Statistics Canada Policy on the Use of Administrative Data Obtained under the Statistics Act

Important notice

The Chief Statistician may grant exemptions from this governing instrument, unless otherwise required by Canadian law or Government of Canada policies.

1. Effective date

1.1. This policy takes effect on December 2, 2015.

2. Application

2.1. This policy applies to all statistical programs of Statistics Canada and to the divisions that support those programs.

2.2. For the purposes of this policy, "administrative data" is Information that is collected by other organizations and departments for their own purposes, and is sought, at the micro or aggregate level, by Statistics Canada in respect to the objects of the Statistics Act. It excludes data that do not pertain to the Canadian society, economy or environment. By definition, Statistics Canada's use of this information for statistical purposes is secondary to the objective of the original collector of the information. (A full definition of administrative data is provided in Appendix A.)

2.3. As this policy is broad in scope and has implications on all areas of statistical activities in Statistics Canada, its application should take into account other Statistics Canada and Government of Canada policies, directives, standards and guidelines as listed in Section 8 (References), as well as Statistics Canada's Principles for the Statistical Use of Administrative Data as stated in Appendix B.

3. Context

3.1. Section 3 of the Statistics Act describes the mandate of Statistics Canada, including "to promote the avoidance of duplication in the information collected by departments of government." The Statistics Act defines "departments of government" as "any department, board, bureau or other division of the Government of Canada or of the government of a province or any agency of either." In this document the term "province" is interpreted to also include the territories.

3.2. Section 13 of the Statistics Act details the authority under which the Chief Statistician, or a person authorized by the Chief Statistician, can obtain access to any documents or records maintained in any federal, provincial or territorial department or in any municipal office, corporation, business or organization, when the documents or records are required for the purposes of the Statistics Act.

Paragraph 3(e) of the Statistics Act further specifies that Statistics Canada's mandate includes the promotion and development of social and economic statistics pertaining to the whole of Canada and to each of the provinces. The application of Section 13 therefore excludes obtaining data that do not pertain to Canadian society, economy or environment.

In addition, Sections 24 through 29 of the Statistics Act provide for access to specified types of information, namely those related to income tax, excise tax, imports and exports, and criminal statistics. These sections provide additional specificity to support the authority described in Section 13. In this document, reference to Section 13 should be interpreted to also include these additional sections of the Statistics Act.

3.3. Statistics Canada's use of administrative data is, by definition, secondary to the original purpose(s) for which the information was collected. It must be limited to those uses permitted by the Statistics Act, as defined in Section 3 of the Statistics Act.

3.4. The confidentiality of administrative data relating to individual persons, businesses or organizations (referred to as identifiable administrative data) must be strictly maintained as required by Subsection 17(1) of the Statistics Act.

3.5. Subsection 17(2) of the Statistics Act allows the Chief Statistician to exercise his discretion for disclosure of certain identifiable information through an order. As permitted by the Act, Statistics Canada will generally provide access to such information when

  • the information is needed for statistical or analytical purposes, and
  • the information released does not disadvantage individual respondents of Statistics Canada and does not harm the relationship between the Agency and its respondents or the reputation of the Agency.

With respect to identifiable administrative data, paragraph 17(2) (a) of the Statistics Act permits disclosure of identifiable administrative data in the manner and to the extent agreed upon by the original collector thereof and the Chief Statistician. Further details can be found in the Directive on Discretionary Disclosure.

3.6. Section 32 of the Statistics Act provides for legal penalties should a person who has custody or charge of any documents or records that are maintained in an organization refuse or neglect to provide access to the administrative data requested by Statistics Canada.

3.7. Section 5 of the Statistics Act may be used to provide access to identifiable administrative data to researchers.  Such researchers are considered to be persons retained under contract to perform special services for the Minister pursuant to the Act and, for the purposes of the Act, they are deemed to be persons employed under the Act while performing those services and as such are subject to the same legal penalties as all employees of Statistics Canada.

3.8. In the case of access under Section 13 of the Act to records held by private sector sources, such as corporations, businesses or organizations, such access may result in a procurement of goods or services and therefore be subject to additional legal and policy requirements, including the Government of Canada Contracting Policy.

4. Definitions

Definitions to be used in the interpretation of this policy are in Appendix A.

