Supplement to Statistics Canada's Generic Privacy Impact Assessment related to the Oral Health Statistics Program
Date: November 2023
Program manager: Director, Centre for Direct Health Measures
Director General, Health Statistics
Reference to Personal Information Bank (PIB)
In accordance with the Privacy Act, Statistics Canada is submitting a new institutional personal information bank (PIB) to describe any personal information collected through the administrative data acquisition activities and voluntary oral health surveys of the Oral Health Statistics Program. The following PIB is proposed for review and registration. (See Appendix 1)
Description of statistical activity
In Budget 2023, the Government of Canada introduced a national dental program to be implemented by Health Canada, with $23.1 million allocated to Statistics Canada over two years "to collect data on oral health and access to dental care in Canada, which will inform the rollout of the Canadian Dental Care Plan".
The national dental program aims to provide dental coverage for uninsured Canadians with annual family income of less than $90,000, with no co-pays for those with family incomes under $70,000. The implementation of this program aims to address inequities related to oral health such as the differences in health outcomes between different sub-populations and barriers to oral health care access across sociodemographic groups. This program is being implemented through the Canadian Dental Care Plan (CDCP)Footnote 1 which will replace the interim Canada Dental Benefit (CDB).Footnote 2 Health Canada is the primary program stakeholder for the CDCP, but will rely on the Canada Revenue Agency (CRA) for administration of the interim CDB, on Employment and Social Development Canada (ESDC) for the maintenance of CDCP applicant data and on a third-party service provider (Sun Life) for the administration of the CDCP.
As such, Statistics Canada, under the authority of the Statistics Act,Footnote 3 is establishing the Oral Health Statistics Program (OHSP) to address these data needs through an integrated comprehensive strategy focusing on two core activities: new oral health surveys and administrative data acquisitions and integration. This data strategy aims to collect data to assess and produce information on Canadians' self-reported oral health status, track changes in oral health care needs and oral health outcomes. The data strategy will also enable Health Canada to track the performance of the CDB and CDCP, the impact of the CDB and CDCP on the Canadian dental infrastructure as well as self-reported measures of the oral health of Canadians. While Health Canada is not a financial contributing partner on this initiative and will not be receiving any microdata from Statistics Canada, Statistics Canada and Health Canada will have a signed a Memorandum of Understanding describing both organisations' commitment to steward the OHSP, ensuring the latter is able to provide the statistical information required to accurately and adequately inform the CDCP on an ongoing basis.
Oral Health Surveys
The OHSP will collect and integrate the following survey activities:
Canadian Oral Health Survey (COHS): The COHS will be a voluntary household survey collecting information directly from respondents in all 10 Canadian provinces. The COHS will sample 55,000 Canadian dwellings where one adult 18 years and older will be randomly selected to complete the survey. The selected respondent will also answer the questionnaire on behalf of individuals 17 years and younger in the household. The first cycle will take place in 2023.
To better understand the state of Canadians' oral health, the COHS will collect information about:
- self-perceived oral health
- knowledge of publicly funded oral health programs and access to dental care
- oral health-related expenses
- oral health insurance coverage
Results from this survey will help better understand Canadians' oral health status, risk factors and insurance coverage to inform policies and monitor changes in the oral health of Canadians over time. It will support the deployment of dental care services to all Canadians, and fill gaps to support the CDCP.
