One-time program or activity | Checkbox: unchecked ☐ 1 |
| Short–term program or activity | Checkbox: checked ☒ 2 |
| Long-term program or activity | Checkbox: unchecked ☐ 5 |
| e) Program population | Risk scale |
|---|---|
| The program's use of personal information for internal administrative purposes affects certain employees. | Checkbox: unchecked ☐ 1 |
| The program's use of personal information for internal administrative purposes affects all employees. | Checkbox: unchecked ☐ 2 |
| The program's use of personal information for external administrative purposes affects specific individuals. | Checkbox: checked ☒ 4 |
| The program's use of personal information for external administrative purposes affects all individuals. | Checkbox: unchecked ☐ 5 |
| f) Technology and privacy (A YES response indicates the potential for privacy concerns and risks, which will require consideration and, if necessary, mitigation). | Risk scale |
|---|---|
| Does the new or substantially modified program or activity involve implementing a new electronic system or using an emerging technology to support the program or activity in terms of creating, collecting, or handling personal information? | Checkbox: unchecked ☐ Yes Checkbox: checked ☒ No |
| Does the new or substantially modified program or activity require any modifications to information technology (IT) legacy systems? | Checkbox: checked ☒ Yes Checkbox: unchecked ☐ No |
Specific technological issues and privacy Does the new or substantially modified program or activity involve the implementation of new technologies or one or more of the following activities: enhanced identification and matching methods, enhanced data collection methods use or disclosure of personal information, surveillance interjurisdiction or trans-border sharing of personal information or use of Artificial Intelligence technology for automated personal information analysis, personal information matching, and knowledge discovery techniques. If Yes to any of the above, it indicates the potential for privacy concerns and risks, which will require consideration and possible mitigation. |
Checkbox: unchecked ☐ Yes Checkbox: checked ☒ No |
| g) Personal information transmissionty | Risk scale |
|---|---|
| The personal information is used within a closed system (i.e., no connections to the Internet, Intranet, or any other system, and the circulation of hardcopy documents is controlled). | Checkbox: unchecked ☐ 1 |
| The personal information is used in a system with connections to at least one other system. | Checkbox: checked ☒ 2 |
| The personal information is transferred to a portable device (i.e., USB key, diskette, laptop computer), transferred to a different medium, or printed. | Checkbox: unchecked ☐ 3 |
| The personal information is transmitted using wireless technologies. | Checkbox: unchecked ☐ 4 |
| The personal information is transmitted through a Cloud service. | Checkbox: unchecked ☐ 5 |
Summary of Risks and Mitigation Strategies
This PIA addresses the following four risks and offers mitigation strategies.
Risk 1
There is a medium risk that the EDOs may not handle RNIP applicant data in a secure and privacy-focused manner.
Mitigation
Although IRCC isn’t accountable for each EDO’s adherence to local privacy laws and policies, it does have the power under the MOUs/ISAs to conduct a program review and audit of each EDO to gather verification information about EDO business practices. Should any shortcomings in EDO privacy practices be found, IRCC plans to seek advice from Legal Services and PPMD to figure out the most effective way to rectify these issues.
Risk 2
There is a low risk that data transmitted from the EDOs to the IRCC could be accessed by IRCC employees who aren’t directly involved with the RNIP. This is because the data is sent to a common mailbox (MS Outlook), and decrypted spreadsheets are stored in the corporate repository (GCDOCS).
Mitigation
IRCC plans to reassess its existing procedures to guarantee the proper security of data. The department will continue to periodically review the process for safeguarding information in GCDOCS and MS Outlook to maintain security and will monitor access controls to ensure adherence to procedures.
Risk 3
There is a medium risk that inaccuracies could arise due to human errors during data entry.
Mitigation
As a part of the program’s functioning, IRCC cross-checks each PR application with the records supplied by the EDOs. If any discrepancies are detected, IRCC requests validation from the EDO to confirm the accuracy of the data. On the processing side of IRCC, quality assurance checks are conducted on applications to ensure that the rate of errors remains within the acceptable range.
Risk 4
There is a low risk that the EDOs might provide more information within the e-Submission Form for Information on Suspected or Confirmed Fraud than what IRCC requires.
Mitigation
An examination of the e-submission forms received from the EDOs revealed that they did not include information that was not relevant to the matter at hand. IRCC’s internal procedure also ensures that any potentially irrelevant information is addressed before the form is stored and disseminated.
Conclusion
The above-mentioned four privacy risks were identified in the low to medium range and mitigation strategies are ongoing to address them.