Supplement to Statistics Canada's Generic Privacy Impact Assessment related to the Narcotics, Substance Use, and Community Well-Being Initiative
Program managers: Assistant Director, Centre for Social Data Insights and Innovation
Director, Centre for Social Data Insights and Innovation
Director General, Census Subject Matter, Social Insights, Integration and Innovation
Reference to Personal Information Bank (PIB)
In accordance with the Privacy Act, Statistics Canada is developing a new institutional personal information bank (PIB) to describe any personal information obtained from provincial and/or municipal paramedics and police services, health and long-term care agencies, as well as existing narcotics registries, for the purposes of the Statistics Act. The following PIB is proposed for review and registration.
Narcotics, Substance Use, and Community Well-Being Initiative
Description: This bank describes information that is obtained from municipal, provincial, and/or federal police services, paramedic services, and health and long-term care agencies, on the topic of individuals who have experienced problematic substance use or a suspected overdose related to opioids, crystal methamphetamines and other forms of narcotics. Personal information may include: first name, last name, date of birth, age, sex, civic address, postal code, telephone number and provincial health number; and, information related to the suspected over-dose incident including whether the individual was criminally charged, the history of police contacts of individuals identified, treatment received, health care billing information, health care services received and dispensing information for all monitored drugs dispensed.
Class of Individuals: Individuals (including minors) who experienced problematic substance use or a suspected drug overdose from 2015 to the present, as identified by police services, paramedic services, and health and long-term care agencies.
Purpose: The personal information is used to produce analytical data that will highlight primary risk factors and increase understanding of the population most at-risk of a drug overdose. These results will assist frontline workers and policy and programs makers in the health, justice and employment sectors in identifying potential multi-sectoral interventions. Personal information is collected pursuant to the Statistics Act (Sections 3, 7, 8, 13).
Consistent Uses: The information is used for statistical and research purposes only. Subject to Statistics Canada's Directive on Microdata Linkage, the collected data for this Initiative may be combined with surveys or administrative data sources described in this chapter, including but not limited to the Canadian Coroners and Medical Examiner Information (StatCan PPU 809), T1 Family File (StatCan PPU 111), Census of Population and National Household Survey (StatCan PPU 005) and health data. The identifiable information is required only for the purpose of record linkage to produce more robust analytical output. A research file containing individual records, with no names or other direct identifiers, may be shared with the organisations participating in the Narcotics, Substance Use, and Community Well-Being Initiative under a discretionary disclosure order with the authorization of the data provider for statistical and research purposes, as permitted by the provisions of Subsection 17(2) of the Statistics Act.
Retention and Disposal Standards: Information is retained until it is no longer required for statistical purposes and then it is destroyed.
RDA Number: 2007/001
Related Record Number: StatCan SSD 040
TBS Registration: To be assigned by TBS
Bank Number: StatCan PPU 814
Description of statistical activity
The Narcotics, Substance Use, and Community Well-Being Initiative (hereinafter referred to as "the Initiative"), is a series of projects where Statistics Canada will be collecting data pertaining to individuals (including minors) who experienced suspected drug overdoses, to produce analytical data that will help provide insight on primary risk factors and increase understanding of those most at-risk of a drug overdose and problematic substance use. Each project under the Initiative will be conducted with a focus on a different municipality, region, province/territory or the country as a whole and will be determined in collaboration with key stakeholders from all levels of government (municipal, provincial and federal). A pilot project was conducted in 2017 in collaboration with the City of Surrey in British Columbia. That pilot project provided high quality and relevant data on the opioid crisis in the City of Surrey, which were used by front line responders and policy makers to inform drug policies and programs used to save Canadian lives. The success of the pilot project has led to the development of the Narcotics, Substance Use, and Community Well-Being Initiative that will provide the necessary data on narcotics and other substances to assist frontline workers and policy and program makers in better identifying, understanding and serving persons most at-risk in various municipalities across the country.
To gather the data needed for this Initiative, Statistics Canada will be collecting administrative data from provincial and/or municipal paramedics and police services, health and long-term care agencies, as well as existing narcotics registries pertaining to individuals who have experienced a suspected overdose related to opioids, crystal methamphetamines and other forms of narcotics which have been identified as having a significant detrimental effect on Canadians and communities across the country. Using the acquired data, a study cohort of individuals who experienced a suspected drug overdose will be created to provide meaningful insights regarding those at greatest risk of an overdose. The data being requested include personal identifiers of overdose victims for the purpose of record linkage and analysis. The personal identifiers include: first name, last name, date of birth, age, sex, civic address, postal code, telephone number and provincial health number.
The requested data will be linked to other administrative data available at Statistics Canada, including coroners' data, tax, census and health data. The resulting analytical data generated from this Initiative will assist frontline workers and policy and programs makers in the health, justice and employment sectors in identifying potential multi-sectoral interventions by informing evidence-based decision-making and effective policy review. The ability to link information on the same individual across various services (including the Criminal Justice System) is integral to better identifying, understanding and serving persons most at-risk. All information collected will be used for statistical purposes only.
Reason for supplement
While Statistics Canada's Generic Privacy Impact Assessment addresses most of the privacy and security risks related to statistical activities conducted by Statistics Canada, this supplement details the necessity and proportionality and the mitigation factors related to this Initiative due to the sensitivity of the information.
