Privacy Impact Assessment (PIA) summary
Government Institution
Veteran Affairs Canada
Government Official Responsible for the Privacy Impact Assessment
Charlotte Stewart
Director General, Service Delivery & Program Management
Head of the government institution / Delegate for section 10 of the Privacy Act
Shawn MacDougall
ATIP Coordinator
Name of Program or Activity of the Government Institution
Veterans Affairs Canada (VAC) and Service Canada (SC) Partnership
Description of Program or Activity
Canada’s Veterans can access services in more locations through a new partnership between VAC and Service Canada. The objective of the partnership is to provide increased access for Canadians, including Veterans and their families, to general information on VAC's programs and services through Service Canada’s in-person network of offices and Scheduled Outreach sites. This partnership with Service Canada provides Veterans with approximately 600 points of service across the country. In addition to obtaining services through Service Canada, Canadians can continue to access information about VAC programs and services online at veterans.gc.ca or in person at VAC offices and Canadian Forces Bases across Canada.
The PIA assessed the initiative to identify risks to personal information and implement changes to remove or mitigate the risks. This PIA has been submitted to Treasury Board Secretariat (TBS) and the Office of the Privacy Commissioner (OPC).
Description of the class of records and Personal Information Bank associated with the program or activity
Class of Records and Personal Information Banks can be reviewed at: VAC's Info Source Chapter
Legal Authority for Program or Activity
VAC – Service Canada Order in Council # 2011-1348, signed by the Deputy Governor General on November 21, 2011.
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
- Personal information is used to make decisions that directly affect the individual (i.e. determining eligibility for programs including authentication for accessing programs/services, administering program payments, overpayments, or support to clients, issuing or denial of permits/licenses, processing appeals, etc.).
Level of risk to privacy – 2
- 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
- With other federal institutions.
Level of risk to privacy – 2
- With other federal institutions.
- Duration of the Program or Activity
- Long-term program - Existing program that has been modified or is established with no clear “sunset”.
Level of risk to privacy – 3
- Long-term program - Existing program that has been modified or is established with no clear “sunset”.
- 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 – No
- 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 – No
- 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 within a closed system.
Level of risk to privacy – 1
- The personal information is used within a closed system.
- Risk Impact to the Institution
- Organizational harm - Changes to the organizational structure, changes to the organizations decision-making structure, changes to the distribution of responsibilities and accountabilities, changes to the program activity architecture, departure of employees, reallocation of HR resources.
Level of risk to privacy – 2
- Organizational harm - Changes to the organizational structure, changes to the organizations decision-making structure, changes to the distribution of responsibilities and accountabilities, changes to the program activity architecture, departure of employees, reallocation of HR resources.
- Risk Impact to the Individual or Employee
- Inconvenience
Level of risk to privacy – 1
- Inconvenience