Recovery Benefits V2.0

Horizontal Integration Directorate
Assessment, Benefit, and Service Branch

On this page

• Overview & Privacy Impact Assessment Initiation (PIA)
• Summary of the project, initiative or change
• Risk identification and categorization

Overview & Privacy Impact Assessment Initiation (PIA)

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

Steven Morgan
Director General
Access to Information and Privacy Directorate

Name of program or activity of the government institution

Benefits:
We deliver a range of ongoing benefits, credits, and one-time payment programs that support the economic and social well-being of Canadians. Through processing activities, we make sure that Canadians receive their rightful benefits in a timely manner. We offer benefit recipients timely and accessible information on their entitlements and obligations both through our call centres and securely online, which helps Canadians become more aware of the benefits they are entitled to and how to receive them.

Standard or institution specific class of record:

Canada Emergency Response Benefit (CERB), Canada Emergency Student Benefit (CESB), Canada Recovery Benefit (CRB), Canada Recovery Sickness Benefit (CRSB) and Canada Recovery Caregiving Benefit (CRCB) – CRA ABSB 649

Standard or institution specific personal information bank:

Recovery Benefits: Canada Recovery Benefit (CRB), Canada Recovery Sickness Benefit (CRSB), and Canada Recovery Caregiving Benefit (CRCB), and the Canada Worker Lockdown Benefit (CWLB)
Bank number CRA PPU 642
TBS Registration Number pending

Legal authority for program or activity

• Canada Revenue Agency Act (CRAA), section 61 authorizes the CRA to enter into contracts, agreements or other arrangements with governments, public or private organizations and agencies or any person in the name of Her Majesty in right of Canada or in its own name. Note: This gives the CRA authority to enter into agreements to administer programs on behalf of other government or private sector organizations.
• The Canada Recovery Benefit Program is authorized under the Canada Recovery Benefits Act.
  • PART I covers the Canada Recovery Benefit.
  • PART 2 covers the Canada Recovery Sickness Benefit.
  • PART 3 covers the Canada Recovery Caregiving Benefit.
• Delegation instrument [Letter of Authorization] issued pursuant to section 11 of the Department of Employment and Social Development Act (DESDA) to the CRA in respect of subsection 4(1), section 6 and 7, subsection 8(2), subsection 11(1), sections 13 and 14, subsection 18(1), section 20, 21, and 25, subsections 26(1) and (2), section 28, subsections 29(1), (2), and (3), sections 30, 31, and 32, subsections 35(2) and (3), sections 37 and 38 of the Canada Recovery Benefits Act (CRBA), signed on October 2, 2020, authorizes the CRA to collect personal information and administer the CRBA on behalf of ESDC.

Pursuant to section 10 of the CRAA, the CRA is authorized to accept delegation of authority to administer the CRBA and CWLB on behalf of ESDC.

• For the administration of the program, the CRA will also use taxpayer information that is authorized (Section 241(4)(d)(vii.7 and 8) in the Income Tax Act).
• The Canada Worker Lockdown Benefit is authorized under the Canada Worker Lockdown Benefit Act.
• The Department of Employment and Social Development has authorized the Canada Revenue Agency to administer and enforce the Canada Workers Lockdown Benefit. Letter of authorization was signed December 2021.

Summary of the project, initiative or change

Overview of the Program or Activity

On October 2, 2020, the government passed legislation to support Canadians experiencing financial hardship as a result of the COVID 19 pandemic. The Canada Recovery Benefit (CRB), the Canada Recovery Sickness Benefit (CRSB), and the Canada Recovery Caregiving Benefit (CRCB) programs were established followed by the Canada Worker Lockdown Benefit in December 2021. The four benefits will be known collectively as the Recovery Benefits throughout this document.

The CRA administered these benefits on behalf of Employment and Social Development Canada (ESDC) and benefits are calculated using existing taxpayer information after an application has been received.

Applications for the Canada Recovery Caregiving Benefit and the Canada Recovery Sickness Benefit began October 5, 2020. Applications for the Canada Recovery Benefit began October 12, 2020. Applications for the Canada Worker Lockdown Benefit began December 2021 retroactive to October 2021.