Prior to starting the survey questionnaire, the COHS will inform respondents that their responses may be combined with sociodemographic and socioeconomic variables such as language spoken at home, immigration status and family income from Statistics Canada's 2021 Census of Population, the Longitudinal Immigration Database, the Administrative Personal Income Masterfile, as well as the Income Tax T1 Family File to further limit the burden of a lengthy questionnaire to respondents and increase the accuracy of results. The respondents are provided with Statistics Canada's contact information for any questions or concerns regarding the record linkage.Footnote 4
Future cycles of the COHS could also include the collection of direct physical health measures at a Statistics Canada's mobile examination centre (MEC),Footnote 5 similar to those used in Statistics Canada's Canadian Health Measures Survey (CHMS), from the general Canadian population with a focus on CDCP claimants. The inclusion of direct physical measures, such as oral health assessments by oral health professionals, would be essential in identifying oral health trends in Canada and provide evidence to support the CDCP.Footnote 6
Statistics Canada will also conduct a mandatory business survey of dental care providers, the Survey of Oral Health Care Providers (SOHCP).Footnote 7 This survey will target businesses, not individuals, and will not collect any personal information aside from business survey respondent contact information or unincorporated business information, which is addressed in Statistics Canada's Generic PIA (Section 3, Program 1). The SOHCP and any other similar business surveys are out of scope for this SPIA.
Administrative Data Acquisitions and Integration
The OHSP will also collect and integrate the following administrative data about individuals participating in the CDB and CDCP:
- CDB Recipient Data: The CDB has been administered by the Canada Revenue Agency (CRA) since November 2022. In this role, the CRA maintains a CDB file that provides socio-economic information about the recipient and their families, including their name, date of birth, social insurance or dependant identification number, address, income, employer, and dental care provider.
- CDCP Applicant Enrollment Data: Once launched, the CDCP will be administered by ESDC, whereby they will maintain data on applicant's and their family for Canadians seeking to enroll in the CDCP, including their name, date of birth, contact information, social insurance number (SIN), plan enrollee identification number, preferred language of communication, and access to private dental benefits.
- CDCP Client Claims Data: The CDCP client claims data will be collected and processed by a third-party administrator (Sun Life)Footnote 8 that will be responsible for facilitating the claims system on behalf of Health Canada. This will include information about the enrollee identification number, nature of dental care (procedure), reimbursement amounts, cost of procedure, and the name and address of the dental care service business.
The combined data will help administrators and policymakers better understand the eligible population seeking dental care. Further, the CDCP enrollment data will be used to generate a custom sampling frame for future surveys discussed above. Social insurance or dependant identification number and plan enrollee identification number and other direct identifiers are required to link individuals' microdata effectively and accurately across datasets and sources.Footnote 9
- Existing Statistics Canada Data holdings: The CDB and CDCP administrative data will be integrated with existing Statistics Canada data holdings in the Social Data Linkage Environment (SDLE)Footnote 10 such as the Longitudinal Immigration Database, the Administrative Personal Income Masterfile, the Income Tax T1 Family File and the 2021 Census of Population, to create a clear and complete picture of populations needing dental care, barriers to dental care, sub-population eligibility for the CDB and/or CDCP, as well as any gaps in program uptake, disaggregated by region and socio-economic characteristics. These insights will enable a better understanding of the eligible populations for the dental care programs, have the potential to highlight issues surrounding access to oral care, and help policymakers in designing targeted outreach strategies, managing risks to dental care supply, and ensuring eligible populations access benefits and receive needed oral health care.
