Supplement to Statistics Canada's Generic Privacy Impact Assessment related to the Survey of Financial Security (SFS)

Date: November 2022

Program manager: Director, Centre for Income and Socioeconomic Well-being Statistics
Director General, Labour Market, Education and Socioeconomic Well-being

Reference to Personal Information Bank (PIB)

Personal information collected through the Survey of Financial Security (SFS) is described in the Statistics Canada Personal Information Bank (PPU 151).

The Personal Information Bank is published on the Statistics Canada website under the latest Information about Program and Information Holdings chapter.

Description of statistical activity

Statistics Canada conducts the Survey of Financial Security (SFS) under the authority of the Statistics ActFootnote 1. The purpose of the SFS is to collect information about the asset and debt holdings of Canadians. This voluntary household survey, collects information on the value of all major financial and non-financial assets and on the money owing on mortgages, vehicles, credit cards, student loans and other debts. It was first conducted in 1999, and since 2016, it is conducted every three years in order to provide a comprehensive picture of the net worth of Canadians and how it may change over time. For the 2023 collection cycle, with a view to better understand how the financial situation of Canadian families has fared since the COVID-19 pandemic was first reported, one new question has been added to measure any changes to the financial situation of Canadians since the pandemic began.

Statistics Canada will publish aggregate results in the Daily (the Agency's official release bulletin) summarizing the survey findings along with data tables. Data will be fully anonymized and non-confidential, without any direct personal identifiers, which prevents the possibility of identifying individuals.

The Department of Finance, the Bank of Canada and public university researchers with vetted and approved research projects will access the data file, with all personal identifiers removed, in Statistics Canada's Research Data Centres (RDC)Footnote 2 and will only be permitted to release aggregate results, which are fully anonymized and non-confidential.

For recent cycles of the Survey of Financial Security, data have been linked to income tax data files (StatCan PPU 111) and the Administrative Personal Income Masterfile (APIM). This linkage is essential to obtain accurate personal and household income information while reducing burden on respondents. Additionally, the income data from the linked SFS/APIM (T1) data is further linked to T4 tax files, the Registered Plans Application Suite (RPAS) file and the Pension Plans in Canada (PPIC) database in order to value registered pension plan assets. Estimating the net worth of Canadians is incomplete without calculating the present value of pensions and the RPAS and PPIC linkages are critical for this work. Statistics Canada's microdata linkage and related statistical activities were assessed in Statistics Canada's Generic Privacy Impact Assessment.Footnote 3 All data linkage activities are subject to established governanceFootnote 4, and are assessed against the privacy principles of necessity and proportionalityFootnote 5. All approved linkages are published on Statistics Canada's websiteFootnote 6.

There are no data sharing agreements in place for the Survey of Financial Security.

Reason for supplement

While the Generic Privacy Impact Assessment (PIA) addresses the privacy and security risks related to statistical activities conducted by Statistics Canada, a supplementary PIA has been deemed necessary to address the sensitive nature of the survey content and the possible concerns of Canadians about the intrusiveness of the collection. This supplementary PIA describes the additional safeguards being implemented for the collection, processing and use of personal financial information. As is the case with all PIAs, Statistics Canada's privacy framework ensures that elements of privacy and protection and privacy controls are documented and applied.

The Generic PIA also presents and addresses the privacy principles and levels of potential risk, which apply to the collection and use of the personal financial information.

Necessity and Proportionality

The collection of personal information for the Survey of Financial Security can be justified against Statistics Canada's Necessity and Proportionality Framework:

1. Necessity:

The SFS seeks to provide data users with an understanding of the wealth dynamics of Canadians and a comprehensive look at the relationship between assets, liabilities, income, and demographic characteristics of Canadian families.

The findings from the SFS can be important to all levels of government, the private sector, academia and non-profit organizations who seek to understand the dynamics of the financial security of Canadians. The survey provides information to help address important questions on the nature of the financial security of Canadians, such as:

  • How many Canadians may be unable to manage their debt load?
  • Do families set aside money for their children's education?
  • Do people save adequately for retirement?
  • Will the pension system be able to support Canada's aging population?
  • What groups of people are most likely to be financially at risk?
  • How vulnerable are Canadians to major shifts in the financial markets?

