1. Directive on Conducting Privacy Impact Assessments

1.1 This directive takes effect on March 6, 2012.

2. Application

2.1 This directive applies to all divisions that manage statistical and non-statistical programs that involve the collection, use, or disclosure of personal information.

3. Legal Context

3.1 The purpose of the Privacy Act is to ensure the protection of the privacy of individuals with respect to personal information about themselves held by a government institution and the provision that individuals have a right of access to that information.

In support of the Privacy Act, a Privacy Impact Assessment (PIA) is an evaluation process which allows those involved in the collection, use or disclosure of personal information to assess and evaluate privacy, confidentiality or security risks associated with these activities, and to develop measures intended to mitigate or eliminate identified risks.

The Treasury Board of Canada Secretariat (TBS)'s Directive on Privacy Impact Assessment outlines the required steps for conducting PIAs.

4. Definitions

4.1 Definitions to be used to interpret this directive are in Appendix A.

5. Directive statement

5.1 Objective

5.1.1 Statistics Canada will develop and maintain a generic PIA to assess the privacy risks associated with a standard statistical program.

5.1.2 Statistics Canada will conduct a specific privacy impact assessment for all new and significantly redesigned collections, uses or disclosures of personal information that raise privacy, confidentiality or data security risks if a generic, or already existing, PIA does not adequately address the risks.

5.2 Expected results

5.2.1 A generic PIA provides an efficient mechanism to address standard risks associated with statistical programs.

5.2.2 By conducting a privacy impact assessment for all new and significantly redesigned collections, uses or disclosures of personal information that raise privacy, confidentiality or data security risks, Statistics Canada is performing due diligence in the protection of personal information as well as being compliant with the TBS Directive.

5.2.3 In cases where substantially similar collections, uses or disclosures of personal information occur in statistical programs, the generic Statistics Canada privacy impact assessment will apply so as to ensure compliance with the TBS Directive.

6. Requirements

Director, Information Management Division (IMD)

The Director, Information Management Division (IMD) has been delegated responsibility for ensuring compliance with the Treasury Board Secretariat Directive on Privacy Impact Assessment. The director has responsibility to direct privacy specialists in the division to:

6.1.1 Provide advice and assistance to program areas on the requirements of the TBS PIA Directive, PIA guidelines and related legislation.

6.1.2 Provide a copy of PIAs to TBS and the Office of the Privacy Commissioner (OPC) following the approval by the Chief Statistician.

6.1.3 Post a summary of every approved PIA on the Statistics Canada web site.

6.1.4 Assist other divisions in reviewing and updating PIAs that have been previously conducted, when and if required.

6.1.5 Develop and register personal information banks (PIB) with Treasury Board Secretariat and include them in the Statistics Canada chapter of Info Source if the PIA is for personal information not linked to a current PIB.

6.2 Senior managers (Directors and above)

In directing managers in a division, the director is responsible for:

6.2.1 Reviewing all new and significantly redesigned collections, uses and disclosures of personal information to determine whether the proposed program or system conforms to a generic or already existing PIA;

6.2.2 Developing, at an early stage in the planning process, a specific privacy impact assessment with support from the privacy specialists in Information Management Division, in cases where a generic PIA does not address all the risks related to privacy, confidentiality and security;

6.2.3 Inform the privacy officers in the Information Management Division of any new program or activity (or any substantial modification to an existing program or activity) where personal information is being collected or used. This will alert them to the possibility of the requirement for a new or modified PIA or PIB (personal information bank).

Note: Operational details related to privacy impact assessments are provided in Appendix B.

6.3 Director General, Informatics Branch

The Director General, Informatics Branch is responsible for directing staff to:

6.3.1. Assist in the conduct of the IT threat and risk assessment for specific PIAs, if required, and providing advice on mitigation measures related to IT security.

6.4 Assistant Chief Statisticians

As advisors to the Chief Statistician, Assistant Chief Statisticians:

6.4.1 Recommend the approval by the Chief Statistician of specific Privacy Impact Assessments conducted within their fields.