In summary, the OHSP will consist of the following:
| Data source | Dataset name – vintage – frequency & type of data collection or acquisition | Data provider; targeted population | VariablesFootnote 11 |
|---|---|---|---|
| New Statistics Canada survey activities | COHS: General population - annual cross-sectional survey (questionnaire) | Direct collection from randomly selected household respondent aged 18 years or older, plus, all household members by proxy; general population |
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| Direct collection from randomly selected household respondent aged 18 years or older, plus, household members under 18 years by proxy; general population |
|
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| COHS: Direct Physical Health Measures component - frequency to be determined | Target population to be determined | Direct physical assessment by a Statistics Canada oral health specialist using the 2022 CHMS protocols. The SPIA would be updated with an addendum to address any additional details. | |
| SOHCP (business survey) - biannual (every 2 years) | Direct collection from randomly selected dental care providers | The SOHCP is a business survey and as such will not collect any personal information aside from business survey respondent contact information or unincorporated business information, which is addressed in Statistics Canada's Generic PIA (Section 3, Program 1), and as such is out of scope for this SPIA. | |
| New Administrative data acquisition | CDB: Recipient Data file – 2020-2024 (anticipated program termination) – monthly | Canada Revenue Agency (CRA); CDB recipients only |
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| CDCP: Applicant Enrollment Data file – December 2023-onward – monthly | Employment & Social Development Canada (ESDC); CDCP applicants only |
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| CDCP Client Claims Data file – 2024-onward – monthly | 3rd party administrator – Sun Life; CDCP claimants only |
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| Existing Statistics Canada Data Holdings (Survey or Administrative Data Acquisition) | Census of Population, 2021 | Statistics Canada; all residents in Canada |
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| T1 Family File | Statistics Canada; all individuals who completed a T1 tax return or received federal child benefits, and their spouse & children within the administrative files sourced through the Canada Revenue Agency for the reference year. |
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| Administrative Personal Income Masterfile | Statistics Canada; all individuals with income who can be identified within the administrative files sourced through the CRA for the reference year. |
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| Longitudinal Immigration Database (IMDB) | Statistics Canada; all immigrants to Canada & non-permanent residents |
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The OHSP may enter into agreements to share personal information of identifiable individuals with their consent. Prior to granting or rejecting consent to share, respondents are advised as part of the data sharing consent request question, or by the interviewer, to consult each person in the household on behalf of whom they are answering, including minors. Availability and access to the program data will focus on using existing secure Statistics Canada access mechanisms such as the Federal Research Data Centre (FDRC), research data centre network (RDC),Footnote 12 Real Time Remote Access (RTRA), Virtual Data Lab (VDL), and Data Analytics ServicesFootnote 13 such as the Advanced Analytics Workspace. These virtual workspaces continue to offer secure and reliable controlled digital environments in which Statistics Canada can manage and monitor controlled access to and use of datasets by vetted individuals working on approved research. These individuals have undertaken Statistics Canada's Oath of office to become deemed employees under the authority of the Statistics Act (Section 5 & 6). Outputs from these digital workspaces continue to be monitored and reviewed by Statistics Canada disclosure control experts prior to release from the virtual environment. The data will also be available in non-confidential aggregated formats via the Statistics Canada's website.
The necessity and proportionality for the OHSP and the collection and use of each dataset are described below.
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 addresses specific privacy and security risks associated with the collection of personal information on adults and minors using a combination of surveys and administrative data acquisitions, including sensitive sociodemographic, financial, health and mental health information about individuals, including minors. 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.
Necessity and Proportionality
The collection and use of personal information for the program can be justified against Statistics Canada's Necessity and Proportionality Framework:
1. Necessity
In the 2023 Budget, the Government of Canada announced $23 million in funding over two years for Statistics Canada to collect data and produce statistics to address data gaps in oral health and access to dental care and inform the rollout and eventual impact of the CDCP on Canadians, specifically noting the need to disaggregate by region and socio-economic characteristics. As such, data collected by the OHSP are necessary to track changes in Canadians' oral health, access and utilization of dental care services, and help policymakers in the anticipated transformations in the delivery of dental care services. This will help Canadians and policymakers in better understanding the Canadian dental care landscape, as well as inform the rollout and implementation of the CDCP.
1.1 Collection modes & methods
A combination of collection modes and methods is necessary to effectively collect timely and accurate relevant data capable of providing robust statistical information about oral health and support Health Canada's implementation and administration of the CDCP in Canada. Microdata linkage will allow separate but relevant information about individuals to be linked, providing for analysis of multiple related variables.
1.1.1 Surveys
Direct collection from survey respondents is necessary in order to collect up-to-date information about individuals' oral health, dental care access, knowledge of publicly funded oral health programs and insurance coverage. Section 3 of the Statistics Act supports this activity by directing Statistics Canada "(a) to collect, compile, analyse, abstract and publish statistical information relating to the commercial, industrial, financial, social, economic and general activities and condition of the people."
