Privacy impact assessment
GCdocs is the Government of Canada’s solution for meeting the legal and policy requirements for information management of electronic and paper documents and records. It allows for the storage, search, retrieval and lifecycle management of information resources. Information from the existing Document Management Centre (DMC) systems will be migrated to GCdocs and the DMC will be de-commissioned.
A privacy impact assessment for GCdocs was conducted to determine if there were any privacy, confidentiality and security issues and, if so, to make recommendations for their resolution or mitigation.
GCdocs will store, manage and provide access to information created by programs. The information stored will include documents up to a security level of Protected B, with the exception of sensitive statistical information (SSI). No classified or Protected C documents will be stored in GCdocs.
Examples of the types of documents within GCdocs that may contain personal information include: travel claims, performance management reports, grievance packages, interview and reference check results, material relating to staffing processes (assessments, letters of offer), official languages complaints, incident and inspections reports, ergonomic assessments, parking permits management documents, contact information about participants in consultations, and public communications.
While GCdocs will be deployed to all Statistics Canada employees, access to personal information will be restricted to those who need the information for work-related duties. The groups and individuals who have access to specific folders containing personal information will be determined by the Office of Primary Responsibility (the director or director general responsible for the functions, sub-functions or activities for which the information is created).
Risk Area Identification and Categorization
The PIA 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 storage of personal information in GCDOCs.
- Type of program or activity – Level 2: Administration of program or activity and services.
- Type of personal information involved and context – Level 3: Social Insurance Number, medical, financial or other sensitive personal information or the context surrounding the personal information is sensitive; personal information of minors or of legally incompetent individuals or involving a representative acting on behalf of the individual.
- Program or activity partners and private sector involvement – Level 2: With other government institutions.
- Duration of the program or activity – Level 3: Long-term program or activity.
- Program population – Level 2: The program's use of personal information for internal administrative purposes affects all employees.
- Personal information transmission – Level 4: The personal information is transmitted using wireless technologies.
- Technology and privacy: GCdocs involves the implementation of a new application that will support programs and activities in the creation and management of personal information.
- Privacy breach: There is a very low risk of a breach of some of the personal information being disclosed without proper authorization.
This privacy impact assessment did not identify any privacy risks that cannot be managed using existing safeguards.