5. Policy statement

5.1. Objective

The objective of this policy is to maximize the efficiency and effectiveness of the use of administrative data in Statistics Canada's statistical programs. Statistics Canada achieves this objective through a corporate strategy intended to influence, access, use, and manage the administrative data supplied to Statistics Canada, and to maintain public trust while doing so.

5.2. Expected results

  • Statistics Canada identifies, influences, and increasingly gains access to administrative data sources for statistical purposes.
  • Statistics Canada undertakes new or revised data collection activity only when it is satisfied that the statistical needs cannot be met effectively using administrative data.
  • Statistics Canada uses corporately-recognized quality assurance processes to assess the fitness for use of administrative data in its statistical programs.
  • The statistical use of administrative data results in an overall better balance among response burden, costs, data quality, and the relevance of statistical outputs for users.
  • Statistics Canada takes a collaborative approach to data providers and treats them consistently across statistical programs in regard to the application of the Statistics Act.
  • Statistics Canada does not enter into agreements that place undue restrictions on its statistical use of the data, unless an exemption has been granted by the Chief Statistician; in principle administrative data obtained under the Statistics Act is a corporate resource available to all statistical programs with a demonstrated need.
  • Statistics Canada appropriately documents the agreements with data providers.
  • Statistics Canada identifies an administrative data custodian for each administrative data source, to obtain and manage access to the data on behalf of Statistics Canada.
  • Statistics Canada documents all administrative data obtained for use in the statistical programs of Statistics Canada in a corporate inventory.
  • Statistics Canada provides researchers with equitable, timely and secure access to identifiable administrative data.
  • Statistics Canada communicates its statistical use of administrative data to stakeholders and the public in a proactive, coherent and transparent manner.
  • Statistics Canada assesses and reports on the data quality and methodology of statistical outputs that use administrative data.
  • Statistics Canada's use of administrative data complies with all relevant legislation and government policy, including but not limited to the Statistics Act, the Privacy Act, the Access to Information Act, the Income Tax Act, the  Government of Canada Policy on Privacy Protection and the Government of Canada Contracting Policy.

6. Policy requirements

6.1. Chief Statistician of Canada

As the official responsible for the administration and operation of Statistics Canada, the Chief Statistician:

  • Delegates the authority to obtain administrative data for use in Statistics Canada's statistical programs to managers at Statistics Canada; and
  • Grants exemptions from the requirements of this policy, unless otherwise required by Canadian law or Government of Canada policies.

6.2. Assistant Chief Statistician, Analytical Studies, Methodology and Statistical Infrastructure Field

As the senior official responsible for the administrative data program of Statistics Canada, the Assistant Chief Statistician, Analytical Studies, Methodology and Statistical Infrastructure Field, is responsible for:

  • Providing leadership for the efficient and effective use of administrative data in Statistics Canada's statistical programs;
  • Ensuring the responsible stewardship of administrative data acquired and used by Statistics Canada in its statistical programs;
  • Acting as the senior external representative of Statistics Canada on matters relating to the statistical use of administrative data, including liaising with Assistant Chief Statisticians who represent Statistics Canada at other senior-level external forums where administrative data may be discussed; and
  • Reporting to the Chief Statistician on Statistics Canada's activities related to the statistical use of administrative data.

6.3. Administrative Data Management Committee is responsible for:

  • Developing the Agency's strategy to improve and augment the use of administrative data for statistical purposes;
  • Reviewing the governance framework for the acquisition, management and use  of administrative data, including statutory provisions, policies, directives and Agency practices, and making recommendations for improvements to the Executive Management Board;
  • Reviewing administrative data initiatives and making recommendations that foster coherence and efficiency across the Agency;
  • Ensuring the identification of an administrative data custodian (typically Administrative Data Division) for administrative data that have a broad corporate use or that involve a complex acquisition process;
  • Signaling to the Chief Statistician arrangements to access administrative data that may place undue restrictions on the Agency's statistical use of the data; and
  • Creating an annual work plan and reporting on progress to the Executive Management Board.