These recovery payment programs required applicants to attest that they meet the eligibility requirements prior to submitting their application for each period of payment requested. Applicants have up to 60 days to apply for each qualifying period (this applies to all benefits). Individuals were only entitled to one benefit for each qualifying period.

Individuals had the option of three channels to apply for the various Recovery Benefits:

• by accessing it through their CRA My Account secure web portal;
• by calling a toll-free number equipped with an automated application process prior to November 29, 2021; or,
• by calling the individual enquiries toll-free number for assistance if they are not able to use the other services.

The Canada Recovery Benefit provided income support to employed and self-employed individuals who were directly affected by COVID-19 and were not entitled to Employment Insurance (EI) benefits. Eligible individuals received between $600 ($540 after taxes withheld)  and $1,000 ($900 after taxes withheld) for a two-week period up to a total of 38 weeks. The Canada Recovery Benefit was available from September 27, 2020, through to October 23, 2021.

Applications were accepted up to 60 days after each period had ended.

To be eligible for the CRB, applicants must have met all of the following conditions for the two-week period for which they were applying:

• they are resident and present in Canada.
• they are at least 15 years of age on the first day of the period.
• they have a valid Social Insurance Number (SIN).
• they had a total income of at least $5,000 for 2019, 2020, or in the 12-month period preceding the day on which they make their first application for this benefit, from one or more of the following sources:
  • employment income;
  • self-employment income; or
  • Employment Insurance (EI) maternity or parental benefits or Quebec Parental Insurance Plan (QPIP) benefits.
• they meet one of the following conditions for the period for which they are applying:
  • they are not employed or self-employed for reasons related to COVID-19; or
  • they have a reduction of at least 50% in their employment income and self-employment income for reasons related to COVID-19.
• they are seeking work during the period for which they are applying.
• they did not place undue restrictions on their availability for work, on or after September 27, 2020, unless reasonable to do so.
• they have not quit their employment or voluntarily ceased to work on or after September 27, 2020.
• they have not:
  • failed to return to employment, at the request of their employer, when it was reasonable to do so;
  • failed to resume self-employment when it was reasonable to do so; or
  • declined a reasonable offer to work that would have started during the two-week period.
• they are not in receipt of Employment Insurance (EI) benefits.
• they are not in receipt of the Canada Recovery Caregiving Benefit (CRCB), the Canada Recovery Sickness Benefit (CRSB), short-term disability benefits, any Employment Insurance (EI) benefits, or Quebec Parental Insurance Plan (QPIP) benefits.
• they are not self-isolating or in quarantine due to international travel.

The Canada Recovery Sickness Benefit provided income support to employed and self-employed individuals who were unable to work because they were sick or needed to self-isolate due to COVID-19, or had an underlying health condition that put them at greater risk of getting COVID-19. Eligible individuals received $500 ($450 after taxes withheld) for each one-week qualifying period up to a total of 42 weeks. The Canada Recovery Sickness Benefit was available from September 27, 2020, through to May 7, 2022. Applications were accepted up to 60 days after each period had ended. To be eligible for the Canada Recovery Sickness Benefit, the individual must have met all the following conditions for the one-week period for which they were applying:

• they are resident and present in Canada;
• they are at least 15 years of age on the first day of the period;
• they have a valid Social Insurance Number (SIN);
• they had a total income of at least $5,000 for 2019, 2020, or in the 12-month period preceding the day on which they make their first application for this benefit, from one or more of the following sources:
  • employment income;
  • self-employment income; or
  • Employment Insurance (EI) maternity or parental benefits or Quebec Parental Insurance Plan (QPIP) benefits.
• they are unable to work for at least 50% of the time they would have otherwise worked or devoted to their work because:
  • they had or might have had COVID-19;
  • they self-isolated on the advice of their employer, a medical practitioner, nurse practitioner, person in authority, government, or public health authority for any reason related to COVID-19; or
  • they have an underlying condition that in the opinion of a medical practitioner, nurse practitioner, person in authority, government or public health authority would make them more susceptible to COVID-19.
• they are not in receipt of paid leave from an employer.
• they are not in receipt of the Canada Recovery Benefit (CRB), the Canada Recovery Caregiving Benefit (CRCB), short-term disability benefits, any Employment Insurance (EI) benefits, or Quebec Parental Insurance Plan (QPIP) benefits.
• they are not self-isolating or in quarantine due to international travel.