6.5 Chief Statistician

The Chief Statistician:

6.5.1 Approves the Statistics Canada generic Privacy Impact Assessment, including all modifications to it, and all specific Privacy Impact Assessments conducted in Statistics Canada.

6.6 Chief Audit Executive

As the officer responsible for the internal audit functions in Statistics Canada, the Chief Audit Executive:

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

7. Consequences

7.1 Consequences of non-compliance with this directive can include informal follow-up and requests from the Director, Information Management Division, internal audits or formal direction from Statistics Canada senior management on corrective measures.

7.2 Consequences of non-compliance with the TBS Directive on privacy impact assessment would be reflected in TBS's assessment of Statistics Canada under the Management Accountability Framework program.

8. References

8.1 Relevant legislation and regulations for this directive are as follows:

Statistics Act

Privacy Act

8.2 Related policy instruments and publications are as follows:

Policy on Government Security (Treasury Board Secretariat)

Policy on Privacy Protection (Treasury Board Secretariat)

Directive on Privacy Protection (Treasury Board Secretariat)

Directive on Privacy Impact Assessment (Treasury Board Secretariat)

Directive on Privacy Requests and Correction of Personal Information (Treasury Board Secretariat)

Directive on Social Insurance Number (Treasury Board Secretariat)

Directive on Information Management Roles and Responsibilities (Treasury Board Secretariat)

Policy on Privacy and Confidentiality (Statistics Canada)

Directive on Access to Information and Privacy (Statistics Canada)

Generic Privacy Impact Assessment for Statistics Canada Surveys (Statistics Canada)

9. Enquiries

Please direct enquiries about this directive to the Director of Information Management Division.

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Appendix A — Definitions

Privacy Impact Assessment (PIA) is a comprehensive process for determining the privacy, confidentiality and security risks associated with the collection, use or disclosure of personal information. It also defines the measures used to mitigate and, wherever possible, eliminate the identified risks. The PIA process ensures that measures intended to protect privacy and ensure the confidentiality and security of personal information are considered at the outset of any new program or service delivery initiative. A PIA also communicates to the public how their privacy is protected and how their information is kept confidential and secure from unauthorized access.

Privacy is the right to be left alone, to be free from interference, from surveillance and from intrusions. When choosing to "invade" a person's privacy, governments have obligations with respect to the collection, use, disclosure, and retention of personal information. Privacy generally refers to information about individual persons.

Confidentiality refers to a commitment not to release identifiable information about an individual (such as a person, business or organization). It implies a "trust" relationship between the supplier of the information and the organization collecting it; this relationship is built on the assurance that the information will not be disclosed without the individual's permission or without due legal authority.

Security is the arrangements organizations use to prevent confidential information from being obtained or disclosed inappropriately, based on assessed threats and risks. Security measures also protect the integrity, availability and value of the information assets. This includes both physical safeguards, such as restricted access to areas where the information is stored and used, and security clearances for employees, as well as technological safeguards to prevent unauthorized electronic access.

Personal Information, as defined by the federal Privacy Act (section 3), means information about an identifiable individual that is recorded in any form including age, date of birth, marital status, education, medical information, address, identifying number, symbol or other particular assigned only to that person.

Personal Information Bank is a description of personal information that is organized and retrievable by a person's name or by an identifying number, symbol or other particular assigned only to that person. The personal information described in the personal information bank is under the control of a government institution.

Appendix B — Procedures for conducting a privacy impact assessment

A privacy impact assessment (PIA) is an evaluation process that allows those responsible for the collection, use and disclosure of personal information to evaluate the privacy, confidentiality and security risks that may be involved and to develop mitigation measures aimed at avoiding or reducing the identified risks.

The Treasury Board Privacy Impact Assessment (PIA) Directive requires all federal government departments undertaking new or substantially redesigned programs that involve the collection, use or disclosure of personal information to complete a privacy impact assessment of the activity.

