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Canada Child Benefit and Related Benefits v2.0

Assessment, Benefit and Service Branch
Benefit Programs  Directorate

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Overview & Privacy Impact Assessment (PIA) Initiation 

Government institution

Canada Revenue Agency

Government official responsible for the PIA

Gillian Pranke
Assistant Commissioner
Assessment, Benefit and Service Branch

Head of the government institution or Delegate for section 10 of the Privacy Act

Anne Marie Laurin
Director General
Access to Information and Privacy Directorate

Name of program or activity of the government institution

Benefits

Standard or institution specific class of record:

Benefit Programs - Canada child benefit and related benefits 
CRA ABSB 646

Standard or institution specific personal information bank:

Canada child benefit and related benefits
CRA PPU 063
TBS Registration: 003210

Legal authority for program or activity

Under section 4 of the Privacy Act, a government institution will not collect any personal information unless the information relates directly to an operating program or an activity of the institution.

Subsection 220(1) of the Income Tax Act gives the Minister of National Revenue implied authority to collect information to administer and enforce the Income Tax Act. Once collected, any information, including personal information, is protected as taxpayer information as defined in the Income Tax Act.

The Canada child benefit is administered under section 122.6 of the Income Tax Act. The young child supplement to the Canada child benefit is administered under subsection 122.61(1.2) of the Income Tax Act.

Personal information is collected in direct relation to these programs. The social insurance number is also collected for identification purposes in keeping with section 237 of the Income Tax Act.

The Canada Revenue Agency (CRA) administers the legislative authorities for the provincial and territorial child benefit programs under each respective provincial tax legislation.

Section 61 of the Canada Revenue Agency Act allows the CRA to put agreements in place with other federal, provincial, and territorial governments to carry out an activity or program it administers.

Paragraph 241(4)(j) of the Income Tax Act authorizes an official to use information (including personal information) relating to a taxpayer to provide information to the taxpayer.

Subparagraph 241(4)(d)(vii.1) of the Income Tax Act authorizes an official to provide taxpayer information to Employment and Social Development Canada (ESDC) solely to administer or enforce the Canada Education Savings Act or a designated provincial program. The personal information released to ESDC helps that department administer the Canada education savings programs.

The CRA collected direct deposit and contact information from ESDC under subsection 241(5) of the Income Tax Act upon consent from the taxpayer to administer section 122.61 of that act.

The CRA will provide personal taxpayer information to Employment and Social Development Canada for the administration and enforcement of the Canadian dental care plan as authorized through section 241(4)(d)(xx,1) of the Income Tax Act.

Summary of the project, initiative or change

Overview of the Program or Activity

Canada child benefit

The Canada child tax benefit was a non-taxable amount paid monthly to help eligible families with the cost of raising children under 18 years of age. It included the:

The national child benefit supplement was the Government of Canada’s contribution to the national child benefit initiative. That initiative was a partnership among the federal, provincial, and territorial governments, as well as First Nations. It aimed to help prevent and reduce child poverty.

The child disability benefit is a tax-free monthly benefit for families who care for children under age 18 with a severe and prolonged impairment in physical or mental functions. Families who are eligible for the Canada child tax benefit for a child will receive the child disability benefit if the child is also eligible for the disability amount. This amount is also known as the disability tax credit.

Individuals can apply for child benefits by:

The federal government later planned to give more Canadian families money to raise their children. So it created an enhanced Canada child benefit program as of July 2016 (2015 benefit year) that replaced the:

However, for the July 2016 to June 2018 period, the CRA continued to support the national child benefit supplement initiative and calculate an equivalent amount within the Canada child benefit.

Eligibility requirements for the new Canada child benefit reused the existing Canada child tax benefit definitions with enhanced eligibility rules. No new collection of information occurred under the Canada child benefit. Individuals who had already applied for the universal child care benefit or the Canada child tax benefit were not required to apply for the new Canada child benefit.

Benefits and credits that relied on the Canada child tax benefit information to determine eligibility and entitlement will now use the Canada child benefit information. The CRA will continue to use the Canada child benefit application to determine eligibility for these related federal, provincial, and territorial programs:

Federal programs

Provincial and territorial programs   

If eligible, the payment amount will be automatically calculated using the information from the applicant and their spouse’s or common-law partner’s income tax and benefit returns.