Information gleaned from the survey also supports evaluating the asset resilience of Canadians and may help identify groups that may be more likely to be financially insecure.

Furthermore, the information provides policymakers and academics with indicators to learn more about highly indebted Canadians, the financial well-being of seniors, the prevalence of wealth inequality and the impact of these issues on our society. It also provides the public and non-governmental organizations with the opportunity to undertake their own research on wealth dynamics in Canada and keep governments accountable for their actions taken to help Canadians improve their financial well-being. Additionally, the data collected by the survey will keep the public informed on wealth-related economic conditions of Canadians.

2. Effectiveness - Working assumptions:

The content and scope of the questions have been developed in partnership with other federal government stakeholders including Finance Canada, Employment and Social Development Canada, the Bank of Canada, and the Canadian Mortgage and Housing Corporation. The questionnaire content includes a comprehensive list of all asset and debt instruments that are available to Canadians.

Before the questionnaire was first launched it was thoroughly tested by Statistics Canada's Questionnaire Design Resource Centre to ensure the concepts were well-understood by Canadians.

For the purpose of better understanding how the financial security of Canadians may change over time, the SFS has a fixed core content which uses a methodology that has remained stable over time. In order to help address new and emerging data priorities, new questions are occasionally developed, tested and included on subsequent survey cycles. One example of this is the introduction of a question on the holdings within the tax-free savings account program, which was launched in 2009 and introduced in the 2012 questionnaire.

3. Proportionality:

While the personal financial information collected by this survey is sensitive and Canadians may have concerns about the intrusiveness of its collection, the information helps governments, economic and social policy analysts, community groups and businesses serve Canadians better.

The sample of 39,500 dwellings across the 10 Canadian provinces is necessary to publish national-level and provincial-level estimates for the wealth dynamics of Canadians grouped by age and family type while still protecting the privacy and confidentiality of respondents. The total sample size has been assessed as necessary to ensure that estimates calculated from the collected data are of sufficient quality.

4. Alternatives:

Although some alternative data are available on individual asset and debt holdings of Canadians, these alternatives do not provide a comprehensive picture of all the asset and debt holdings of Canadians which is necessary to estimate their wealth (assets less debts). As an example, the survey calculates the current value of employer-sponsored pension plans held by Canadians based on their employment and demographic characteristics. Additionally, there are no alternative datasets available with a level of granularity that supports Statistics Canada's mandate. The collection and use of the personal information is being designed in such a way to minimize the collection and use of individualized data.

Mitigation factors

Some questions in the SFS are considered sensitive as they relate to the finances of Canadians. However, 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, some of which are highlighted here, as well as with some additional measures;

Transparency

As is the case for all surveys, respondents are informed through the invitation letter, at the beginning of the questionnaire and on Statistics Canada's websiteFootnote 7, that participation is voluntary and of the nature of the survey. Additionally, to further inform their decision to participate, a brochure and promotional materials are also provided (See Appendix 1).

Confidentiality

As is the case for all surveys, 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 access. Variables that might indirectly identify respondents are examined and modified as necessary in order to protect the privacy and confidentiality of respondents. Individual responses will be grouped with those of others when reporting results. Individual responses and results for very small groups will never be published or shared with government departments or agencies. Careful analysis of the data will be performed prior to the publication and sharing of aggregate data to protect the privacy and confidentiality of respondents.

Conclusion

This assessment concludes that the overall risk of harm to the survey respondents has been deemed manageable with existing Statistics Canada safeguards.

Formal approval

This Supplementary Privacy Impact Assessment has been reviewed and recommended for approval by Statistics Canada’s Chief Privacy Officer, the Director General for Labour Market, Education and Socioeconomic Well-being, and the Assistant Chief Statistician for the 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 Supplementary Privacy Impact Assessment.

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

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