6.4. Director, Administrative Data Division is responsible for:

  • Acquiring and acting as custodian for administrative data that typically have a broad corporate use or that involve a complex acquisition process, by entering into agreements with data providers on behalf of Statistics Canada, including but not limited to the administrative data obtained from the Canada Revenue Agency;
  • Supporting statistical programs at Statistics Canada in their acquisition and use of administrative data;
  • Ensuring that a corporate inventory of all administrative data obtained by Statistics Canada for its statistical programs is maintained and made available;
  • Ensuring that the core processing of administrative data that are of use to multiple statistical programs is carried out in a coordinated, central manner, and that these data are made available for further local processing and use in statistical programs;
  • Seeking opportunities to improve methods or processes for the statistical use of administrative data, including those related to the protection of confidentiality, and to promote them across Statistics Canada;
  • Supporting the Administrative Data Management Committee in the fulfillment of its responsibilities; and
  • Coordinating Statistics Canada's participation in interdepartmental, intergovernmental and international administrative data initiatives, in collaboration with other divisions of Statistics Canada.

6.5. Senior managers (Assistant Chief Statisticians, Directors General and Directors) of statistical programs and of programs that provide support to statistical programs are responsible, with support from their employees, for:

  • Identifying opportunities for the use of administrative data in their statistical programs;
  • Reviewing the potential use of administrative data in their programs before approving any new or substantially revised data collection activity, taking into consideration the balance between response burden, costs, data quality and the relevance of statistical outputs for users;
  • Obtaining administrative data needed for their programs from the designated administrative data custodian (Administrative Data Division or other administrative data custodian within Statistics Canada) or, where no custodian exists, directly from the data provider when, after consultation with Administrative Data Division and as described in the Directive in Obtaining Administrative Data under the Statistics Act, they are identified as the administrative data custodian;
  • Serving as an administrative data custodian, as described in the Directive in Obtaining Administrative Data under the Statistics Act, including:
    • Acting as the single point of contact between Statistics Canada and the data provider(s) for all matters related to the administrative data source(s) for which they are the custodian;
    • Bringing situations where the data provider wishes to impose restrictions on Statistics Canada's statistical use of the data, including restrictions on access to identifiable administrative data  by deemed employees, to the attention of the Administrative Data Management Committee and, where appropriate,  of the Microdata Access Management Committee;
    • Documenting the arrangements to obtain the administrative data sources for which they are the custodian in an agreement with the data provider;
    • Complying with the Financial Administration Act when administrative data are obtained at a cost;
    • Registering all administrative data sources for which they are the custodian in the corporate inventory of administrative data;
    • Authorizing  other employees of Statistics Canada (including deemed employees) to access identifiable administrative data for which they are the custodian, based on the need-to-know principle and respecting any requirements included in agreements with the data providers; and
    • Managing and ensuring the protection of administrative data files for which they are the custodian, in accordance with all relevant legislation, policies and procedures, including those requirements included in the agreements with data providers;
  • Assessing the fitness for use of administrative data in their statistical programs, using corporately-recognized quality assurance processes;
  • Collaborating proactively with data providers to improve the relevance and quality of administrative data holdings for statistical use and for the benefit of data providers;
  • Processing and using the administrative data in their statistical programs, including the dissemination of statistical outputs that incorporate administrative data and the assessment and reporting on data quality and methodology, as required by the Policy on Informing Users of Data Quality and Methodology; and
  • Ensuring the confidentiality of statistical outputs that are based on administrative data.

6.6. Director, Information Management Division is responsible for:

  • Providing information, advice and services for the interpretation and implementation of the Statistics Act, other relevant legislation (e.g., Access to Information Act, Privacy Act), and policy instrument provisions relating to administrative data, including but not limited to coordination of legal advice with the Department of Justice, delegations of authority, agreements with data providers, confidentiality, privacy impact assessments,  discretionary disclosure, data sharing, record linkage, and information management; and
  • Developing data acquisition agreements with data providers that respect the Statistics Act and other legal requirements.

6.7. Director, Microdata Access Division is responsible for:

  • Providing governance for all aspects of requests for deemed employees to access identifiable administrative data in Statistics Canada's premises, including headquarters, regional offices, and at Research Data Centres or their equivalents, as described in the Directive on the Use of Deemed Employees.

6.8. Director General, Methodology Branch is responsible for:

  • Developing corporate-wide quality assurance practices to assist statistical programs in assessing the fitness for use of administrative data in statistical programs; and
  • Providing methodological advice and services to statistical programs and Administrative Data Division for the statistical use of administrative data, including quality assessment, data processing, the protection of confidentiality, and reporting on the data quality and methodology of statistical outputs that employ administrative data.