1.1.2 Administrative Data Acquisitions
Administrative Data Acquisitions are required to obtain the information as recorded by the dental care programs, which by necessity will contain the most accurate and up-to-date information on service providers and services provided. Administrative data are used for many different statistical purposes, including replacing or complementing direct data collection to reduce respondent burden and supporting foundational statistical operations, such as the creation of survey frames, design of survey samples, validation, imputation, estimation, and the measurement of the quality of other data. Section 3 of the Statistics Act supports this activity by directing Statistics Canada "(d) to promote the avoidance of duplication in the information collected by departments of government; and (e) generally, to promote and develop integrated social and economic statistics pertaining to the whole of Canada and to each of the provinces thereof and to coordinate plans for the integration of those statistics."
1.1.3 Existing Statistics Canada Data Holdings
Existing Statistics Canada holdings such as the Census of Population are necessary to develop an accurate survey frame that accurately represents the Canadian population and produce proper statistical weights for statistical products. Other data holdings, such as the Longitudinal Immigration Database, T1 Family File are required in order to provide relevant and accurate sociodemographic, immigrant, income and business information without increasing respondent burden. As above, Section 3 of the Statistics Act supports this activity by directing Statistics Canada "(d) to promote the avoidance of duplication in the information collected by departments of government; and (e) generally, to promote and develop integrated social and economic statistics pertaining to the whole of Canada and to each of the provinces thereof and to coordinate plans for the integration of those statistics."
1.2 Types of information
The information collected and used in the OHSP includes personal information of minors, as the CDCP includes support for minors to obtain dental care.
1.2.1 Sociodemographic information (Surveys, Administrative Data Acquisitions, Existing Statistics Canada Data Holdings)
1.2.1.1 Surveys
Sociodemographic information will be collected from surveys and will enable validation and statistical analytical evaluation of dental care disparities, health inequities, and risk factors associated with Canadians' oral health. This information will allow disaggregated statistical analysis that is representative of the Canadian population. This includes information about the gender of respondents and minors in the household, which are required to produce data on gender disparities and transgender identity as it relates to oral health.Footnote 14
1.2.1.2 Administrative Data Acquisitions
Administrative data acquisitions are required in order to produce information about the regional and sociodemographic characteristics of Canadians who are seeking financial help in order to reduce barriers, such as cost, associated with accessing and/or receiving oral care. Direct personal identifiers are also required to ensure the accuracy of linkages performed, in order to adhere to Statistics Canada's Quality Guidelines.
1.2.1.3 Existing Statistics Canada Data Holdings
Data linkages will be done with data from the 2021 Census of Population, the Longitudinal Immigration Database (IMDB), the Income Tax T1 Family File, and the Administrative Personal Income Masterfile to augment the surveys and administrative data acquisitions with regional and socio-economic information. All data linkages will be conducted in compliance with Statistic Canada's Directive on Microdata Linkage, and to meet the priorities established by the Government of Canada.
Together, these data will produce an overarching view of Canadians' oral health, helping policymakers and Canadians evaluate the rollout of the CDCP and highlighting potential dental care access concerns within sub-populations.
1.2.2 Income information (Surveys, Administrative Data Acquisitions, Existing Statistics Canada Data Holdings)
1.2.2.1 Surveys
Supplementary information about net household and family income will be obtained via linkage with the T1 Family File and the Administrative Personal Income Masterfile to evaluate the socioeconomic characteristics of Canadians who will enroll in the CDCP, helping policymakers and Canadians better understand the relationships between oral health and socioeconomic indicators.