Necessity and Proportionality
The collection and use of personal information for the Narcotics, Substance Abuse and Community Well-Being Initiative can be justified using the four-part test proposed by the Office of the Privacy Commissioner of Canada:
Necessity: The information generated from these projects will serve to fill data gaps by adding to the body of knowledge surrounding the social determinants of emerging drug use issues such as the opioid crisis. The Initiative responds to requests from communities interested in obtaining detailed data and analysis on narcotics in their communities, on a cost recovery basis. The data from various external databases are integral for this Initiative as Statistics Canada currently only has access to the National Ambulatory Care Reporting System (NACRS) and Discharge Abstract Database (DAD). Both of these databases are important data sources, however they do not provide the level of detail required for the purposes of the Initiative. For example, in the DAD and NACRS, crystal methamphetamines are included as part of a larger group of stimulants, however detailed information about crystal methamphetamines specifically is not provided.
These data will help highlight primary risk factors and increase understanding of those most at-risk of drug overdose, which contributes to the ability to identify and act on opportunities for intervention in the community. The integration of these data and the indicators generated by these projects will allow front line responders and policy makers to better tailor policies and programs aimed at saving lives and preventing fatal overdoses.
Effectiveness: The collected data will be linked to other Statistics Canada databases such as coroners' data, tax, Census and health data. This integrated data will result in high quality, timely and relevant aggregated analytical outputs. These outputs will assist the health, justice and employment sectors in identifying potential multi-sectoral interventions by informing evidence-based decision-making and effective policy review with respect to the opioid crisis and methamphetamine issues. The effectiveness of the project model has already been seen with the results from the pilot project in Surrey, which were used by front-line responders and policy makers to inform drug policies and programs used to save Canadian lives.
Proportionality: The requested data represents the minimum information required to formulate the cohort and produce the analytical output requested. These analytical outputs can highlight the demographic characteristics of individuals who have experienced an overdose, and the associated risk and protective factors associated with overdose events. The analytical output is developed in collaboration with key stakeholders, to best inform their data needs. The files and variables requested represent only the data that are needed to produce high quality aggregated analytical information. The pilot project in Surrey was used as a model for the Narcotics, Substance Abuse and Community Well-Being Initiative to determine the types and number of variables needed to produce the requested indicators. Given that the work under the Initiative is predicated on work previously undertaken by Statistics Canada, the quality requirements have already been assessed, and cannot be modified without decreasing the quality of the final analytical output. For the pilot project in Surrey, several administrative databases were acquired, each of which contained roughly nine personal identifiers used for linking the data with other databases. Additionally, various incident level variables were collected related to the type of database, such as: the type of call made to emergency services requesting a service, if treatment was given, final outcome of the call (for example, if a first responder was sent), and billing information. There could be up to 70 additional incident level variables requested depending on the specific database of interest and the analysis sought by the stakeholder. Although personal identifiers are required for record linkage, all risk mitigation approaches have been implemented and are described below under "Mitigation Factors".
Proportionality has also been considered based on data sensitivity and ethics:
- Data sensitivity: Although the data requested have some degree of sensitivity, no issues relating to sensitivity were raised during the course of the pilot project in Surrey and the overall public good resulting from the Initiative justifies their collection.
- Ethics: In undertaking this work, numerous experts have been consulted to date. These include experts at Statistics Canada, but also experts working with provincial and municipal governments. Under this Initiative, Statistics Canada is partnering with the Simcoe-Muskoka Opioids Strategy (SMOS) group, comprised of experts working in the health, justice and employment sectors. There are no known legal issues stemming from the Initiative as the data being requested are from data custodians with the authority to share the data with Statistics Canada. While there are no plans to engage with Canadians at large, under the project's common governance structure, individuals with lived experience are given the opportunity to review and comment on the analytical output prior to dissemination. The opioid crisis shows no sign of slowing down, and is impacting thousands of Canadians and communities across Canada. Given the gravity of the crisis, and the potential social good resulting from the project in increasing understanding of those most at-risk of drug overdose, the project is helping more than hindering.
Alternatives: There is no extensive source of overdose incidents currently available at Statistics Canada. For instance, for the pilot project in Surrey, we received paramedic data which proved critical in forming the study cohort. Detailed paramedic data is not currently available at Statistics Canada. Existing administrative data sources available at Statistics Canada, namely, the National Ambulatory Care Reporting System (NACRS), Discharge Abstract Database (DAD), and Vital Statistics – Death Database (CVSD), underestimate the number of individuals experiencing overdose and do not have the same level of detail that the requested databases will provide. Databases that do not have a sufficient level of detail reduce the accuracy of the indicators produced, therefore making it difficult to determine primary risk factors and the sub-populations at greatest risk of overdose. Additionally, this data does not exist anywhere in one data source therefore validating the importance of using Statistics Canada's capability and expertise to integrate the external data sources in order to create a comprehensive database for the Initiative.
The identifiable information is required only for the purpose of record linkage to produce more accurate analysis. Upon receipt of the files, the identifiable data will be stored separately from the analytical information. Any identifiable information on the analytical files will be replaced by an anonymized person key. The identifiable information will be available only on a need-to-know basis, and will be restricted to the project team of under 8 people.
A research file containing individual records, with no names or other direct identifiers, may be shared with the organisations participating in the Initiative under a discretionary disclosure order with the authorization of the data provider for statistical and research purposes, as permitted by the provisions of Subsection 17(2) of the Statistics Act.
Access to personal information
Statistics Canada has established that information collected about minors will not be disclosed to parents or guardians requesting access to their child's personal information. If parental values and belief systems differ from those of the minor, disclosure of the minor's information to a parent or guardian could place the minor's safety at risk. The individuals themselves, whether they are adults or minors, can request and obtain the information collected about themselves.
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.
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, Social, Health and Labour Statistics Field. 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 Privacy Impact Assessment.
Modern Statistical Methods and Data Science
Chief Privacy Officer
Assistant Chief Statistician,
Social, Health and Labour Statistics
Chief Statistician of Canada