What’s New

Spousal link and data matching for the registered educational savings plan

ESDC put in place a legislative change to the Canada Education Savings Act effective January 1, 2018. The change is known as the spousal link. It allowed the cohabiting spouse or common-law partner of a primary caregiver to designate a trust for the Canada learning bond and Canada education savings grant. Previously, only the primary caregiver could designate a trust. 

Now, when an individual (subscriber) opens a registered education savings plan for a dependant, ESDC sends information to the CRA identifying the subscriber and the beneficiary. The CRA will match that information to the CRA’s identification and Canada child benefit databases. If the subscriber is the primary caregiver for the Canada child benefit, the CRA will confirm their entitlement and income thresholds. The CRA will send that personal information to ESDC, which will use it to administer Canada education savings programs. The CRA releases that information under subparagraph 241(4) (d) (vii.1) of the Income Tax Act.

To continue to help ESDC administer their programs under the new Canada Education Savings Act, the CRA will expand the matching it does on requests received from ESDC for the Canada education savings programs. The matching will include the subscriber’s cohabiting spouse or common-law partner.

The memorandum of understanding between the CRA and ESDC for the registered education savings plan and Canada education savings programs has been amended to include the new spousal link and enhanced data matching parameters.

Direct deposit and address linking 

The CRA is working with ESDC to improve services to Canadians by sharing personal information. Individuals previously had the option to update their direct deposit information and mailing address with one federal department and if they consented, that department could pass that information to another federal department.

ESDC would use the direct deposit information and mailing address it received to administer the Canada Pension Plan, employment insurance, and old age security programs.

The CRA would use the direct deposit information and mailing address it received from ESDC to administer programs under the Income Tax Act, including the Canada child benefit.

Previously, the consent to share this information could be given verbally, electronically through My Account, or in writing. This exchange of information has been suspended indefinitely.

In-person updates to direct deposit and address through Service Canada

Effective April 15, 2024, individuals can update their information in person through a Service Canada counter agent. After authenticating and helping the individual with their ESDC files, the counter agent will offer to forward any address or direct deposit changes to the CRA. The individual must verbally consent to having their direct deposit and address information electronically forwarded to the CRA to take advantage of this service. 

Connecting Families Initiative

Launched in November 2018, the Innovation Sciences and Economic Development Canada  Connecting Families Initiative helped bridge the digital divide for Canadian families who struggle to afford access to home Internet. The initiative relies on Internet service providers that participate voluntarily without receiving a government subsidy. This initiative brings together the public, private, and non-profit sectors and has helped tens of thousands of low-income Canadian families access the Internet. Since the launch in 2018, over 82,000 low-income households have benefited.

The CRA supports this initiative by identifying eligible families receiving the maximum Canada Child benefit and issuing invitation letters containing a unique access code. This unique access codes is then provided by the family applying for  ISED’s connecting families program to provide reduced internet costs. The access code acts as a validation the family has met the CCB eligibility requirement.

In April 2022, phase two of the initiative introduced significantly faster speeds and increased the data usage amount. The new phase also broadened eligibility from families receiving the maximum Canada child benefit to include low-income seniors receiving the maximum guaranteed income supplement. This initiative will be available until March 2027.

Canada Border Services Agency – residency

The CRA has entered into an agreement with the Canada Border Services Agency (CBSA) to receive exit information on individuals who have left Canada for more than 183 consecutive days. The CBSA will send to the CRA the full name, date of birth, gender, and exit date of those individuals. The CRA will match this data to its identification database. When it finds a match, the CRA will review the benefits account to determine whether the individual still meets the criteria for the Canada child benefit under section 122.6 of the Income Tax Act.  

Section 122.6 states that an individual must be a resident of Canada for tax purposes to be eligible for the Canada child benefit. Although residency is a case-by-case determination, an extended absence from the country is a strong indicator of non-residency. Therefore, a further review of the benefit account is required. This new sharing of information started in March 2020; however, due to COVID, the CBSA halted the information feed. The feed started back up again in August 2022.

