Supplement to Statistics Canada’s Generic Privacy Impact Assessment related to the Canadian Human Trafficking Hotline Feasibility Study Data Acquisition Project

Date: August 2021

Program managers: Director, Canadian Centre for Justice and Community Safety Statistics
Director General, Health, Justice, Diversity and Populations Branch

Reference to Personal Information Bank (PIB)

Not applicable as there are no direct personal identifiers being collected.

Description of statistical activity

Trafficking in persons, also known as human trafficking, involves recruiting, transporting, transferring, receiving, holding, concealing or harbouring a person, or exercising control, direction or influence over the movements of a person, for the purpose of exploiting them or facilitating their exploitation. There are various forms of human trafficking, including trafficking for forced labour, for the purpose of exploitative begging or for organ removal; however, trafficking for sexual exploitation is the most detected.

Information currently available about human trafficking in Canada is limited. As part of the National Strategy to Combat Human Trafficking, Statistics Canada is working with federal, provincial and territorial governments to examine the feasibility of using administrative data on human trafficking to supplement current statistics. A key component of the National Strategy is the need to enhance data collection and research “to help better understand the nature, prevalence and scope of human trafficking, close data gaps, and help inform policy and programs that help victims and survivors” (National Strategy to Combat Human Trafficking 2019 - 2024). As part of these discussions, the Canadian Centre for Justice and Community Safety Statistics (CCJCSS) at Statistics Canada has been working with the Canadian Centre to End Human Trafficking (CCTEHT) to acquire and examine administrative data related to their operation of the Canadian Human Trafficking Hotline.

The CCTEHT hotline receives calls related to human trafficking that may or may not be reported to police. Data requested include information on the characteristics of human trafficking incidents and victims, such as the age, gender, immigration status and/or ethnicity of victims, the type of trafficking (e.g., sexual exploitation or forced labour), and other relevant characteristics of trafficking such as high level geographic information and industry (in case of labour trafficking).

This feasibility study seeks to address a number of important questions about human trafficking in Canada. Statistics Canada will evaluate the information from the hotline and, if feasible, publish aggregate tables to complement information from police-reported data. Beyond providing a more expanded measure of the number of human trafficking victims, this initiative aims to use data from the CCTEHT to help to answer broader questions on the characteristics of these victims, information on recruitment characteristics and other relevant characteristics of trafficking. Having these data presented alongside official police-reported statistics will be useful to policy makers, researchers and the justice community in supporting evidence-based decision-making on policy and programmatic efforts to effectively prevent and respond to human trafficking in Canada.

No information identifying individuals will be requested and, as such, analysis of the data will not involve linkages between the hotline data and other data sources. Moreover, Statistics Canada will not publish any information that could potentially identify an individual based on the characteristics of victims or location of incidents. The type of information to be requested is noted above.

Reason for supplement

While the Generic Privacy Impact Assessment (PIA) addresses most of the privacy and security risks related to statistical activities conducted by Statistics Canada, this supplement is being carried out due to the sensitive nature of the data collected by the CCTEHT. As is the case with all PIAs, Statistics Canada’s privacy framework ensures that elements of privacy protection and privacy controls are documented and applied.

This supplement also presents an analysis of the necessity and proportionality of acquiring this sensitive information.

Necessity and Proportionality

The acquisition of administrative data for the Canadian Human Trafficking Hotline Feasibility Study Data Acquisition Project can be justified against Statistics Canada’s Necessity and Proportionality Framework:

  1. Necessity: Rates of police-reported human trafficking in Canada have increased considerably over the past decade and Canada has continued its efforts to combat this crime. Most notably, in 2019, as part of the National Strategy to Combat Human Trafficking, the Canadian Human Trafficking Hotline was launched to help victims and survivors of all forms of human trafficking access services and the supports they need. Data collected through the hotline will help in identifying vulnerable populations, gaps in services for victims and survivors, as well as assist in developing better law enforcement programs to target human trafficking.

    Published human trafficking statistics from the Canadian Centre for Justice and Community Safety Statistics at Statistics Canada are based on data from the Uniform Crime Reporting (UCR) Survey which include only incidents that have been detected and reported to the police. The CCTEHT hotline data provide an important data set that may offer additional insight into the nature and extent of human trafficking in Canada by providing information on contacts received from across Canada that may not be reported to police.

    The hotline data have information about human trafficking victims and incidents that is not collected by the UCR. In particular, the hotline data may provide information not currently available on the type of human trafficking (e.g., sexual exploitation, labour trafficking, immigration status of victims, or industries where human trafficking is more likely to take place). By yielding more granular data, this initiative will support the ability of the National Strategy to combat human trafficking through a victim-centered, survivor-informed and gender-responsive lens. This may help with understanding human trafficking victimization among particularly vulnerable populations, such as minors or foreign workers, who may be more readily exploitable. As noted above, no information that directly identifies individuals, such as names or telephone numbers, will be requested.

  2. Effectiveness (Working assumptions): As this project is still in a feasibility stage, detailed information on the data to be acquired is not yet final. Data requested will be limited to a subset of information from the CCTEHT hotline database that has the potential to address statistical information needs, based on discussion with the data provider. This would include variables on age, gender, and immigration status and/or ethnicity, the type of trafficking (e.g., sexual exploitation, forced labour), and other relevant characteristics of trafficking including high level geographic information and industry (in case of labour trafficking), etc. This information will be valuable in identifying populations that are at particular risk. No personal identifiers will be requested. It should be noted that the CCTEHT hotline provides a statement about its confidentiality policy and only collects information provided voluntarily by callers and does not prompt them for additional information.