1.2.2.2 Administrative Data Acquisitions
Information on net household and family income will be collected through the CDB recipient data file. Should income data be missing from the CDB recipient data file, this information will be sought through the T1 Family File, and the Administrative Personal Income Masterfile. Income information is necessary to produce statistic on the socio-economic and regional characteristics of Canadians seeking oral care. This information will help Canadians and policymakers better understand nuanced economic characteristics of Canadians using this benefit program, which will in turn inform the implementation and administration of Canada's Dental Care Program.
1.2.2.3 Existing Statistics Canada Data Holdings
For the CDCP applicant enrollment data and the client claims data files, income information will be via linkage with the T1 Family File, and the Administrative Personal Income Masterfile and is necessary to produce statistics on the socio-economic and regional characteristics of Canadians seeking oral care.
1.2.3 Business information (Surveys, Administrative Data Acquisitions, Existing Statistics Canada Data Holdings)
The OHSP will collect business information through the Survey of Oral Health Care Providers (SOHCP). However, as mentioned above, no personal information will be collected other than business contact or unincorporated business information, and as such, is out of scope for this SPIA. Business information about the service providers (dental care offices) will also be collected from administrative data acquisition activities and will serve to provide insights into where Canadians are accessing dental care and the costs associated with care. Information regarding dental care providers, such as the office address and procedure cost, will enable an understanding of dental care access, such as the average travel distance between patient residences and their dental care provider by province or sub-population. These data will be integral pieces of information needed so that Statistics Canada can meet the Government of Canada's commitment to define the current state of Canada's dental care infrastructure and potential barriers to access care. Policymakers and Canadians require this information in order to make informed decisions.
1.2.4 Health information (Surveys, Administrative Data Acquisitions, Existing Statistics Canada Data Holdings)
1.2.4.1 Surveys
The collection of health information related to the individual's oral health, general health and mental health in combination with sociodemographic information are required to identify risk factors and health inequities amongst sub-populations. The collection of mental health information in combination with oral health information such as on-going and untreated mouth pain or brushing and flossing habits is necessary to understand possible associations, and the direction of those associations, between mental health, oral health behaviours, access to dental care services, oral health status and overall quality of life. Following the launch of the CDCP, this baseline information will be used to compare and assess improvements in Canadians' oral health over time with data collected from future surveys.
1.2.4.2 Administrative Data Acquisitions
Supplemental oral health information about Canadians who are enrolled in, and make a claim under, the CDCP will be acquired from administrative records. These claims data will include information about the procedure and its cost. This information is necessary to infer aspects of oral health and Canadians' approach to oral health behaviours (e.g., are the procedures preventative or for treatment?). This is particularly relevant because the CDCP is seeking to remove the barriers and improve the oral health of populations with oral health and oral care access challenges.
1.2.4.3 Existing Statistics Canada Data Holdings
The CDCP applicant enrollment data will be supplemented with disability tax credit information through linkage with the T1 Family File. This is necessary to measure the CDCP performance and to understand potential barriers to enrollment and use of the program. Linkage to the 2021 Census of Population will further allow for the production of statistics relative to disabilities. This is necessary to produce a holistic picture of the socio-economic and regional characteristics of oral health including populations living with a disability.
1.2.5 Dental insurance coverage information (Surveys, Administrative Data Acquisitions)
The collection of dental insurance coverage information from the administrative data acquisition activities and the oral health surveys will provide information about the status of applicants' CDCP enrollment, and attestations about any health insurance coverage provided through private, employment, or government insurance plans. This information will be used to understand the sociodemographic characteristics of Canadians who lack oral health insurance coverage, which will help inform Canadians and policymakers on the implementation of the CDCP.
2. Effectiveness – Working assumptions:
The OHSP aims to effectively collect and analyze information on the current and future status of oral health and dental care in Canada through the collection of the aforementioned datasets and surveys on an ongoing basis. All of Statistics Canada directives and policies for the collection, linkage, sharing, and dissemination of administrative and survey data and insights will be followed.
