Community Volunteer Income Tax Program - Privacy impact assessment summary

Benefit Programs Directorate,
Assessment, Benefit, and Service Branch

Overview & PIA Initiative

Government institution
Canada Revenue Agency

Government official responsible for the privacy impact assessment (PIA)
Frank Vermaeten
Assistant Commissioner
Assessment, Benefit, and Services Branch

Head of the government institution or Delegate for section 10 of the Privacy Act
Marie-Claude Juneau
ATIP Coordinator

Name of program or activity of the government institution
Tax Information Services and Assistance

Summary of the project / initiative / change:

The Community Volunteer Income Tax Program (CVITP) is a collaboration between community organizations and the Canada Revenue Agency (CRA). The program has been operating since 1971 and its mandate is to help individuals and families in need by preparing their income tax and benefit returns. In order to qualify to receive help, a person must have a modest income and a simple tax situation.

Community organizations throughout Canada operate on a volunteer basis to host tax preparation clinics and prepare income tax and benefit returns for eligible individuals within their community.

The role of the CVITP is to:

The program is offered in the province of Québec under the Volunteer Program. A memorandum of understanding with Revenu Québec outlines the joint obligations and duties of both parties. Revenu Québec’s and CRA’s employees work together as coordinators for the Volunteer Program. Revenu Québec’s employees have access to the program’s information for their region via CRA’s computers and network. All personal information collected is retained by CRA.

Volunteers and organizations must register on a yearly basis. The preferred method of registration is to fill out an online form available on the CRA website. An account is created every time a new volunteer or organization registers. Subsequent registrations are stored under the account belonging to the volunteer or organization. Account & registration details are stored in a standalone database called the CVITP Management Tool (CMT).

Organizations who cannot register online can register over the phone by talking directly to a CVITP coordinator. After a community organization registers, a CVITP coordinator will review the information, make sure that the registration is complete and that the organization is in good standing. Afterwards the organization is approved to participate for a period of one year.

Volunteers who cannot register online can register by mailing a completed and signed Form T242, Volunteer Information and Software Agreement, or Form COM-307, Information Sheet and Tax Software Agreement (for Québec), to a CRA program coordinator. In both instances, a CVITP coordinator will capture the information in the CMT.

After a volunteer registers, they must meet the screening criteria by either:

The community organization is responsible for reviewing the PRC and informing the CVITP coordinator via email of whether or not they accept to work with the volunteer.

Once the screening criteria is met, the volunteer’s registration is approved and he can start filing tax returns on behalf of taxpayers. An exception is made to the screening criteria for volunteers who have participated in the program for more than 5 years, this exception will be grand-fathered as of 2016. Also, in remote areas where no community organizations exist, a volunteer may be allowed to participate independently even though they are not affiliated to an organization. Independent volunteers must meet the security screening via the EFILE certification unless they fall under the grand-fathered exception.

In addition to the information collected for registration purposes, anonymized views and opinions are collected as a result of some projects operating in partnership with CVITP to monitor the effectiveness of the program. Currently, two such projects are underway: the Ethnography Study conducted by the CRA’s Strategy and Integration Branch, and a discussion forum with the organizations. Reports may be written to summarize views and opinions but will not include any personal information that would make it possible to identify the participants.

The scope of this privacy impact assessment (PIA) is limited to the CRA’s role as coordinator and overseer of the participation of coordinators and volunteers in the CVITP. It does not cover the preparation of income tax and benefit returns, the interaction between the volunteer and the taxpayer, nor does it cover the EFILE certification process.

Description of the class of record and personal information bank

Standard or institution specific class of record: Community Volunteer Income Tax Program - CRA ABSB 110
Standard or institution specific personal information bank: Community Volunteer Income Tax Program PIB - CRA PPU 100

Legal authority for program or activity

The Minister of National Revenue is responsible to administer and enforce the Income Tax Act (ITA) under section 220 of the ITA. The CRA has been granted responsibility for “general administrative policy in the Agency” under paragraph 30(1)(a) of the Canada Revenue Agency Act (CRA Act).

Risk identification and categorization.

1) Type of program or activity
Administration of Programs / Activity and Services
Level of risk to privacy: 2
Details: Personal information is used to assess suitability of, and to register volunteers for the Community Volunteer Income Tax Program (CVITP) and to identify a CVITP organization contact. Information is also collected to monitor the effectiveness of the program.