The Canada Recovery Caregiving Benefit provided income support to employed and self-employed individuals who were unable to work because they must care for their child under 12 years of age or a family member who needed supervised care. This applied if their school, regular program or facility was closed or unavailable to them due to COVID-19, or because their dependent was sick, self-isolating, or at risk of serious health complications due to COVID-19. Eligible individuals received $500 ($450 after taxes withheld) for each one-week period up to a total of 44 weeks for the household. The Canada Recovery Caregiving Benefit was available from September 27, 2020, through to May 7, 2022. Applications were accepted up to 60 days after each period had ended.

To be eligible for the CRCB, the individual must have met all the following conditions for the one-week period for which they were applying:

• they are resident and present in Canada.
• they are at least 15 years of age on the first day of the period.
• they have a valid Social Insurance Number (SIN).
• they had a total income of at least $5,000 for 2019, 2020, or in the 12-month period preceding the day on which they make their first application for this benefit, from one or more of the following sources:
  • employment income;
  • self-employment income; or
  • Employment Insurance (EI) maternity or parental benefits or Quebec Parental Insurance Plan (QPIP) benefits.
• they are unable to work for at least 50% of the time they would have otherwise worked or devoted to their work because of one of the following reasons:
  • they had to take care of a child who was under 12 years of age on the first day of the period for which they are applying because:
    • their school or other facility that they normally attended was closed, open only certain times, or open only for certain children for reasons related to COVID-19;
    • they could not attend school or other facility that they normally attend under the advice of a medical professional due to being at high risk of having serious health complications if they contract COVID-19;
    • they were in isolation on the advice of a medical practitioner, nurse practitioner, person in authority, government or public health authority for reasons related to COVID-19;
    • they contracted or might have contracted COVID-19; or
    • the individual who usually provided care of their child was not available for reasons related to COVID-19.
  • they had to provide care to a family member who requires supervised care because:
    • their day program or facility that they normally attended was closed, open only certain times, or open only for a certain persons for reasons related to COVID-19;
    • they could not attend the day program or other facility that they normally attend under the advice of a medical practitioner or nurse practitioner who is of the opinion that the family member would be at high risk of having serious health complications if they contract COVID-19;
    • they were in isolation on the advice of a medical practitioner, nurse practitioner, person in authority, government or public health authority for reasons related to COVID-19;
    • they contracted or might have contracted COVID-19; or
    • the care services that are normally provided to the family member at their normal place of residence are not available for reasons related to COVID-19.
• they are the only individual from their household claiming the Canada Recovery Caregiving Benefit.
• they are not applying for a week that would exceed the 38-week maximum per household.
• they are not in receipt of paid leave from an employer.
• they are not in receipt of the Canada Recovery Benefit (CRB), the Canada Recovery Sickness Benefit (CRSB), short-term disability benefits, any Employment Insurance (EI) benefits, or Quebec Parental Insurance Plan (QPIP) benefits.

they are not self-isolating or in quarantine due to international travel.

What’s New

This PIA has been updated to include the Canada Workers Lockdown Benefit, reflect extended qualifying periods and enhanced validation on the application for the Canada Recovery Benefit, the Canada Recovery Caregiving Benefit, and the Canada Recovery Sickness Benefit.  Retroactive applications for the Canada Recovery Caregiving Benefit, and Canada Recovery Sickness Benefit were accepted until July 6, 2022.

On November 30, 2020, the application for the recovery benefits was expanded and applicants were asked to provide free-form text to provide further context used to validate their eligibility. 

Employment and Social Development Canada, in partnership with the Canada Revenue Agency, added an upfront validation regarding international travel to the Canada Recovery Sickness Benefit, Canada Recovery Caregiving Benefit and Canada Recovery Benefit application process on January 11, 2021, retroactive to applications starting January 3, 2021.

ESDC passed legislation regarding international travel and the Canada Recovery Sickness Benefit, Canada Recovery Caregiving Benefit and Canada Recovery Benefit, which was implemented on March 15, 2021, resulting in a change to the eligibility and attestations for the benefits. Applicants had to attest that they were not self-isolating or in quarantine due to international travel.

