Registered Disability Savings Plans

Privacy Impact Assessment (PIA) summary

What is a Registered Disability Savings Plan?

Budget 2007 announced the introduction of a new Registered Disability Savings Plan (RDSP) whose purpose is to help parents and others save for the long-term financial security of persons with severe and prolonged disabilities.

The financial institutions that offer RDSPs to the public are known as issuers. The issuer must be a trust company licensed or authorized to carry on business in Canada. An individual who is a Canadian resident, eligible for the disability tax credit (DTC), and for whom an RDSP is established is the beneficiary. The beneficiary may be under the care of one or more primary caregivers. Lastly, the entity that opens an RDSP for a beneficiary is the holder. The beneficiary, their parent or other legal representative may become a holder.

The RDSP consists of three main elements:

1. Contributions from individuals with the consent of the plan holder. Contributions are limited to a lifetime maximum of $200,000. Contributions will be permitted until the end of the year in which the beneficiary attains 59 years of age.
2. Amounts paid into the plan from the Canada Disability Savings Grant program (Grants). Grants are paid at matching rates of 100%, 200% or 300% up to a maximum lifetime Grant limit of $70,000.
3. Amounts paid into the plan from the Canada Disability Savings Bond program (Bonds). Bonds of up to $1,000 per year will be provided to RDSPs established by low and modest-income families, up to a maximum lifetime Bond limit of $20,000, and will not be contingent on contributions.

The administration of the RDSP program is a shared responsibility between the CRA and Human Resources and Skills Development Canada (HRSDC). The Registered Plans Directorate is responsible for ensuring the requirements of the Income Tax Act are met with respect to the registration of RDSPs. HRSDC administers the program's Grants and Bonds in accordance with the provisions of the Canada Disability Savings Act and Canada Disability Savings Regulations.

Protecting Personal Privacy

A Privacy Impact Assessment (PIA) Report on the RDSP program was prepared by the Directorate to ensure that the CRA is compliant with privacy requirements as outlined in the Privacy Act, the Income Tax Act and Treasury Board Secretariat Policies. The purpose of this PIA Report is to determine if any privacy issues exist with respect to the Directorate's administration of the RDSP program and, if so, to provide recommendations on ways to mitigate or resolve them.

Summary of the RDSP PIA Report

The RDSP program involves the collection, use, disclosure and retention of personal information. The Income Tax Act provides the CRA with the authority to collect personal information for the purpose of administering the RDSP program. The privacy analysis examined the adherence to the ten privacy principles provided in the PIA Guidelines. The PIA Report has shown that:

• Personal information from the beneficiary, holder(s), primary caregiver(s), and legal representative (if applicable) is necessary to administer the RDSP program.
• Appropriate measures are in place for the custody and control of personal information. The institutions accountable have been documented.
• Only personal information necessary for program administration is collected. The Directorate collects personal information indirectly from HRSDC's Canada Disability Savings Program System.
• The CRA only discloses to HRSDC the required information needed to administer the Canada Disability Savings Act and Canada Disability Savings Regulations. Similarly, HRSDC only discloses the personal information necessary for the CRA to ensure compliance with the Income Tax Act.
• Personal information is safeguarded when transmitted between issuers and HRSDC because the data is encrypted. Information that is transmitted between HRSDC and the CRA is also encrypted and, thus, safeguarded.
• A description of the personal information maintained by the CRA with respect to the RDSP program is included in the CRA's Info Source chapter in the personal information bank entitled Registered Retirement and Deferred Income Plans (CRA PPU 226). Individuals can access their personal information either informally or through a formal Access to Information Act or Privacy Act request submitted to the CRA's Access to Information and Privacy Directorate.

Access to personal information is in accordance with the CRA information management, privacy, and security policies. An employee's view access profile limits the type of data they can access, ensuring that only authorized individuals have access to this data. To increase awareness of the importance of safeguarding personal information, the CRA provides security and privacy awareness training to its employees outlining relevant policies regarding breaches of security and privacy.