2.1 Collection modes & methods
For more information on the effectiveness of Statistics Canada's surveys, administrative data acquisitions and linkage activities, please see Statistics Canada's Statistics: Power from Data! 3.3.1 Data collection methods, 3.4.5 Record linkage or Statistics Canada's Quality Guidelines. Privacy analysis of these standardized Statistics Canada statistical activities are found in Statistics Canada's Generic Privacy Impact Assessment.
2.2 Types of information
2.2.1 Sociodemographic information
The survey questionnaires and sample frame were developed according to Statistics Canada's processes and methodologies ensuring results are representative of the population and provide a sufficient quantity of respondents to allow for privacy-protecting analysis, release and publication. Sociodemographic survey questions are based on previous Statistics Canada surveys such as the 2022 Canadian Health Measures Survey (CHMS) and the 2022 Canadian Community Health Survey (CCHS). The surveys will be administered using a self-reported electronic questionnaire with telephone follow-up.
Administrative records from the CDB and CDCP will contain information about the claimant, and may contain information about their family, if included at time of data entry. This data will include information on all Canadians who enrolled and/or claimed coverage under the CDB and CDCP and will therefore provide the means to achieve the highest quality estimates of sociodemographic characteristics of Canadians who seek improved access to oral care.
The collection of sociodemographic information will be effective in enabling an evaluation of dental care disparities, health inequities, and risk factors associated with Canadians' oral health and producing quality population level estimates that are representative of Canadian adults, households and/or children living in the 10 Canadian provinces. This data could, for instance, indicate the composition or types of households eligible for the CDCP as it rolls out in stages of eligible participants, assisting Canadians and policymakers in its implementation.
2.2.2 Income information
As there are only a few limited public oral health programs available to Canadians, oral health care is typically provided by private businesses with costs that can be a potential barrier to those requiring treatment. To better understand the economic characteristics of Canadians seeking access to oral health care under the CDB and CDCP, accurate and timely income information will be acquired from appropriate administrative records and existing Statistics Canada data holdings. Analysis of income information for CDB recipients will help discern characteristics of the eligible population for the CDCP. Furthermore, income information may help to discern CDCP-eligible populations who have not yet enrolled in the CDCP, further assisting Canadians and policymakers in its implementation.
2.2.3 Business information
Geographic information about dental care offices will be obtained through the CDB recipient and CDCP client claims data. Treatments and associated costs will also be obtained through the CDCP claims data. Information about where Canadians receive their dental care will provide a clearer picture of where Canadians access their dental care and what anticipated future demands will be placed on specific dental care providers as a result of the implementation of the CDCP.
2.2.4 Health information
Health related questions included in the oral health surveys are based on previous Statistics Canada surveys such as the 2022 CHMS and the 2022 CCHS. Comparison and analysis between the collected data from the oral health surveys and the health data collected from these other surveys will allow for effective monitoring of changes in trends around the oral health of Canadians over time and inform policy creation and maintenance. Oral health surveys will be collected annually for effective comparative analysis moving forward.
2.2.5 Dental insurance coverage
Dental insurance coverage data will indicate the cohort of respondents who plan to enroll in the CDCP before and after its implementation. By leveraging the dental insurance coverage data from the administrative data acquisition activities and oral health surveys, the OHSP will also help to improve the survey sampling strategy for future administrative data acquisition activities and surveys, effectively augmenting the quality of resulting statistical products.
3. Proportionality
While the personal information collected by the OHSP from different sources can be deemed sensitive, it is expected to yield benefits such as improving Canadian's access to oral health care, and reducing oral health inequities in Canada. Careful consideration was made to avoid adversely impacting the privacy of respondents by limiting the number of survey questions and incorporating data linkages where possible to increase accuracy and reduce respondent burden. The collection of data directly from individuals on oral health surveys in combination with the collection of data indirectly from administrative data acquisition activities will allow for proportional insights on barriers to oral health in the general population as well as in those seeking and accessing care, respectively. The survey data will include information on all Canadians, irrespective of their CDCP eligibility status (e.g., insurance coverage, travel to dental offices, etc.), while administrative data from the CDCP will provide additional information on the subpopulation that enrolled in the CDCP. This combination of information will allow policymakers to have the necessary evidence to evaluate the CDCP, such as by determining whether the program is improving health equity amongst Canadians. The OHSP is expected to deliver representative and high-quality information on oral health and dental care access in Canada by expanding and filling data gaps not covered in other Statistics Canada surveys.
