Privacy Impact Assessment (PIA) summary
Government Institution
Veteran Affairs Canada
Government Official Responsible for the Privacy Impact Assessment
Mary Nicholson
Director, Re-establishment, Financial Well-being and Business Intelligence Directorate
Head of the government institution / Delegate for section 10 of the Privacy Act
Crystal Garret-Baird
Director, Privacy and Information Management
Name of Program or Activity of the Government Institution
Income Replacement Benefit
Description of Program or Activity
The program provides economic support to eligible Canadian Armed Forces Veterans, members’ or Veterans’ surviving spouse/common-law partner, or orphans for the economic impact that a career ending and/or service-related injury or death can have on a Veteran’s ability to earn income, advance in a career or save for retirement. Support is provided to Veterans who have health problems, resulting from service that are causing a barrier to re-establishment and who are participating in the Rehabilitation Program; and those who were eligible for the program, but are unable to participate due to a diminished earnings capacity; Compensation is provided in the form of monthly income support payments. A lump sum benefit may be paid to the surviving spouse/common-law partner or orphans for non-service related death before the Veteran’s age of 65, if the Veteran was entitled to the Income Replacement Benefit at the time of his/her death. This lump sum payment equates to 24 times the amount of the Income Replacement Benefit amount that the Veteran would have been entitled to, for the month in which s/he died, before offsets.
Description of the class of record and the Personal Information Bank
Classes of Records (CORs) and Personal Information Banks (PIBs) can be reviewed at VAC's Information about Programs and Information Holdings.
Financial Benefits – Class of Record
Income Replacement Benefit – Personal Information Bank
Legal Authority for Program or Activity
Personal information is collected pursuant to Part 2, sections 18-26 and section 78.1 of the Veterans Well-being Act (VWA) [formerly known as the Canadian Forces Members and Veterans Re-establishment and Compensation Act (CFMVRCA)], as well as the associated Regulations. Sections 80 and 81 of the VWA provides information sharing authority upon which government institutions and agencies can rely. Social Insurance Numbers are collected pursuant to Section 82 of the VWA.
Risk Area Identification & Categorization
The following section contains risks identified in the PIA for the new or modified program. A risk scale has been included. The numbered risk scale is presented in ascending order: the first level represents the lowest level of potential risk for the risk area; the fourth level (4) represents the highest level of potential risk for the given risk area. Please refer to “Appendix C” of the TBS Directive on PIAs to learn more about the risk scale.
- Type of Program or Activity
- Administration of Programs / Activity and Services
Level of risk to privacy – 2
- Administration of Programs / Activity and Services
- Type of Personal Information Involved and Context
- Social Insurance Number, medical, financial or other sensitive personal information and/or the context surrounding the personal information is sensitive. Personal information of minors or incompetent individuals or involving a representative acting on behalf of the individual.
Level of risk to privacy – 3
- Social Insurance Number, medical, financial or other sensitive personal information and/or the context surrounding the personal information is sensitive. Personal information of minors or incompetent individuals or involving a representative acting on behalf of the individual.
- Program or Activity Partners and Private Sector Involvement
- Within the institution (amongst one or more programs within the same institution)
- With other federal institutions
Level of risk to privacy – 1 and 2
- Duration of the Program or Activity
- Long-term program.
Level of risk to privacy – 3
- Long-term program.
- Program Population
- The program affects certain individuals for external administrative purposes.
Level of risk to privacy – 3
- The program affects certain individuals for external administrative purposes.
- Technology & Privacy
- Does the new or modified program or activity involve the implementation of a new electronic system, software or application program including collaborative software (or groupware) that is implemented to support the program or activity in terms of the creation, collection or handling of personal information?
Risk to privacy - No
- Does the new or modified program or activity require any modifications to IT legacy systems and / or services?
Risk to privacy - Yes
- Enhanced identification methods - This includes biometric technology (i.e. facial recognition, gait analysis, iris scan, fingerprint analysis, voice print, radio frequency identification (RFID), etc.) as well as easy pass technology, new identification cards including magnetic stripe cards, “smart cards” (i.e. identification cards that are embedded with either an antenna or a contact pad that is connected to a microprocessor and a memory chip or only a memory chip with non-programmable logic).
Risk to privacy – No
- Use of Surveillance - This includes surveillance technologies such as audio/video recording devices, thermal imaging, recognition devices, RFID, surreptitious surveillance / interception, computer aided monitoring including audit trails, satellite surveillance etc.
Risk to privacy – No
- Use of automated personal information analysis, personal information matching and knowledge discovery techniques - For the purposes of the Directive on PIA, government institution are to identify those activities that involve the use of automated technology to analyze, create, compare, cull, identify or extract personal information elements. Such activities would include personal information matching, record linkage, personal information mining, personal information comparison, knowledge discovery, information filtering or analysis. Such activities involve some form of artificial intelligence and/or machine learning to uncover knowledge (intelligence), trends/patterns or to predict behavior.
Risk to privacy – Yes
- Does the new or modified program or activity involve the implementation of a new electronic system, software or application program including collaborative software (or groupware) that is implemented to support the program or activity in terms of the creation, collection or handling of personal information?
- Personal Information Transmission
- The personal information is used in a system that has connections to at least one other system.
- The personal information is transferred to a portable device or is printed.
- The personal information is transmitted using wireless technologies.
Level of risk to privacy – 2, 3, 4
- Risk Impact to the Institution
- Managerial harm
- Organizational harm
- Financial harm
- Reputational harm, embarrassment, loss of credibility.
Level of risk to privacy – 1, 2, 3 and 4
- Risk Impact to the Individual or Employee
- Inconvenience
- Reputational harm, embarrassment
- Financial harm
Level of risk to privacy – 1, 2 and 3