Because of the commonalities in procedures among surveys at Statistics Canada, the Generic Privacy Impact Assessment for Statistics Canada Surveys covers the majority of the Agency's household and business surveys, as well as the receipt and use of administrative information for statistical purposes. This generic PIA describes in detail how the Agency meets the ten privacy principles and includes a threat and risk assessment that focuses on the Agency's major data collection methodologies.

However, in cases where the generic PIA is deemed not applicable to a survey due to special or enhanced privacy risks, a specific privacy impact assessment must be produced. The specific PIA need only address risks not identified in the generic PIA.

According to the TBS PIA Directive, the collection, use and disclosure of personal information in the context of new or redesigned administrative programs and services—for example, human resources and marketing—may require that a privacy impact assessment be conducted.

The following are the procedures that both statistical and non-statistical program managers must follow.

Step 1. Determination of the need for a privacy impact assessment

A program area may contact a privacy specialist in Information Management Division to discuss the program, services or survey. If the Generic Privacy Impact Assessment for Statistics Canada Surveys is deemed to adequately address all known privacy risks, no further action is required. Alternatively an existing specific PIA may address all the known risks.

Step 2. When a privacy impact assessment is required

Using the Treasury Board template for a Core Privacy Impact Assessment, the program manager must complete a first draft of a PIA. This draft will be reviewed by a privacy specialist in Information Management Division. There will likely be various exchanges over the development period of the PIA.

Step 3. When a privacy impact assessment is finalized

Under the Treasury Board directive the head of institution is required to approve the final PIA. Therefore divisions are responsible for creating the memo from their Assistant Chief Statistician to the Chief Statistician requesting approval of the PIA.

Depending on the nature of the program covered by the PIA, the Chief Statistician may grant approval himself or, will decide that review and approval by Policy Committee is required.

Step 4. When a privacy impact assessment is approved

Information Management Division will arrange the following:

• Copies of the approved PIA are sent to Treasury Board and the Office of the Privacy Commissioner.
• A summary of the PIA is prepared and posted on the Statistics Canada web site.

Tourism and Centre for Education Statistics Division

This information is collected under the authority of the Statistics Act, Revised Statutes of Canada, 1985, Chapter S-19.

Although your participation in this survey is voluntary, your cooperation is important so that the information collected will be as accurate and complete as possible.

Purpose of the survey

This survey collects financial information (income and expenditures) on all universities and degree-granting colleges in Canada. Your information may also be used by Statistics Canada for other statistical and research purposes.

Confidentiality

Statistics Canada is prohibited by law from releasing any information it collects which could identify any person, business, or organization, unless consent has been given by the respondent or as permitted by the Statistics Act. Statistics Canada will use the information from this survey for statistical purposes.

Fax or e-mail transmission disclosure

Statistics Canada advises you that there could be risk of disclosure during the transmission of information by facsimile or e-mail. However, upon receipt, Statistics Canada will provide the guaranteed level of protection afforded all information collected under the authority of the Statistics Act. Note: There is no risk of disclosure if you are completing a web-based questionnaire online.

Record linkages

To enhance the data from this survey, Statistics Canada may combine it with information from other surveys or from administrative sources.

General information

• Name of University (or College)
• Address
  • Street
  • City
  • Province
  • Postal Code
• Fiscal year ending: Day Month Year
• Name and title of respondent
• Telephone
  • Area code
  • Number
  • Local
• Fax
  • Area code
  • Number
• E-mail address
• Name of Senior Administrative Officer (if different from above)

Instructions

1. Please read carefully the accompanying Guidelines.
2. All amounts should be expressed in thousands of dollars ($'000s).
3. In the "Observations and Comments" section, please explain financial data that may not be comparable with the prior year.
4. Please do not fill in shaded areas. All non-shaded cells should be completed.
   A nil entry should be indicated with a zero.

