Service Feedback Program v1.0

Service, Innovation and Integration Branch  
Chief Service Officer Directorate 

On this page

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

Overview & Privacy Impact Assessment (PIA) Initiation 

Government institution

Canada Revenue Agency

Government official responsible for the PIA

Maxime Guénette
Assistant Commissioner, Chief Data Officer and Chief Service Officer
Service, Innovation and Integration Branch

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

France Carty
Acting Director General
Access to Information and Privacy Directorate

Name of program or activity of the government institution

Service Feedback

We offer clients a process to provide feedback, including complaints, suggestions and compliments, and resolve problems about the service, quality, or timeliness of the Canada Revenue Agency’s (CRA) work, as described under the service rights in the Taxpayer Bill of Rights. The service issues raised by clients provide valuable insight and that feedback, in turn, helps the CRA identify and implement ongoing service improvements.

Standard or institution specific class of record:

Service Feedback
CRA SIIB 575

Standard or institution specific personal information bank:

Service Complaints
CRA PPU 571
TBS Registration Number: 002024

Legal authority for program or activity

Personal information is collected under the authority of section 5 of the Canada Revenue Agency Act which gives to the CRA the mandate to support the administration and enforcement of the legislation under the responsibility of the Minister of National Revenue, including Part I of the Canada Pension Plan, Part IV of the Employment Insurance Act, collection of debts under the Canada Student Financial Assistance Act and the Canada Student Loans Act. More specifically, section 220 of the Income Tax Act and section 275 of the Excise Tax Act authorize the CRA to collect personal information for purposes related to the administration and enforcement of these acts. Personal information collected is used to administer the Service Feedback Program.

The social insurance number is collected pursuant to section 237 of the Income Tax Act and section 275 of the Excise Tax Act and is used for identification purposes.  

Summary of the project, initiative or change

Overview of the Program or Activity

The Service Feedback Program offers a means to resolve taxpayers’ issues where normal administrative and operational channels and procedures have been unable to do so. Taxpayer problems are usually resolved at the local level by the enquiries agents or resource officers. However, from time to time, exceptional cases arise that need more specialized intervention, which require referrals to the Service Feedback Program. This program helps identify problems while upholding the eight service rights outlined in the Taxpayer Bill of Rights. It also gives taxpayers an avenue for bringing their concerns to the CRA’s attention.

The Service Feedback Program is responsible for receiving, investigating, analyzing and tasking to the appropriate CRA business lines to respond to the issues, when taxpayers submit service-related feedback. Service refers to the quality and timeliness of the work performed by the CRA. It can be about any program, process or service across all business lines of the CRA. Service-related feedback could include mistakes (which could refer to misunderstandings or omissions), undue delays (beyond service standards), poor or misleading information, staff behaviour (allegation of discourteous service, harassment or unfair and improper treatment by CRA employees) and legislative requirements (accessibility barriers, official language issues). Feedback includes complaints, problems/issues, compliments, and suggestions.

Before seeking assistance from the Service Feedback Program, an individual should either contact the program with which they are dealing or the Client Contact Centre to discuss their issue. If their issue cannot be resolved in a manner acceptable to the individual, a service complaint can be submitted using Form RC193 (Service Feedback form). That form can be submitted using various intake methods: an online tool or a fillable PDF version. The completed PDF can be submitted via mail, fax, or through three separate online account types: i.e., the form can be submitted via the “Submit Documents” feature of MyAccount, My Business Account, or Represent a Client. Persons with impairment, including a physical, mental, intellectual, cognitive, learning, communication or sensory impairment or a functional limitation, may submit their Service Feedback form in various formats, including email or by speaking to a Contact Centre Agent.  

From the portal, mail, fax, and internal account submissions, the Service Feedback form is transmitted to a system accessible to the CRA’s National Intake Centre. From those submissions, cases are created and tracked in a dedicated case management system. 