4. Alternatives
Although Statistics Canada collects some oral health information in surveys such as the CHMS and CCHS, the OHSP collection activities will leverage new and more comprehensive oral health data. Moreover, as timely and consistent data on the oral health of Canadians has become an ongoing data need for the Government of Canada, the cyclical nature of oral health content in Statistics Canada's CHMS and CCHS, which is included to a limited degree only every few survey cycles, a dedicated oral health survey remains the only viable option to obtain comprehensive up-to-date information on oral health care and related factors. Additionally, despite the use of administrative data and microdata linkage activities to fill data gaps and reduce respondent burden, a cross-sectional oral health surveyFootnote 15 remains required to supplement those activities with first-hand information from affected individuals about conditions and other variables not captured in the administrative data. Alternative sources of data were considered before proceeding with this survey and several oral health questions from other Statistics Canada surveys such as the CHMS and the CCHS were reused or modified for this survey to allow for a comprehensive baseline survey on oral health.
There exist no viable alternatives to collecting administrative data directly from the CDB and CDCP programs themselves, as no other similar national programs exist from which to acquire administrative oral health data. The COHS will be the first primary source of comprehensive oral health data, but it will have limited effectiveness if it is not supplemented by the administrative data integrations, as they become available. As such, the selected combination of survey and administrative data is essential to providing insights on the state of oral health in Canada effectively and objectively, with no suitable substitutions.
Mitigation factors
The overall risk of harm to the survey respondents has been deemed manageable with existing Statistics Canada safeguards that are described in Statistics Canada's Generic Privacy Impact Assessment, which includes the following standard measures:
Transparency
Prior to the collection of the Canadian Oral Health Survey, respondents will be informed that the survey is voluntary, of the survey purpose, potential sharing agreements and anticipated data linkage, allowing them to decide whether they wish to participate and consent to sharing their information.
At the beginning of the survey:
Survey Purpose
Statistics Canada and Health Canada have partnered to conduct the Canadian Oral Health Survey. This annual survey gathers information from Canadians on their oral health, including their ability to pay, challenges finding oral services, experiences with the oral health care system, and care needs.
Additionally, the survey collects information on Canadians' knowledge of publicly funded oral health programs and access to dental care expenses and insurance coverage to better understand the state of oral health. Results from this survey will be used to inform policies and monitor changes in the oral health of Canadians over time."
Record linkages
To enhance the data from this survey and to reduce the response burden, Statistics Canada will combine the information you provide with information from Census of Population, the Longitudinal Immigration Database, and tax data from the Canadian Revenue Agency
Statistics Canada may also combine the information you provide with other survey or administrative data sources.
At the end of the survey:
Data sharing agreements
To avoid duplication of surveys, Statistics Canada may enter into agreements to share the data from this survey, with provincial and territorial ministries of health. For Quebec residents, Statistics Canada may also enter into an agreement with the Institut de la statistique du Québec to share the same information.
These organizations agree to keep the data confidential and use it only for statistical purposes.
Do you agree to share the data provided?
If you are answering on behalf of other people, please consult each person."
Respondents will be able to reply "Yes" or "No"; if "No" is selected, their information will be excluded from all related share files.
The survey purpose will be provided via a brochure, invitation and reminder letters that will be mailed separately to the targeted respondents, and will also be reiterated at the beginning of the questionnaire. Respondents will also be informed in the brochure, invitation letter, reminder letters, and in the questionnaire itself, that their participation is voluntary before being asked any questions. Information about the survey including a copy of the questionnaire, will also be available on Statistics Canada's website.
