Date and location
December 12, 2024, 9:30 a.m. to 12:00 p.m.
Hybrid meeting
Microsoft Teams
The Ivan P. Fellegi Conference Room, 26th floor, R.H. Coats Building
100 Tunney's Pasture Parkway, Ottawa
Members
- Chantal Bernier, Co-Chair, Global Privacy and Cybersecurity Group, Dentons Canada (Chair)
- André Loranger, Chief Statistician of Canada
- Len Garis, Researcher and Adjunct Professor, University of the Fraser Valley
- Ali Ghorbani, Cyber Security Chair, University of New Brunswick
- Robert Gordon, Executive Director, Canadian Cyber Threat Exchange
- David Robichaud, Ethics Professor, University of Ottawa
- Eran Tal, Canada Research Chair in Data Ethics, McGill University
Regrets
- Ali Ghorbani, Cyber Security Chair, University of New Brunswick
- Suzanne L. Morin, Vice President, Chief Privacy and Data Ethics Officer, Sun Life
Statistics Canada guests/support
- Antonio Bakopoulos
- Marie-Eve Bedard
- Josée Bégin
- Kathy Champagne
- Stéphane Dufour
- Tom Dufour
- Pierre Desrochers
- Rock Lemay
- Larry MacNabb
- Patrice Martineau
- Kathleen Mitchell
- Nicolas Rahal
- Eric Rancourt
Other guest
Jonathan MacDonald (Treasury Board of Canada Secretariat)
1. Introductions and Opening Remarks
André Loranger, Chief Statistician of Canada
Chantal Bernier, Co-chair, Global Privacy and Cybersecurity Group, Dentons Canada LLP
Mr. Loranger opened the meeting by welcoming members to the ninth meeting of the Advisory Council on Ethics and Modernization of Microdata Access and introducing the two new members of the Council: Eran Tal and Suzanne L. Morin.
Mr. Loranger then provided a brief update on Statistics Canada's current situation: the organization has just completed a conclusive series of tests in preparation for the 2026 Census of Population; the organization is preparing for the adoption of 2025 SNA (System of National Accounts); the organization is developing solutions to the decline in response rates; and the organization continues to implement its modernization plan, in particular to become more efficient.
Mrs. Bernier welcomed the Board members and underlined the quality of the meeting's agenda.
2. De-identification
Pierre Desrochers, Director, Office of Privacy Management and Information Coordination, Statistics Canada
Mr. Desrochers presented a summary of the progress made over the past few years and the main current issues in data de-identification. He also pointed out that Statistics Canada is working with the Treasury Board of Canada Secretariat (TBS) to provide whole-of-government de-identification guidelines that would be issued by TBS.
According to Mr. Desrochers, it is important to make a clear distinction between anonymized information and de-identified information. Ms. Bernier noted the issue of inconsistency in the use of the terms “de-identification” and “anonymization” in the privacy legislation, as well as the evolution towards regulating anonymization techniques or setting conditions for anonymization. The discussion proceeded with referring to "de-identification" as the replacement of identifiers with a code, maintaining traceability to the individual, and anonymization, as the destruction of identifiers in such a manner that information is no longer, irreversibly, traceable to the individual.
Council members were satisfied with the presentation and provided the following recommendations.
- As anonymization techniques may not be suitable as a statistical method and procedure, prioritize data de-identification techniques over anonymization techniques. Where necessary, specify on the Statistics Canada website the situations in which de-identification techniques are used versus anonymization techniques.
- Ensure that the techniques and methods used to de-identify and anonymize data are effective.
- Develop tools and methods to mitigate identification risks.
3. Data governance under the Statistics Act
Pierre Desrochers, Director, Office of Privacy Management and Information Coordination, Statistics Canada
Mr. Desrochers presented on emerging privacy laws in Canada and the perceived challenges for data sharing between Statistics Canada and provincial authorities. The Statistics Act gives Statistics Canada a broad mandate but may lack mechanisms for collaboration and implementation. Provincial powers in data sharing and differing legal frameworks may create perceived challenges.
Council members were pleased with the presentation, recommending that Statistics Canada examine how they could demonstrate leadership and play a more collaborative role in facilitating data exchange at the national level. The Council also emphasizes the importance of balancing privacy rights and the collective interest to ensure that any data access is appropriate by a clear public benefit, that the data is managed in a way that minimizes privacy risks, and that any potential harms are mitigated by strong and transparent safeguards.
4. Differentiated collection
Rock Lemay, Director-general, Collection and Regional Services, Statistics Canada
Mr. Lemay presented an overview of Statistics Canada's current differentiated data collection strategies. Mr. Lemay explained that one of his team's objectives is to collect data, using different ethical tools and mechanisms, to enable the production of quality disaggregated data that meets the needs of Canadians. According to Mr. Lemay, one of the main challenges is to get in touch with certain types of respondents, who are more difficult to reach for a variety of reasons.
For the last Census of Population, Statistics Canada developed an approach based on the development of collection strategies adapted to different respondent personas. The organization plans to use a similar strategy for other social surveys.
Statistics Canada must, however, ensure that it does not use too many personas, which would make its strategy less effective, and that it does not introduce bias. In response to a question from Council members, Mr. Lemay clarified that the organization uses the same standard personas for most of its programs, but that it also uses special personas for certain specific surveys.
Council members were satisfied with the presentation and supported Statistics Canada's approach to differentiated collection. The Council made the following recommendations.
- Properly document the differentiated collection methods used (e.g. issues identified, possible biases)
- Be transparent, by publishing strategies on the Statistics Canada website.
5. Roundtable and Closing Remarks
André Loranger, Chief Statistician of Canada
Chantal Bernier, Co-chair, Global Privacy and Cybersecurity Group, Dentons Canada
Mr. Loranger and Ms. Bernier thanked the Council members and participants for the excellent presentations and discussions. Both made a point of mentioning the quality and relevance of the topics covered at Council meetings.
Advisory council action items
Action Item
- Next meeting: Spring 2025.
Recommendations for Statistics Canada
- De-identification
- Prioritize data de-identification techniques over anonymization techniques. Where necessary, specify on the Statistics Canada website the situations in which de-identification techniques are used versus anonymization techniques.
- Ensure that the techniques and methods used to de-identify and anonymize data are effective.
- Develop tools and methods to mitigate identification risks.
- Data governance under the Statistics Act
- Play a leading role in the ethical sharing of data between different levels of government, while respecting existing legislation.
- Identify the barriers to sharing and effective ways of overcoming them.
- Differentiated collection
- Properly document the differentiated collection methods used (e.g. issues identified, possible biases)
- Be transparent, by publishing strategies on the Statistics Canada website.