    A full evaluation of the quality of these data will be carried out to determine what information can be published. In light of this evaluative pilot work, Statistics Canada will work closely with the CCTEHT to assist in the ongoing development of the hotline database.

    Ongoing frequency of data acquisition will be determined by the feasibility study, but is expected to be annual.

  3. Proportionality: The information collected by the CCTEHT hotline is by its nature very sensitive information. At the same time, however, this information plays an important role in the development of evidence-based approaches to ending human trafficking. As such, part of the mandate of the Canadian Centre to End Human Trafficking which operates the hotline is to use these data to contribute to research and statistics on the nature of human trafficking in Canada. In this context, and as part of their funding agreement, the CCTEHT is required to collect data on human trafficking and to enter into a data sharing agreement with Statistics Canada. As a complement to official police-reported statistics, analysis of information from the hotline may be used to determine vulnerable populations, gaps in services for victims and survivors, as well as to assist in developing evidence-informed public policy that prevents trafficking, supports victims, and deters traffickers. This project has been developed over a number of years in consultation with a variety of stakeholders. Moreover, as part of this ongoing work, the development of the CCTEHT hotline itself involved a broad consultation with stakeholders, including victims. Key stakeholders for this project include the National Action Plan to End Gender based violence, the National Strategy to Combat Human Trafficking and the 2021 Missing and Murdered Indigenous Women, Girls, and 2SLGBTQQIA+ People National Action Plan.

    Similar hotline data collection on human trafficking has been successfully implemented by the Polaris Project in the United States, which has been working in global jurisdictions to support the collection of human trafficking statistics, including providing guidance and advice to the CCTEHT. This acquisition is part of a feasibility study to determine the value and quality of the CCTEHT hotline data to produce statistics on human trafficking by Statistics Canada, within the Canadian context.

    No information that directly identifies a victim or caller will be requested (e.g. name or contact information). Furthermore, the data that are being requested from the hotline are being collected under the Statistics Act and, as part of Statistics Canada’s mandate, guaranteeing the security of that information is a top priority. Based on confidentiality guidelines, only aggregate non-confidential data are released outside of Statistics Canada. More information on how the data is protected is provided in the “Mitigation factors” section below.

    At this point in time, the acquisition of data from the CCTEHT is part of a feasibility study to determine the quality and value of the CCTEHT information to address current data gaps with respect to human trafficking. As the CCTEHT hotline is relatively new and the database is still in development, this work will also consider the fact that data quality and the usability of various indicators is expected to improve over time.

    The benefits of the findings, which are expected to support decision making at all levels of government aimed at improving mental health and well-being are believed to be proportional to the potential risks to privacy.

  4. Alternatives: Statistics Canada and the justice community have long recognized the need for improved information related to human trafficking. Ongoing work has been done to identify additional sources of information to complement police-reported data from the UCR. A consultation in 2020 with government departments identified no comprehensive government data sources on human trafficking victims and incidents that could complement existing information. The work with the CCTEHT is therefore, to date, the only alternative source of information identified that has sufficient coverage and the relevant information to potentially address this data gap.

Mitigation factors

Statistics Canada recognizes that the data collected by the Canadian Human Trafficking Hotline are by their very nature sensitive as human trafficking involves the coercion and control of victims, can involve sexual exploitation, and may involve organized criminal networks. Often, this can result in contacts to the hotline not wanting their whereabouts or other characteristics known. The confidentiality of information collected by the CCTEHT hotline will be protected by various processes. Also, it should be noted that the CCTEHT has featured and referenced its own privacy policy on its website. The hotline also has specific procedures in place to seek consent from callers and to inform why and how their information will be used. In addition, Statistics Canada will not be requesting any personal identifiers such as name or contact information of callers or victims under this data acquisition. Moreover, Statistics Canada will not publish any information that could potentially identify an individual based on the characteristics of victims or location of incidents. As such, the overall risk of harm has been deemed manageable with existing Statistics Canada safeguards that are described in Statistics Canada’s Generic Privacy Impact Assessment.

Under the Statistics Act, Statistics Canada's use of records obtained from the CCTEHT is limited to statistical purposes only. By law, Statistics Canada is prohibited from disclosing personal information collected under the authority of the Statistics Act for any administrative or decision-making purposes related to any specific individual– not to the police, the Royal Canadian Mounted Police (RCMP), the Canada Border Services Agency (CBSA) or even the courts.

The focus of this project is currently to determine the feasibility of producing published information on human trafficking based on the CCTEHT data. Only information that meets minimum data quality standards will be published, along with data quality indicators. The CCTEHT will be involved in the review of any published documents.

Conclusion

This assessment concludes that, with the existing Statistics Canada safeguards, any remaining risks are such that Statistics Canada is prepared to accept and manage the risk.

Formal approval

This Supplementary Privacy Impact Assessment has been reviewed and recommended for approval by Statistics Canada’s Chief Privacy Officer, Director General for Modern Statistical Methods and Data Science, and Assistant Chief Statistician for Social, Health and Labour Statistics.

The Chief Statistician of Canada has the authority for section 10 of the Privacy Act for Statistics Canada, and is responsible for the Agency's operations, including the program area mentioned in this Supplementary Privacy Impact Assessment.

This Privacy Impact Assessment has been approved by the Chief Statistician of Canada.

Pierre Desrochers
Chief Privacy Officer
September 23, 2021

Eric Rancourt
Director General
Modern Statistical Methods and Data Science
October 6, 2021

Lynn Barr Telford
Assistant Chief Statistician
Social, Health and Labour Statistics
October 12, 2021

Anil Arora
Chief Statistician of Canada

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