Privacy Impact Assessment for Talent Cloud - Beta
Talent Cloud is an experiment responding to challenges Canada’s Public Service is facing in the digital age. These include:
- a critical government-wide shortage of talent in digital and tech professions;
- lack of agility in government’s current staffing model that prevents the rapid formation of cross-sector teams to respond to government priorities;
- ongoing issues of inclusion and diversity, with a particular focus on issues related to the retention, promotion and recognition of Indigenous talent; and,
- costly inefficiencies in the current Public Service staffing model, leading to both sub-optimal service outcomes for Canadians and a diminished value proposition for the Public Service as an employer (particularly in high-demand and emerging skills fields).
Talent Cloud is pilot testing a new process to recruit talent for project-based work in the Government of Canada. It is targeting a 30 day staffing model for project-based (term) positions. This initiative aims to create the world’s first public sector “gig” marketplace, structured around next generation workers’ rights. In Talent Cloud’s Phase 1: Beta test (Digital and Tech Talent Pilot), the project is looking to staff 10-20 term positions using the externally advertised process. Only funding partner departments can staff using Talent Cloud during its pilot development phases. The expansion and continuation of the pilot will depend on the results of the Phase 1 pilot tests.
Talent Cloud is an agile build, applying principles of human-centered design and business process engineering.
The information Talent Cloud will be collecting under this Privacy Impact Assessment (PIA) covers the period between fall and winter of 2018 (Phase 1: Beta test). The information being collected reflects the insights and findings from user testing sessions on the staffing redesign conducted from 2017 to 2018. Talent Cloud will continue to improve the project based on input and feedback from users, including after the Talent Cloud platform and website go live. While the functionality of the site and the language may evolve, the critical details around information collection and storage provided in this document will be respected throughout.
Why the Privacy Impact Assessment was necessary
Talent Cloud is a staffing platform, which, by its very nature, involves the collection of personal information. Given that Talent Cloud is a new staffing model, this suggests that a PIA is strongly advisable, if not required.
Privacy Impact Assessment objectives
- To assess, reduce and mitigate potential risks associated with the collection of personal information.
- To resolve any privacy issues that may be of potential public concern.
Privacy Impact Assessment findings and risk summary
Talent Cloud will be restricting the collection of information during the pilot phase (Phase 1: Beta test) to Protected A information. In the event of a privacy breach, this could reasonably be expected to cause some level of injury to job applicants, in cases where the information shared with Talent Cloud is not already a matter of public record on a job applicant’s social media presence (e.g. LinkedIn profile).
In some cases, Talent Cloud will be deliberately taking “risks” on the platform, in that the team will be testing new ideas and approaches to staffing, for which current policy guidance either does not exist or is significantly outdated (which, in itself, poses risks to Government and citizens). For example, Talent Cloud will be testing ways to give job applicant’s a higher level of agency over their own narrative, including open ended questions and the chance to provide a wider range of supporting evidence against a claim of skills made during an application process. This is in response to significant user testing and research on emerging trends in workers’ rights in the digital age. Anonymity is not an asset in a job search in an economy driven by platforms; but control over how one shares and owns one’s story and data is critical. Agency for applicants and applicant access to information are critical to all aspects of Talent Cloud’s design.
Any risks to privacy in the Talent Cloud model will always be undertaken with the team’s commitment to “do no harm”, which refers not only to protecting users, but also to causing no irreversible harm to the existing staffing system. Talent Cloud is committed to innovation that, if proved unsuccessful, can be taken apart again without any damage to individuals or to the government’s current operating procedures. Talent Cloud is committed to ensuring that no additional risks to privacy, discrimination or failure to secure employment are undertaken by Talent Cloud applicants, as compared against the baseline of the current Government of Canada staffing model.
Talent Cloud is working with the Treasury Board of Canada Secretariat’s (TBS) Information Technology (IT) Security and Cyber Security teams to mitigate risks associated with the platform and its server location. Wherever possible, Talent Cloud has taken additional steps, beyond minimum requirements, to increase security.
As an Agile project, any identified privacy risks that emerge during the course of the pilot testing can be immediately addressed by the Talent Cloud team. If they are minor in nature (such as wording, coding or protocol corrections), this can be immediately implemented. If any risks of a more significant nature emerge, the Talent Cloud team has the ability to shut down the Talent Cloud site until the necessary changes have been made.
Throughout, personal information and privacy will be handled respectfully and with due caution, with the goal of protecting not only individuals, but also citizens trust in the Government’s ability to handle data responsibly.
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