Alberta child and family benefit

As part of the 2019 budget, the Province of Alberta introduced the Alberta child and family benefit. This benefit, which began in July 2020, replaced the Alberta family employment tax credit (AFETC) and the Alberta child benefit (ACB). This single benefit continues to provide payments to lower-income families in Alberta who are eligible for the Canada child benefit. The CRA administers this benefit on the behalf of the Alberta Government. The Alberta child and family benefit is issued quarterly.

Pandemic relief

In May 2021, the CRA began administering the Canada child benefit young child supplement and issuing payments as a COVID-19 pandemic relief measure. This initiative was intended as a short-term supplement to the Canada child benefit. It provided up to four payments in 2021 to families with children under the age of six who were eligible for the Canada child benefit.

Contingency extension in 2020 due to pandemic

The CRA postponed the deadline for the 2019 income tax and benefit return deadline to June 1,2020, in response to the COVID-19 pandemic. Because of this, the CRA provided contingency payments to families who were eligible for the Canada child benefit or a related benefit payment in June 2020 but hadn’t filed their returns yet.

The CRA issued these estimated payments from July 2020 to September 2020. Once a family filed its 2019 return(s) and the updated income information was available, the CRA adjusted the payments it had previously issued. If a family did not file its tax return(s), it had to repay the full estimated amount the CRA had issued.  

Benefits system renewal project

In February 2021, the CRA designed a new system. The goal was to renew the systems the CRA used to process benefit and credit payments to the Canadian public. This newly designed system provides a solid foundation that improved flexibility, sustainability, and stability. 

Canada dental benefit

In December 2022, the Government of Canada introduced the interim Canada dental benefit. This interim benefit uses information from the Canada child benefit. The Canada dental benefit is intended to help lower dental costs for eligible families. Parents and guardians may be eligible if they pay for dental care for a child under 12 years old who does not have access to a private dental insurance plan. The CRA conducted a separate privacy impact assessment on the Canada dental benefit program.

One-time top-up to the Canada housing benefit

In December 2022, the CRA processed applications and payments for the one-time top-up to the Canada housing benefit program to assist low-income families with the cost of rent. This was a tax-free payment to directly support low-income renters who are experiencing housing affordability challenges in 2022. The payment was calculated based on the 2021 adjusted family net income and a higher income threshold was used for applicants who were either single and residing with a CCB dependant, single and had a disabled adult dependent, or married or common-law. Applicants were encouraged to apply for the CCB to provide their statement of world income if they were a newcomer to Canada in 2022 and did not meet the 2021 filing requirement. A separate privacy impact assessment was conducted on the one-time top-up to the Canada housing benefit initiative.

Canada Student Financial Assistance – repayment assistance plan

In November 2021, the CRA and ESDC entered into an agreement for the CRA to help ESDC validate and determine the eligibility of student loan borrowers applying for the repayment assistance plan. This plan helps student loan borrowers who are experiencing hardship repay their student loans. Approved applicants can have their monthly student loan and interest payments reduced for a specified period.

Upon consent of the applicant or their spouse, the CRA will provide any personal information it has about the applicant. This information can include their name, social insurance number, date of birth, income, marital status, and the number of dependants eligible for the Canada child benefit. This exchange of information is done through a third-party service provider, the National Student Loans Service Centre, that has a service contract with ESDC. The exchange is done using a secure electronic transfer. The Centre identifies the applicant and spouse to the CRA, and the CRA provides a response with the requested personal information if it finds a match in its records.  

BC family benefit

The BC child opportunity benefit replaced the BC early childhood tax benefit in October 2020 and was renamed the BC family benefit in January 2023. In September 2022, the British Columbia government announced enhanced payments for the BC child opportunity benefit for January, February and March 2023. Individuals could receive the enhanced benefit payments even if they didn’t normally receive the benefit because their family net income exceeds the income threshold. This was a monthly payment integrated with the Canada child benefit for residents of British Columbia.

The CRA and Yukon Ministry of Health and Social Services – automated benefits application

Effective October 2023, the Yukon will work with the CRA to process a Canada child benefits application for a newborn child. It will use the automated benefits application process to transmit information from the birth registration form to the CRA. The individual must consent on the birth registration form to allow the Yukon vital statistics agency under the Yukon Ministry of Health and Social Services to electronically send birth information to the CRA. If the individual  does not consent, they can submit a Canada child benefits application (Form RC66) or apply online using My Account.