CRA service feedback officers are responsible for reviewing the complaint and determining how best to resolve the issue. Communication to the complainant to gather additional or clarifying information may occur via telephone or in writing; email or other methods may be used for those with accessibility needs. Once assessed, the appropriate CRA business line is required to make changes in CRA systems, if warranted, and inform the service feedback officer who will, in turn, communicate the outcome of the complaint to the individual who submitted the complaint. 

When warranted, a complaint related to a CRA employee may be referred to the Internal Affairs and Fraud Control Division, Finance and Administration Branch, for their review and action.  

The Service Feedback Program is also responsible for resolving unique problems received by the CRA Contact Centre or service feedback officer warranting urgent action by the CRA to address a taxpayer’s urgent issues, such as those related to humanitarian and/or financial pressures. For example, if an individual did not receive their monthly Canada Child Benefit payment and the resulting financial pressures are severe, such as eviction or inability to feed family members, service feedback officers are responsible for analyzing the reported issue and urgently assessing and resolving the issue. Much like the complaint process, the service feedback officer will task CRA business line staff with resolving issues in a CRA system and ensuring any disbursement of funds is urgently provided to the individual, if warranted.

The problem resolution process and the complaint process, may also be initiated by a Member of Parliament on behalf of their constituent through the submission of Form RC 161 Authorization for Parliamentarians. The individual’s Member of Parliament submits the form directly to a regional Service Feedback Program official via unsecure email or fax.

When necessary to support the complaint or problem, the Service Feedback Program may disclose personal information to provincial/territorial tax and benefit organizations, as well as other federal government departments/agencies, such as Service Canada.

If an individual is not satisfied with the CRA’s response to the outcome of their complaint or how their problem was resolved, they may make a complaint to the Office of the Taxpayers’ Ombudsperson. At times, the Office of the Taxpayers’ Ombudsperson may receive a complaint which was not initially sent to the CRA Service Feedback Program. In these instances, the Office of the Taxpayers’ Ombudsperson will review this complaint using their own processes and when appropriate, will refer the complaint to the CRA by forwarding the Office of the Taxpayers’ Ombudsperson Complaint Form completed by the individual—a disclosure authorized through a consent statement found on that form or the Permission to Disclose form. The CRA’s Ombudsperson Liaison Office, which is the designated point of contact for communication between the Office of the Taxpayers’ Ombudsperson and the CRA, receives the complaint form and provides it to the Service Feedback Program where it is processed like other complaints.  

Moreover, the Service Feedback Program, through the submission of the same Service Feedback form, is responsible for receiving and disseminating compliments and suggestions. Again, the service feedback officer reviews the form and, for compliments, forwards the information to the employee’s manager for recognition. For suggestions, the service feedback officer determines the appropriate business line and forwards the information to them for consideration.  

The Service Feedback Program tracks and leverages service feedback received from Canadians by consolidating and analyzing service feedback data to provide evidence-based guidance for decision-making and the identification of potential service improvement opportunities, and to develop and contribute to corporate reports on service. It raises service-related systemic issues to identify potential service improvements, which provides a proactive rather than reactive approach to how the CRA handles service-related complaints. It may also collect feedback on the Service Feedback Program’s processes to continuously improve the program.

What’s New

The Service Feedback form was updated in 2020 to support the submission of compliments and suggestions, in addition to complaints. Moreover, the Service Feedback Program was created on April 1, 2023, to encompass what was formerly called the Service Complaints and Problem Resolution Program. The personal information collected, used, and disclosed as a result of these groups merging is not changing, but to ensure a comprehensive program definition, a program name change is being made.

The program name and description has been approved by the CRA but has not yet been posted to the CRA’s Info Source publication, which currently reflects the program name and description as Service Complaints. The program personal information bank will be changed, through this privacy impact assessment, to Service Feedback Program once various changes to the bank are approved by Treasury Board of Canada Secretariat.

Scope of the Privacy Impact Assessment

To ensure compliance with the Privacy Act and associated CRA and Treasury Board of Canada Secretariat privacy policies, this privacy impact assessment examines the Service Feedback Program. This includes the program activities involving the collection, use, disclosure, retention and destruction of personal information included in various forms and referrals, predominantly the Service Feedback form. This privacy impact assessment also assesses the systems used to receive and store feedback, as well as the internal referrals of issues/problems to be resolved by various CRA business lines. 