Regarding the administrative data acquisitions, Canadians who enroll in the CDCP are informed that the information they provide to access these benefits are collected and managed according to the Department of Health Act, the Dental Care Measures Act, the Privacy Act, the Department of Employment and Social Development Act and other applicable laws and by applying to the CDCP, they consent to the use and disclosure of their information for the purpose of evaluating the implementation of the CDCP.
Confidentiality
As with all Statistics Canada programs, variables that directly identify respondents will be separated from the data files in the first stage of data processing and placed in a secure location with controlled need-to-know access. Variables that might indirectly identify respondents are also examined and modified as necessary in order to further protect the privacy and confidentiality of respondents prior to publication and dissemination. Individual responses provided in a survey will be grouped with those of others when reporting results. Furthermore, careful analysis of the data will be performed prior to the publication and sharing of aggregate data to ensure that marginalized and vulnerable communities are not disproportionally impacted.
Data linkage
Security measures for linkage keys and administrative data files respect the policies, directives and guidelines for information technology security at Statistics Canada and the Government of Canada. When linkage is required, it is done only after strict review and approval, according to Statistics Canada's Directive on Microdata Linkages, using anonymized statistical identifiers ("linkage keys") and, as a result, no linked files contain direct personal identifiers such as name, phone number or address (excluding postal code). The personal identifiers used to create linkage keys are removed from the rest of the information and securely stored with highly restricted need-to-know access that is revoked when no longer required.
Conclusion
This assessment concludes that with the existing Statistics Canada safeguards and mitigations listed above, 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 the Enterprise 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 Supplementary Privacy Impact Assessment.
This Privacy Impact Assessment has been approved by the Chief Statistician of Canada.
Appendix 1: Personal Information Bank
Oral Health Statistics Program
Description: This bank describes information obtained from respondents to Statistics Canada oral health surveys and from related administrative files of individuals who applied for, are enrolled in, or received reimbursement or payments under the Canada Dental Benefit and/or the Canadian Dental Care Plan. These files are obtained from the Canada Revenue Agency, Employment and Social Development Canada, and the third-party administrator of the Canadian Dental Care Plan. The personal information may include name, contact, biographical, biometric, citizenship status, education, language, health and medical information, employment, marital status, family information (spouse name, gender, preferred language of communication, and dependent name and age), personal and family income, reimbursement for services received/coverage paid, provincial health card number and Social Insurance Number. Additional information such as information about applicants' private or government insurance coverage, their dental care provider (such as office address), and information about dental appointments (costs and dates) may also be collected.
Note: In addition to the requirements specified on the Personal Information Request form, individuals who participated in a health survey and are requesting information described by this bank must provide the name of the survey in which they participated, the year in which the survey was conducted and their address at that time.
Class of Individuals: General public and Canadian families or individuals who applied to, are or were enrolled in, or claimants of the Canada Dental Benefit and Canadian Dental Care Plan.
Purpose: The personal information is used, in aggregate form, for statistical analysis and research of various oral health-related trends and issues over time, to improve the health of Canadians and the delivery of oral health services to them through ongoing research at all levels of government. Personal information is collected pursuant to the Statistics Act (Sections 3, 4, 7, 8, 13).
Consistent Uses: The data acquired may involve data-matching of the above surveys and databases and other Statistics Canada data holdings to meet the objectives of these studies. Information without names or other identifying information may be shared with outside organizations such as other federal departments, provincial and territorial governments, and university researchers, as permitted under the provisions of Sections 12 and 17(2) of the Statistics Act, for statistical and research purposes.
Retention and Disposal Standards: Information is retained until it is no longer required for statistical purposes, at which point it will be destroyed.
RDA Number: 2018/007
Related Record Number: StatCan HLT 080
TBS Registration: To be assigned by TBS
Bank Number: StatCan PPU 036