Privacy Impact Assessment for Talent Cloud
Talent Cloud is an experimental staffing platform that is attempting to respond to the challenges facing Canada’s public service in the digital age. These challenges include:
- a critical government-wide shortage of talent (particularly in the digital and technology professions)
- a lack of agility in the government’s current staffing model, which prevents the rapid formation of cross-sector teams to respond to government priorities
- ongoing issues of inclusion and diversity, with a focus on issues related to the retention, promotion and recognition of Indigenous talent
- costly inefficiencies in the current public service staffing model, leading to both suboptimal service outcomes for Canadians and a diminished value proposition for the public service as an employer (particularly with regard to high-demand skills and emerging fields)
- is testing a new process to recruit talent for project-based work in the Government of Canada
- is attempting to significantly reduce the time it takes to staff project-based (term) positions
- aims to create the world’s first public sector “gig” marketplace that is structured around worker rights for the next generation
In Phase 1 of Talent Cloud, the beta test phase, the project staffed roughly 20 term positions using externally advertised processes. During the Talent Cloud pilot, only funding-partner departments can staff using the Talent Cloud platform.
Talent Cloud completed an initial privacy impact assessment in fall 2018, which reflected the platform’s information collection and privacy considerations in its Protected A environment for the Phase 1 pilot. This assessment is an update to that initial privacy impact assessment, as the platform transitions to a Protected B environment in summer 2020. There are four key differences in the updated privacy impact assessment:
- New information is being collected, including:
- voluntary self-declarations of employment equity categories
- the recording of applicant assessment results (visible only to human resources and the hiring manager)
- work samples and credentials uploaded by applicants to demonstrate skills or training
- A new login system, which is a temporary solution that will be in place until the Government of Canada single sign-on login is available.
- New portals on the Talent Cloud platform and a portal upgrade: the Talent Cloud platform is a central database of information that is stored in the TBS cloud environment. Access to information in this database (creating, editing, viewing and removing information) is granted based on the needs of specific groups. Each group only has access to the information required to perform their duties as part of the applicant selection process.
- Upgrades to the Talent Cloud applicant assessment system, which are based on feedback from hiring managers and human resources advisors. The upgrades will allow managers to record whether each applicant meets or does not meet each selection criteria for each process that an applicant has applied to.
Talent Cloud is developed using agile software development principles that apply principles of human-centred design and business process engineering.Talent Cloud will expand its collection activities under this privacy impact assessment in summer 2020. The information being collected reflects findings from user-testing sessions on the staffing redesign conducted from 2017 to 2019, including feedback and results from the live platform, which was launched in October 2018. Talent Cloud will continue to improve the project based on input and feedback from users after the Talent Cloud platform and website go live. While the functionality of the site and the language may evolve, the critical details about information collection and storage provided in this document will be respected.
Why the Privacy Impact Assessment was necessary
Talent Cloud is a staffing platform that collects personal information. Given that Talent Cloud is a new staffing model, a privacy impact assessment 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
As part of its activities as a staffing platform, Talent Cloud will be expanding the collection of information during summer 2020 to include Protected B information. In the event of a privacy breach, the data collected 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 (for example, a LinkedIn profile).
In some cases, Talent Cloud will be deliberately taking risks, in that the team will be testing new ideas and approaches to staffing. These approaches are either not covered by current guidance or the current guidance is outdated. For example, Talent Cloud will be testing ways to give job applicants a higher level of agency over their own narrative, including the use of open-ended questions and the chance to provide a wider range of supporting evidence to demonstrate skills. These new ways are in response to significant user testing and research on emerging trends in worker rights in the digital age. Anonymity when job searching is not an asset in an economy that is driven by platforms; however, control over how one shares and owns one’s story and data is critical. Applicant agency and access to information are critical to all aspects of the design of Talent Cloud.
With regard to any risks to privacy, the Talent Cloud team is committed to “doing 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 without any damage to individuals or to the government’s current operating procedures. Talent Cloud is committed to ensuring that, when compared against the baseline of the current Government of Canada staffing model, applicants face no additional privacy risks, discrimination or difficulty in securing employment.
Talent Cloud is working with TBS information technology (IT), security and cybersecurity teams to mitigate risks associated with the platform and its server location. Where possible, Talent Cloud has taken additional steps, beyond minimum requirements, to increase security.
Since Talent Cloud is an agile project, any identified privacy risks that emerge during pilot testing can be immediately addressed by the Talent Cloud team. If the risks are minor in nature (such as wording, coding or protocol corrections), the necessary changes can be implemented immediately. If more significant risks emerge, the Talent Cloud team has the ability to shut down the Talent Cloud site until the necessary changes have been made.
Personal information and privacy will be handled respectfully, with due caution, and with the goal of protecting not only individuals, but also trust in the government’s ability to handle data responsibly.
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