6.9. Director General, Informatics Branch is responsible for:

  • Developing or coordinating with other parties such as Shared Services Canada the development of corporate-wide informatics frameworks and solutions for the acquisition, use and management of administrative data sources for statistical purposes; and
  • Providing technical advice and services to statistical programs and to Administrative Data Division for the acquisition and processing of administrative data, including advice on technical requirements to be included in agreements with data providers.

6.10. Director General, Communications Division is responsible for:

  • Developing and implementing a corporate approach to the communication of Statistics Canada's use and protection of administrative data in a proactive, coherent and transparent manner, to ensure ongoing stakeholder and public support; and
  • Providing information, advice and services to statistical programs and to Administrative Data Division on communications issues relevant to the statistical use of administrative data.

6.11. Director, Corporate Support Services Division is responsible for:

  • Providing information, advice and services relating to the procurement of administrative data from private sector sources where payment is involved; and
  • Developing contracts with private sector data providers where payment is involved that respect legal requirements and the Government of Canada Contracting Policy.

6.12. Chief Audit Executive

As the official responsible for the internal audit functions of Statistics Canada, the Chief Audit Executive:

  • Assures, on a regular and ongoing basis, compliance with this policy through risk-based compliance audits.

7. Consequences of Non-compliance

Consequences of non-compliance can include informal follow-up and requests from the Director of Administrative Data Division, internal audits or formal direction from Statistics Canada senior management on corrective measures.

8. References

The following list includes the main documents that are relevant, but it should not be considered exhaustive. Depending on individual circumstances, other governance may apply.

8.1. Relevant legislation

  • Statistics Act
  • Privacy Act
  • Access to Information Act
  • Personal Information Protection and Electronic Documents Act (PIPEDA)
  • Income Tax Act
  • Excise Tax Act
  • Customs Act
  • Library and Archives Act
  • Financial Administration Act

8.2. Related Treasury Board Secretariat policies and other governance

  • Contracting Policy
  • Policy on Privacy Protection
  • Policy on Information Management
  • Directive on Recordkeeping

8.3. Related Statistics Canada policies and other governance

Policies on:

  • Information Management
  • Informing Users of Data Quality and Methodology
  • Microdata Access
  • Privacy and Confidentiality

Directives on:

  • Conducting Privacy Impact Assessments
  • Data Sharing under Sections 11 and 12
  • Discretionary Disclosure
  • Informing Survey Respondents
  • Management of Statistical Microdata Files
  • Management of Aggregate Statistics
  • Obtaining Administrative Data under the Statistics Act
  • Prescription for Data Collection
  • Record Linkage
  • Security of Sensitive Statistical Information
  • Use of Deemed Employees

Other governance:

  • Corporate Management Framework
  • Quality Assurance Framework (2002)
  • Quality Guidelines, Fifth Edition (2009)
  • Guidelines for the management of statistical microdata files and aggregate statistics

9. Enquiries

Please direct enquiries about this policy to the Director, Administrative Data Division.

Appendix A: Definitions

Administrative Data: Information that is collected by other organizations and departments for their own purposes, and is sought, at the micro or aggregate level, by Statistics Canada in respect to the objects of the Statistics Act. It excludes data that do not pertain to Canadian society, economy or environment. By definition, Statistics Canada's use of this information for statistical purposes is secondary to the objective of the original collector of the information. Administrative data include the traditional sources, for example, various data sets received from the Canada Revenue Agency, and also alternative sources, such as data obtained from surveys conducted by others without Statistics Canada's involvement and data generated by electronic devices (e.g., satellites, sensors, scanners, mobile phones) that are gathered by other organizations. Exclusions: Administrative data should not be confused with products that may be obtained from other organizations such as publications, reports, guides, metadata and computer programs. They also exclude data or information that is available to the public, including on the Internet, or data that can be obtained, under licence or not, by anyone, with or without a fee.

Administrative Data Custodian:  At Statistics Canada, the data custodian is the person who has been given the responsibility to obtain and manage the access to the administrative data on behalf of Statistics Canada.