As this privacy impact assessment is focused solely on the Service Feedback Program, the following activities are mentioned but are not fulsomely assessed in this privacy impact assessment: 

1. Ombudsperson’s Liaison Office: The primary role of this office is to be the primary CRA point of contact with the Office of the Taxpayers’ Ombudsperson. Those liaison activities are not in scope for this privacy impact assessment. heir inclusion in the scope of this privacy impact assessment is limited to receiving a complaint form and referring it to the National Intake Centre. 
2. Other CRA business lines: Various business lines with the CRA are responsible for assessing issues to be resolved, as shared with them by service feedback officers. Their activities in resolving the issue, the systems they access, data corrections, and the errors that may have occurred that resulted in the complaint are not in scope.
3. Online account creation and maintenance: The creation and management of personal information related to three online accounts is out of scope: My Account; My Business Account; Represent a Client.

Risk identification and categorization

• A) Type of program or activity

  Administration of programs / Activity and services 

  Level of risk to privacy: 2

  Details:

  The Service Feedback Program is a formalized complaint/problem resolution process that allows the CRA to gather, track and analyze taxpayers' feedback with the goal of improving service to taxpayers, and resolving issues. The program receives complaints and urgent problems/issues that are analyzed to determine if there are any account changes required to be actioned in order to come to a resolution. The personal information collected for these purposes results in a decision on the complaint/problem to be resolved, which directly impacts the individual; the outcome typically relates to a potential need to adjust or reassess tax and/or benefits. The Service Feedback Program also gather, track and analyze anonymous suggestions or compliments with the goal of improving service to taxpayers.

  Service Feedback Program officials do not record account changes that result in some resolutions. Instead, program officials notify CRA business lines of the issues and resolutions that are necessary. In turn, the CRA business lines are responsible for receiving that information and actioning it, while the service feedback officer communicates the resolution to the taxpayer.

  The program also collects compliments and feedback/suggestions, which are forwarded to the appropriate program for consideration.

  The outcome of complaints and compliments also has potential impacts on CRA employees who may receive recognition or a reprimand for their actions.

• 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:

  In most cases, the Service Feedback form requires identifying information on an individual or entity, such as a business or charity, (name, address, telephone number), as well as the social insurance number, business number, and/or other account numbers (import/export, trust account, non-residence account number, etc.). When the feedback is being filed anonymously, no identifying information is provided on the form. In addition to the social insurance number / business number, the form requires a narrative text describing the nature of the individual’s complaint, problem, compliment, or feedback. The individual may also submit additional documents for two reasons. First, if the free text field (for the narrative explanation) is not big enough, a separate document may be attached to finalize the individual’s statement. And second, the form states that “any related documents” may also be attached. Historically, this has resulted in the following information being described in the narrative or included as separate documents: medical information, medical receipts, bank statements, disability application form completed by a medical specialist, written description of their lifestyle, health or financial situation, humanitarian issues, credit card statements, citizenship and/or permanent resident cards, and other information. The type of information provided in the narrative text and/or supporting documents varies from one submission to the next.   

  The Authorization for Parliamentarian form (Form RC161) collects the same type of information on the client, as well as contact details for the Member of Parliament’s staff. 

  Furthermore, information accessed by service feedback officers varies from one case to the next, but likely requires access to tax and benefit data in one or multiple CRA systems to determine if the nature of the complaint/problem is an issue in need of correction and which area of the CRA needs to provide a response.  

• 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 Service Feedback Program is primarily a complaint and problem resolution program involving only internal stakeholders. The submission of forms by individuals involves the use of a digital repository built and managed by a third-party service provider. That digital repository provides an Agency-wide digital solution that is secure and efficient. The Service Feedback Program onboarded to the third-party digital repository on October 5, 2020. Once documents are submitted, the National Intake Centre retrieves the information and creates a case in a dedicated case management system where cases are tracked, managed, and resolved.