Pre-natal infant nutrition supplement (previously called the mother baby nutrition supplement)

Effective April 2022, the mother baby nutrition supplement was renamed the prenatal infant nutrition supplement. This monthly benefit is a supplement to the Newfoundland and Labrador child benefit and is intended for low-income expectant mothers with children under the age of one living in that province. This is a monthly payment integrated with the Canada child benefit.

Proof of birth policy change for the Canada child benefit

As of November 20, 2023, all Canada child benefit applications must include a proof of birth if the CRA has never previously paid benefits for that child. Previously, proof of birth was not required if the child was born in Canada and is under one year of age. This change affects only applications received through the CRA’s My Account or by mail. The automated benefits application satisfies the proof of birth requirement since the provincial or territorial government securely transmits the child’s birth registration number to the CRA.

This change responds to the Office of the Auditor General’s recommendation in 2021 to improve the administration of the Canada child benefit program. This strategy ensures the same level of integrity for My Account and paper applications as is currently provided with the automated benefits application.

Canadian dental care plan

The Canadian dental care plan is a Health Canada initiative that ESDC administers. This plan will provide dental coverage for uninsured Canadians with an annual income of less than $90,000, with no deductions for those with family incomes under $70,000. As of July 2024, the CRA will help ESDC administer the plan for applicants with children under 18. To do this, the CRA will use a secure data exchange confirming the applicant is the primary caregiver of the child or children for the Canada child benefit.

Scope of the Privacy Impact Assessment

The scope of this PIA is the administration of the Canada child benefit and related federal, provincial, and territorial benefits and credits.

These activities are not included in this PIA:

Programs and initiatives that focus on child benefits and credits are constantly changing. Therefore, when we identify a new initiative or a change to an existing benefit, we will review and update this PIA accordingly. 

Risk identification and categorization

A) Type of program or activity

Compliance and regulatory investigations and enforcement  

Level of risk to privacy: 3

Details:

The personal information is used to identify, determine, validate, and pay benefits and credits. The information is also used to determine whether an individual knowingly participated in or made a false statement or omission. The consequences can include reviews that may result in terminating and/or recovering the benefits and possibly charging civil penalties under subsection 163(2) of the Income Tax Act. 

Also, in limited cases, information obtained during a validation or compliance review could be used to refer the matter to the CRA’s Criminal Investigations Program for further investigation. An investigation could result in criminal charges under section 238 or 239 of the Income Tax Act against a particular individual.  

B) Type of personal information involved and context

An individual’s social insurance number and their medical, financial or other personal information, as well as the context surrounding that personal information, is sensitive. Personal information of minors or incompetent individuals or involving a representative acting on behalf of the individual. 

Level of risk to privacy: 3

Details:

Personal information collected includes details such as name, contact information, financial information, social insurance number (SIN) and signature, marital status, as well as residency and citizenship status.

In addition, some of the information includes the personal information of minors.

C) Program or activity partners and private sector involvement

Private sector organizations or international organizations or foreign governments 

Level of risk to privacy: 4

Details:

The Canada child benefit and related benefits  includes administering benefit and tax credit programs for federal, provincial, and territorial partners. The CRA discloses information to its partners to make sure benefits and tax credits are accurately calculated and for program evaluation. It also discloses information to Public Services and Procurement Canada so that department can issue payments.

Effective March 2020, the CRA receives information from the CBSA so the CRA can determine an individual’s residency status in Canada. This information is required to determine eligibility for the Canada child benefit and integrated payments.

The CRA provides information to ESDC in support of the employment insurance family supplement, the Canada education savings programs, and the learning bond.

As well, the CRA discloses financial information and mailing addresses to ESDC so that department can administer the Canada Pension Plan, employment insurance, and old age security programs.

The CRA sends and receives benefit information including eligibility, entitlement, payment, and identification data to other provincial or territorial governments and to First Nation departments so they can administer social and income assistance benefits. The CRA will continue to work with our provincial and territorial partners to assist with their administration of social and income assistance to families with children under the principles of the original national child benefit initiative. The CRA passes benefit information, including eligibility, entitlement, payment, and identification data, to the provinces for this purpose.