Agreement: The documentation of the terms and conditions related to the acquisition, management, use and disposal of administrative data obtained from another organization by Statistics Canada. It may take the form of a data acquisition agreement, written communications or a contract.

Contract: The document that contains financial arrangements related to obtaining administrative data from private sector organizations when Statistics Canada pays costs.

Data Acquisition Agreement: A document describing terms and conditions agreed to by Statistics Canada and one or more other organizations. To be in force, the data acquisition agreement must be signed by authorized managers of each of the participating organizations. It is one of the three acceptable approaches to documenting an agreement that enables Statistics Canada to obtain administrative data from other organizations.

The data acquisition agreement takes the form of a:

  • memorandum of understanding with federal departments and agencies
  • agreement with provincial, territorial or municipal organizations
  • agreement with private sector organizations, when there are no costs to Statistics Canada.

Data Provider: A department of government (including those of the provinces or territories), a municipal office, a corporation, a business or an organization that has custody of administrative data and provides them to Statistics Canada for the purposes of the Statistics Act. A provider of administrative data under Section 13 of the Statistics Act cannot be an individual.

Identifiable Administrative Data: Administrative data that could directly or indirectly identify an individual person, business or organization. This includes both microdata and aggregated data at a confidential level.

Influence: The process of working collaboratively with data providers to improve the relevance and quality of administrative data holdings for statistical purposes and for the benefit of data providers. Aspects of administrative data holdings that might be influenced include, but are not limited to, the variables collected, the concepts and definitions used, the quality assurance processes applied during collection and processing, the frequency and timeliness with which data are collected, processed and supplied to Statistics Canada, and the quality of metadata available. The process is grounded in the mandate given to Statistics Canada under Section 3 of the Statistics Act, applied in an open, non-threatening and cooperative manner.

Appendix B: Statistics Canada's Principles for the Statistical Use of Administrative Data

  1. To reduce the duplication of information collected from Canadians, and in accordance with the United Nations Fundamental Principles of Official Statistics and the Recommendation of the Council on Good Statistical Practice of the Organisation for Economic Co-operation and Development, Statistics Canada makes use of administrative data in the production of official statistics.
  2. The statistical uses of administrative data are kept functionally separate from the administrative uses of such data through strong legal, policy and organizational safeguards. In particular, the confidentiality of all identifiable administrative data obtained by Statistics Canada for statistical purposes is protected by the Statistics Act and the data are only accessed within Statistics Canada based on demonstrated needs.
  3. In collaboration with data providers, Statistics Canada uses its mandate under the Statistics Act to access administrative data for statistical purposes, and to influence the information collected by departments of government (including the provinces and territories), in order to enhance the usefulness of administrative data for statistical purposes and reduce duplication.
  4. Statistics Canada's objective in using administrative data for statistical purposes is to achieve a better overall balance among cost, respondent burden and data quality, where quality refers to the relevance, accuracy, timeliness, accessibility, interpretability, and coherence of statistical outputs.
  5. Administrative data are used for many different statistical purposes: replacing or complementing direct data collection to reduce costs and respondent burden; achieving efficiencies in statistical operations, such as the creation of survey frames, design of survey samples, imputation, estimation, and the measurement of the quality of other data; and developing and providing access to new data products (tabular or analytical), such as by integrating administrative data with other data.
  6. Statistics Canada carefully considers the impact on privacy in using identifiable administrative data for a purpose that was not envisaged at the time of original data collection, particularly when administrative data are to be linked to other data.
  7. Statistics Canada considers the possibility of using administrative data already available before undertaking new data collection activity.
  8. Statistics Canada establishes and maintains ongoing, mutually beneficial relationships with data providers, both to ensure the long-term supply, usefulness and quality of administrative data, and to identify and influence future changes to administrative data sources that may affect statistical uses.
  9. Statistics Canada assesses the fitness for use of administrative data sources and, in collaboration with data providers, identifies ways to improve the quality of the administrative data. In particular, the processes for collecting and producing the administrative data within the data provider's organization and the effects on the proposed statistical use must be well understood, and the quality of the administrative data must be documented.
  10. Statistics Canada is transparent in its use of administrative data. It communicates the benefits of reduced respondent burden from using data already collected as well as the measures taken to protect the confidentiality of the data.
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