Reserved for Statistics Canada

• Full-time equivalent
• Report Status
• Institution Code: nceYYIII
• Comments

Table 1
Income by fund
Table summary
This is an empty data table used by respondents to provide data to Statistics Canada. This table contains no data.

Types of income	Funds
	General operating	Special purpose and trust	Sponsored research			Ancillary	Capital	Endowment	Total funds
			Entities consolidated	Entities not consolidated	Sub-total
	(thousands of dollars)
Government departments and agencies - grants and contracts
Federal
1. Social Sciences and Humanities Research Council
2. Health Canada
3. Natural Sciences and Engineering Research Council
4. Canadian Institutes of Health Research (CIHR)
5. Canada Foundation for Innovation (CFI)
6. Canada Research Chairs
7. Other federal
Other
8. Provincial
9. Municipal
10. Other provinces
11. Foreign
Tuition and other fees
12. Credit course tuition
13. Non-credit tuition
14. Other fees
Donations, including bequests
15. Individuals
16. Business enterprises
17. Not-for-profit organizations
Non-government grants and contracts
18. Individuals
19. Business enterprises
20. Not-for-profit organizations
Investment
21. Endowment
22. Other investment
Other
23. Sale of services and products
24. Miscellaneous
25. TotalNote 1
Note 1. The total for Sponsored research – Entities not consolidated must agree with the total for Sponsored research – Entities not consolidated in Table 2. Return to note 1 referrer

Observations and comments

• Description (Fund and type of income)
• Comments

Table 2
Expenditures by fund
Table summary
This is an empty data table used by respondents to provide data to Statistics Canada. This table contains no data.

Types of expenditures	Funds
	General operating	Special purpose and trust	Sponsored research			Ancillary	Capital	Endowment	Total funds
			Entities consolidated	Entities not consolidated	Sub-total
	(thousands of dollars)
Academic salaries
1. Academic ranks
2. Other instruction and research
3. Other salaries and wages
4. Benefits
5. Travel
6. Library acquisitions
7. Printing and duplicating
8. Materials and supplies
9. Communications
10. Other operational expenditures
11. Utilities
12. Renovations and alterations
13. Scholarships, bursaries and prizes
14. Externally contracted services
15. Professional fees
16. Cost of goods sold
17. Interest
18. Furniture and equipment purchase
19. Equipment rental and maintenance
20. Internal sales and cost recoveries
21. Sub-total
22. Buildings, land and land improvements
23. Lump sum payments
24. TotalNote 1
Note 1. The total for Sponsored research – Entities not consolidated must agree with the total for Sponsored research – Entities not consolidated in Table 1. Return to note 1 referrer

Observations and comments

• Description (Fund and type of expenditure)
• Comments

Table 4
General operating expenditures by function
Table summary
This is an empty data table used by respondents to provide data to Statistics Canada. This table contains no data.

Types of expenditures	Functions
	Instruction and non-sponsored research	Non-credit instruction	Library	Computing and communications	Administration and general	Student services	Physical plant	External Relations	Total functionsNote 1
	(thousands of dollars)
Academic salaries
1. Academic ranks
2. Other instruction and research
3. Other salaries and wages
4. Benefits
5. Travel
6. Library acquisitions
7. Printing and duplicating
8. Materials and supplies
9. Communications
10. Other operational expenditures
11. Utilities
12. Renovations and alterations
13. Scholarships, bursaries and prizes
14. Externally contracted services
15. Professional fees
16. Cost of goods sold
17. Interest
18. Furniture and equipment purchase
19. Equipment rental and maintenance
20. Internal sales and cost recoveries
21. Sub-total
22. Buildings, land and land improvements
23. Lump sum payments
24. Total
Note 1. The amounts in column Total functions should agree with the amounts in column General operating in Table 2. Return to note 1 referrer

Observations and comments

• Description (Function and type of expenditure)
• Comments

Purpose

To familiarize participants with benchmarking methods and software. Benchmarking deals with the problem of combining a series of high-frequency data (e.g., quarterly, or monthly data) with a series of less frequent data (e.g., annual data) for a certain variable into a consistent time series. Benchmarking techniques can also be used to solve interpolation, linking and bridging problems associated with time series.

