Income Verification Services

Privacy Impact Assessment (PIA) summary - Information and Relationship Management Directorate, Strategy and Integration Branch

Overview and privacy impact assessment initiation

Government institution

Canada Revenue Agency

Government official responsible for the privacy impact assessment (PIA)

Yves Giroux
Assistant Commissioner, Strategy and Integration 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

Income verification services

Description of the class of record and personal information bank

Standard or institution specific class of record:

• Individual Returns and  Payment Processing Program (CRA ABSB 217) 
• Benefit Programs - Canada Child Benefits and other Federal, Provincial, and Territorial Programs and Supplements (CRA ABSB 646)
• Benefit Programs - Disability Tax Credit (DTC) Program (CRA ABSB 647)
• Benefit Programs - Working Income Tax Benefit Program (CRA ABSB 346)
• Benefits Programs - Goods and Services Tax/Harmonized Sales Tax (GST/HST) Credit and other related Provincial and Territorial Credit Programs (CRA ABSB 648)

Standard or institution specific personal information bank:

• Individual Returns and Payment Processing (CRA PPU 005)
• Canada Child Tax Benefit (CCTB) Program (CRA PPU 063)   
• Disability Tax Credit (DTC) Program (CRA PPU 218)
• Working Income Tax Benefit (WITB) (CRA PPU 178)
• Goods and Services Tax / Harmonized Sales Tax Credit (GST/HST credit) (CRA PPU 140)

Legal authority for program or activity

Section 241 of the Income Tax Act allows the CRA to provide certain taxpayer information to any person, including a federal, provincial or territorial official, with the consent of the taxpayer. The legal authority that allows the provincial, territorial or federal government department to collect personal information and enter into an agreement with the CRA is specified in each written agreement.

Summary of the project / initiative / change

Individuals who apply for various provincial or territorial and federal income assistance programs have to provide proof of income. Examples of income assistance programs are drug cost assistance, housing, and student loans and grants. With the applicant’s consent, the Canada Revenue Agency (CRA) sends the proof of income electronically and securely to the partner government.

Risk identification and categorization

A) Type of program or activity

Administration of programs or activity and services 

Level of risk to privacy: 2

Details: The CRA gives personal information to partners with whom we have a written agreement to establish eligibility for benefits or assistance.

B) Type of personal information involved and context

Social insurance number, medical, financial or other sensitive personal information 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: Most of the information used in the context of income verification fits into category 3 since it is personal data such as social insurance number, date of birth, address, marital status and financial information.

C) Program or activity partners and private sector involvement

One or several federal, provincial or municipal governments

Level of risk to privacy: 3

Details: Taxpayer information is exchanged between the CRA and other provincial, territorial or federal government departments. Details are outlined in a written collaborative agreement.

D) Duration of the program or activity

Long-term program

Level of risk to privacy: 3

Details: Income verification is a long-term program with no clear end. Individual agreements, however, end when partners’ programs change or stop. There is also a 10-year mandatory review of each agreement.

E) Program population

The program affects certain individuals for external administrative purposes.

Level of risk to privacy: 3

Details: The program affects the applicants of related provincial or territorial and federal income assistance programs.

F) Technology and privacy

Does the new or modified program or activity involve implementing a new electronic system, software or application program, including collaborative software or groupware, to support the program or activity for creating, collecting or handling personal information?

Risk to privacy: No

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

Risk to privacy: No

The new or modified program or activity involves implementing one or more of the following technologies:

Enhanced identification methods - this includes biometric technology (facial recognition, iris scan, gait analysis, fingerprint analysis, voice print, radio frequency identification, etc.) as well as easy-pass technology, new identification cards including magnetic stripe cards, smart cards (identification cards 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

Surveillance—this includes surveillance technologies such as audio and video recording devices, thermal imaging, recognition devices, radio frequency identification, surreptitious surveillance and interception, computer-aided monitoring including audit trails, satellite surveillance, etc.

Risk to privacy: No

Automated personal information analysis, personal information matching and knowledge discovery techniques - for the purposes of the Directive on privacy impact assessments, government institutions have to identify activities that use automated technology to analyze, create, compare, identify or extract personal information. These activities include personal information matching, record linkages, personal information mining, personal information comparison, knowledge discovery, information filtering or analysis. Activities involve some form of artificial intelligence or machine learning to uncover intelligence, trends or patterns or to predict behavior.

Risk to privacy: Yes

Details: Using file transfer protocol with Entrust encryption software, the federal, provincial or territorial partner gives the CRA information, such as the given name, surname, social insurance number and date of birth, to validate an individual’s identity. To get a high accuracy rating, the social insurance number and two of the three other elements must match. Once a match is made, the CRA sends the partner the type and number of data fields they agreed upon, using the same file transfer protocol.

G) 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 CRA pulls personal information from its mainframe system and sends it to the partner organization using file transfer protocol with Entrust encryption software.

H) Risk impact to the individual or employee

Details: If personal data is compromised, it could cause financial harm and embarrassment to the individual.

I) Risk impact to the institution

Details: If information is accidently or deliberately discharged or compromised, it could cause embarrassment and loss of credibility and public trust to the CRA and its federal, provincial or territorial Partner.