Although Quebec does not participate in the national child benefit initiative, the province does acknowledge that benefit and participates in an exchange with the CRA to provide income assistance to families with children. The CRA passes benefit information, including eligibility, entitlement, payment, and identification data, to Quebec for this purpose.

The CRA also uses information internally to collect outstanding balances and for audit activities, appeals, statistical gathering, and call centre enquiry responses.

A third party in the private sector stores paper copies containing personal information.

D) Duration of the program or activity

Long-term 

Level of risk to privacy: 3

Details:

Although some of the individual provincial or territorial benefits and credits may be short term, most are not. The Canada child benefit is a long-term program with no established end date.

E) Program population

The program affects certain individuals for external administrative purposes.

Level of risk to privacy: 3

Details:

The program affects individuals who apply for the Canada child benefit, their spouse or common-law partner and their children under 18 years of age.

F) Technology & privacy

  1. Does the new or modified program or activity involve the implementation of a new electronic system, software or application program including collaborative software (or groupware) that is implemented to support the program or activity in terms of the creation, collection or handling of personal information?

    2. Risk to privacy: Yes

  2. Does the new or modified program or activity require any modifications to IT legacy systems and/or services?

    3. Risk to privacy: Yes

  3. Does the new or modified program or activity involve the implementation of one or more of the following technologies?

Enhanced identification methods - this includes biometric technology (i.e. facial recognition, gait analysis, iris scan, fingerprint analysis, voice print, radio frequency identification (RFID), etc.) as well as easy pass technology, new identification cards including magnetic stripe cards, "smart cards" (i.e. identification cards that are embedded with either an antenna or a contact pad that is connected to a microprocessor and a memory chip or only a memory chip with non-programmable logic).

Risk to privacy: No

Use of Surveillance - this includes surveillance technologies such as audio/video recording devices, thermal imaging, recognition devices, RFID, surreptitious surveillance/interception, computer aided monitoring including audit trails, satellite surveillance etc.

Risk to privacy: No

Use of automated personal information analysis, personal information matching and knowledge discovery techniques - for the purposes of the Directive on PIA, government institutions are to identify those activities that involve the use of automated technology to analyze, create, compare, identify or extract personal information elements. Such activities would include personal information matching, record linkage, personal information mining, personal information comparison, knowledge discovery, information filtering or analysis. Such activities involve some form of artificial intelligence and/or machine learning to uncover knowledge (intelligence), trends/patterns or to predict behavior.

Risk to privacy: Yes

G) Personal information transmission

The personal information is transmitted using wireless technologies.

Level of risk to privacy: 4

Details:

Personal information can be used in a system that has access to other systems and can be transferred to a secure portable device encrypted using CRA-approved encryption.

Online services:

The CRA uses specially configured computer web servers for any online services (for example, My Account) and corporate firewalls to protect its web servers from unauthorized access. The CRA does not store personal information on these servers; it securely stores personal information only on separate computer systems that are not directly accessible from the Internet.

When transmitting personal information, access to the CRA’s web servers is limited to web browsers that meet Government of Canada security standards of encryption. The CRA ensures that personal and financial information is encrypted—or scrambled—when it transmits that information between an individual’s computer and the CRA’s web servers. This ensures that computer hackers and other Internet users cannot view or alter the data being transmitted.

Portable devices:

Some employees’ workstations include CRA-issued laptops in docking stations. Laptops comply with the security requirements of the Computing Environment Policy with encryption and access control. Any telework is carried out through secure remote access.

Any USB keys used must be issued by the CRA and formatted with encryption technology specific to the user.

Data transfers and exchanges:

All electronic transactions are securely transferred using Entrust encryption software with public key infrastructure.

Direct deposit and identification changes (such as an address change) received in writing are digitized and stored in the Document Management Portal for later access by CRA employees on a need-to-know basis.

H) Potential risk that in the event of a privacy breach, there will be an impact on the individual or employee

Details:

If the personal information was compromised, the information has the potential to cause financial or physical harm and embarrassment to the individual.

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