  Program officials are responsible for assessing and addressing complaints and completing the standardized documentation (Complaint Summary Form) associated with the feedback. The Complaint Summary Form details information collected to resolve the complaint and decisions/recommendations made by the Officer. The Complaint Summary Form is stored in the case management system. 

  Program officials have mainly read-only access to various CRA systems to be able to perform their assessment. When action must be taken in a CRA system to resolve a complaint, Service Feedback Program officials seldom make system changes. Instead, they refer the issue to the appropriate CRA business line, which determines and performs the necessary actions to address the service issues falling under its responsibility.

  Taxpayer’s information is used at the time the business line addresses the complaint. As part of the analysis of the service issue raised by a taxpayer, a review of the taxpayer’s account is most often necessary. In order to accurately respond to a service issue, the service feedback officer as well as the business line will review the taxpayer’s account to identify allegations of mistreatment, delays in processing, etc., as part of the complaint’s review.

  If an individual submits a complaint to the Office of the Taxpayers’ Ombudsperson prior to allowing the Service Feedback Program to resolve the issue, the Office of the Taxpayers’ Ombudsperson will not hear their complaint. Instead, the Office of the Taxpayers’ Ombudsperson will forward the Office of the Taxpayers’ Ombudsperson Complaint Form to the CRA’s Ombudsperson Liaison Office, which, in turn, provides the information to the Service Feedback Program. Also, an individual may seek assistance from their Member of Parliament which may result in the Member of Parliament’s office submitting an Authorization for Parliamentarians form to the CRA Service Feedback Program officials for their action. 

  At times, the Service Feedback Program may share tax and benefit information with a provincial/territorial entity to support a problem or complaint resolution. As an example, when a Canada Child Benefit review is ongoing and the benefit is being held until the review is completed, a provincial benefit agency, such as Ontario Works, may provide the client with a social assistance supplement to cover the loss of revenue until the review is completed by the CRA and a retroactive payment issued. Once the Canada Child Benefit review is completed, the client repays the supplement that was received from Ontario Works. In these instances, the Service Feedback Program discloses benefit information to Ontario Works so that an accurate repayment can be made.

• D) Duration of the program or activity

  Long-term program

  Level of risk to privacy: 3

  Details:

  The Service Feedback Program is a long-term program with no “sunset” date.

• E) Program population

  The program affects certain individuals for external administrative purposes.

  Level of risk to privacy: 3

  Details:

  Individual taxpayers or entities submit complaints, problems/issues, compliments, and suggestions. For complaints and problems/issues, an administrative purpose occurs impacting the taxpayer—a decision on their complaint/problem is made by the CRA and they are notified. These decisions by the CRA may negatively or positively impact the individual, often related to the amount of tax or benefit the individual receives.

  A taxpayer’s complaint or compliment may also impact CRA employees who may receive recognition or reprimand.

• 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: No

  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:

  Taxpayers’ correspondence is received by a third-party service provider, digitized and saved in the electronic document management system. The information is extracted from the electronic document management system, data entry is performed, and cases are created in a dedicated case management system. When data is automatically sent from the document management system to the case management system, a case number is created and transmitted back to the document management system. 

  Requests received in writing are sent to the National Intake Centre (Shawinigan, QC). The mail room at the National Intake Centre mails the forms to the third-party vendor for storage in the document management system. 

  Service Feedback Program staff access various CRA systems to assess a complaint/problem. As some employees telework, wireless technologies are used to gain access to the CRA network where system access is available. 

  Once a case is closed in the case management system, case status information is transmitted to the document management system which triggers the retention period for the vendor-provided document management system.

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

  Details:

  In the event of a privacy breach, there could be significant financial and reputational damage to the individual. The information collected by the Service Feedback Program, which includes name, address, social insurance number, and other information can be used by a fraudster to commit identify theft. Moreover, the embarrassment and reputational impact related to the unauthorized release of someone’s financial status, tax debt/arrears, fines, penalties, narrative information on forms, supporting documents, or other information could exacerbate the impact. With all these risks also come the reasonable potential that the individual will experience mental health injury that negatively impacts their lives and relationships.