Extend the Canada Recovery Caregiving Benefit

• The Canada Recovery Caregiving Benefit program originally scheduled to end in  November 20, 2021, was extended to May 7, 2022.

Extend the Canada Recovery Sickness Benefit

• The Canada Recovery Sickness Benefit program originally scheduled to end in  November 20, 2021, to was extended to May 7, 2022

The Canada Worker Lockdown Benefit Act was implemented in December 2021. The Canada Worker Lockdown Benefit provided income support to employed and self-employed individuals who were unable to work due to a COVID-19 Lockdown Regions Designation Order. Eligible individuals received $300 ($270 after taxes withheld) for each one-week period they were entitled to. Applications were accepted up to 60 days after each qualifying period had ended.

Scope of the Privacy Impact Assessment

This Privacy impact assessment concerns the administration of the benefit programs and payments only and is considered in scope for this PIA. Post payment verification, compliance and enforcement activities are not in the scope of this PIA and will be reported on under a separate PIA (under development). 

Risk identification and categorization

A) Type of program or activity

Compliance / Regulatory investigations and enforcement  

Level of risk to privacy: 3

Details:

Personal information will be used by the CRA to administer the Recovery Benefits on behalf of the ESDC. The personal information is used for the identification, determination, validation and payment of the recovery benefits. Information is also used to determine whether an individual knowingly participated in or made a false statement or omission. The consequences can include reviews which may result in termination and/or recoup of benefits, and possibly levying civil penalties under section 27 of the Canada Workers Lockdown Benefit Act and section 39 of the Canada Recovery Benefits Act.  

B) 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:

Personal information may include: name, contact information, Social Insurance Number, date of birth, date of death, incarceration status, mailing address, income, the attestation for eligibility, and direct deposit information.

To further determine eligibility, personal information will also be cross-referenced with existing data. 

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 CRA is sharing personal information relating to the Recovery Benefits with federal government departments. It is being shared with Employment and Social Development Canada for the purpose of identifying taxpayers in receipt of Employment Insurance to determine benefit eligibility. Information is shared with Employment and Social Development Canada for policy and program evaluation and with Public Services and Procurement Canada for the purpose of administering payments. Information will be stored in a private sector organization anticipated to start in 2022.

D) Duration of the program or activity

Short–term program 

Level of risk to privacy: 2

Details:

This is a short-term program to help Canadians facing hardship as a result of the COVID-19 outbreak. At this time, no application is permitted to be made on any day that is more than 60 days after the end of the week to which the benefit relates; however, the enforcement activities (to audit and/or recover erroneous or over payments) could last a few years. Note: post-payment verification, compliance and enforcement activities are out of scope and will be assessed in a separate PIA.

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 any of the Recovery Benefits.

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?
   

   Risk to privacy: No

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

   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: Not Applicable

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:

Individuals submit their personal information in their Recovery Benefit applications to the CRA electronically using My Account via wireless or non-wireless technology. Alternatively, they may submit their personal information to the CRA via an automated telephone service using a land-based telephone line or cellular. This Protected B information is then stored in various CRA systems and databases, which have access to other systems and in limited circumstances can be transferred to a departmentally approved and secure portable device such as a secure USB key with higher level of encryption.

ESDC’s data exchange mechanism (secure FTP), which is supported by Shared Services Canada, has existed for over a decade.

CRA employees use laptops with Secure Remote Access to work remotely across Canada. Both casual and routine telework employees are required to enter into an agreement with the Agency outlining an employee’s responsibilities and obligations; in addition, employees must be trained on the protection and handling of information and security awareness.

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 is compromised, it has the potential to cause financial harm and embarrassment to the affected individual.

In early August 2020, the Government of Canada took action to stop credential-stuffing attacks against the Government of Canada Branded Credential Service (“GCKey”) and the CRA’s My Account for individuals.

The CRA continues to monitor for suspicious activities resulting from the credential-stuffing attacks. Safeguards have been placed on affected accounts. The CRA has also put measures in place to identify high-risk accounts in order to prevent potentially suspicious applications from being made.