Benefits to participants

Upon completion of the course, the participants will be able to understand some of the benchmarking techniques in use at Statistics Canada. They will have acquired the technical knowledge to solve benchmarking problems in SAS and in R, and to analyze the results. The course is technical and theoretical.

Target population

This course is intended for employees involved or interested in the production and analysis of benchmarked series or in the benchmarking process itself.

Course outline

The course examines

• Introduction and issues related to benchmarking.
• Benchmarking methods available in SAS and R: pro-rating; Denton; proportional Denton, a numerical version of the regression-based model and variants that directly compute the benchmarking adjustment factors.
• Timeliness issues with implicit and/or explicit forecasts and annual growth rates.
• Benchmarking stock variables and interpolation.
• Using benchmarking methods to solve bridging or linking problems.

Some knowledge of SAS or R will be useful, but not mandatory.

Other Related Courses

The course is specialized and requires basic statistical knowledge. The course STC0437 Theory and Application of Reconciliation is also available.

Delivery type: Virtual instructor-led

Duration: 3 half-days

Contact:
If you have questions or to register to the course, contact us at statcan.timeseriessupportsoutienenserieschronologiques.statcan@statcan.gc.ca.

Introduction

In 2006, the My Account feature was launched to provide visitors to the Statistics Canada website with the option to receive email notifications when products of interest are released. In 2014, My Account was updated and improved to ensure that it continues to meet the needs of its users, and was renamed My StatCan.

Objectives

A privacy impact assessment for My StatCan was conducted to determine if there were any privacy, confidentiality and security issues associated with the web application, and if so, to make recommendations for their resolution or mitigation.

Description

My StatCan includes the following key features: increased access to Statistics Canada information, a more efficient email notification system, and a one-stop registration for all online interactions with Statistics Canada, such as the Chat with an Expert, Question of the Month and StatCan Blog.

Participants are asked to provide a user name (alias) and their email address, which may be used to correspond with them if required, and indicate by checking a box whether they wish to participate in Statistics Canada's future consultations.

A username is a necessary component of the registration process because it allows registrants to log in to My StatCan and customize their home page. It also enables them to participate in Statistics Canada’s online discussion platforms such as Chat with an Expert. Participants are told explicitly that their username will be displayed in their My StatCan account, and alongside their questions or comments in the online discussion platforms.

All questions and comments posted will be subject to moderation to ensure that the rules of engagement are followed and that no personal information is disclosed.

Risk Area Identification and Categorization

The privacy impact assessment also identifies the risk areas and categorizes the level of potential risk (level 1 representing the lowest level of potential risk and level 4, the highest) associated with the collection and use of personal information through My StatCan.

Personal information of respondents:

• Type of program or activity – Level 1: Program or activity that does not involve a decision about an identifiable individual.
• Type of personal information involved and context – Level 1: Only personal information, with no contextual sensitivities, collected directly from the individual or provided with the consent of the individual for disclosure under an authorized program.
• Program or activity partners and private sector involvement – Level 1: Within the institution (among one or more programs within the same institution).
• Duration of the program or activity – Level 3: Long-term program or activity (ongoing).
• Program population – Level 3: The program's use of personal information for external administrative purposes affects certain individuals.
• Personal information transmission – Level 2: The personal information is used in a system that has connections to at least one other system.
• Technology and privacy: The platform will use the Drupal software, which has already been implemented for other Statistics Canada online products, including StatCan Blog and Question of the Month.
• Privacy breach: There is a very low risk of personal information being disclosed.

Conclusion

This assessment of My StatCan did not identify any privacy risks that cannot be managed using existing safeguards.