2) Type of personal information involved and context
Social Insurance Number, medical, financial or other sensitive personal information and/or the context surrounding the 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: The information used to administer the CVITP includes name, contact information, police records checks, and biographical information. 

EFILE certification may be used as a security measure instead of the police records check. When this occurs, only the result of the certification is communicated by the EFILE helpdesks to the CVITP program. The personal information collected by EFILE is not shared with CVITP.

Views and opinions may also be collected in order to enhance the program. In the framework of the Ethnography Study, interviews will be conducted; only the general portion of the interview will be recorded on encrypted devices so that the researchers can fully analyze the information at a later time. A consent form and a protocol have been developed for the Study.

In addition, discussion forums held with organizations will be done on an informal and verbal basis. Views and opinions will be shared with the administrators of the program but no reports will be made.

3) 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 CVITP is a community-based outreach program that is administered by the CRA in partnership with community organizations as well as with the Revenue Québec. 
Community organizations confirm with the CRA when they review and accept a police record check as a security measure for a volunteer. Starting October 2017, the CRA will inform organizations when their volunteers have been approved so that they can start to participate in the program.

4) Duration of the program or activity
Long-term program
Level of risk to privacy: 3
Details: The CVITP is a long term program. It has been in place since 1971 and there is no plan to stop the program.

5) Program population
The program affects certain individuals for external administrative purposes.
Level of risk to privacy: 3
Details: This program affects individuals applying to be volunteers in the CVITP. It also involves contacting individuals representing community organizations who participate in the CVITP.

Views and opinions of CVITP and study participants are collected for non-administrative purposes to monitor the effectiveness of the program.

As the CVITP operates at arm’s-length with the volunteers and organizations, there is no information shared between the CVTIP program and the taxpayer.

6) Technology & privacy
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?
Risk to privacy: Yes

Does the new or modified program or activity require any modifications to IT legacy systems and/or services?
Risk to privacy: No

The new or modified program or activity involves 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
Details: n/a

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
Details: The program does not involve the use of surveillance on individuals associated with the CVITP.

However, upon request, ITB is able to retrieve the audit log directly from the CMT in order to review who has accessed an account.

The information is used to verify that only authorized users have accessed personal information and to ensure that access can be linked to specific individuals to support the investigation of suspected or alleged misuse. 

Every time CRA employees log in on their computers, or RQ coordinators log in their laptop provided by CRA, a notice pops up requiring them to acknowledge that they are aware that all access to CRA networks is monitored and that access is on a need-to-know basis. This information is already described in the standard personal information bank Electronic Network Monitoring Logs PSU 905.

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
Details: Automated personal information matching will be used to authenticate returning volunteers in order to avoid duplication of volunteer accounts.

7) Personal information transmission
The personal information is used in a system that has connections to at least one other system.
Level of risk to privacy: 2
Details: The volunteers and organizations can register online by filling out an electronic registration form available on the CRA’s website, and the information is transmitted into the CMT. Alternatively, volunteers can fill out a paper form and organizations can register over the phone; in those instances, the information is entered manually in the CMT by a CRA coordinator.

The personal information of the individuals applying to be volunteers in the CVITP and the individuals representing community organizations who participate in the CVITP is not transferred to other mediums.

Although there is no information shared between the program and the taxpayer, it is important to note that the CVITP is responsible for establishing procedures to ensure all participants are aware of, and adhere to, federal privacy requirements and minimum standards for the protection of personal information. As such, specific instructions are provided to volunteers on how to handle and protect taxpayers’ information. For example, volunteers must encrypt returns using the tax software and save the electronic files on a USB flash drive only. If the tax software does not encrypt returns, they must use an encrypted USB flash drive.

8) Risk impact to the institution
Details: Given the limited personal information collected on the volunteers and the contacts of community organizations, a privacy breach would not cause serious injury or harm to the individual involved in the event of a privacy breach. However, it could cause a measure of embarrassment if it became known that they were not accepted in the program.

9) Risk impact to the individual or employee
Details: Given the limited personal information collected on the volunteers and the contacts of community organizations, a privacy breach would not cause serious injury or harm to the individual involved in the event of a privacy breach. However, it could cause a measure of embarrassment if it became known that they were not accepted in the program.

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