Introduction
Statistics Canada is modernizing its methods of data access to improve its service to users of Statistics Canada data. The goal of modernization is to fully realize the potential of the data holdings created for the public good and increase collaboration and partnerships between data users and providers while ensuring that all data assets are protected against unauthorized use and disclosure.
Objective
This privacy impact assessment identifies and explores privacy, confidentiality and security issues associated with the use of video surveillance monitoring (camera monitoring) in secure facilities designed for the purposes of data access and makes recommendations for issue resolution or mitigation.
Description
As a first prototype, Statistics Canada undertakes to provide access to anonymized data for statistical research projects at the Virtual Federal Research Data Centre (vFRDC) located at Canada Mortgage and Housing Corporation (CMHC) headquarters in Ottawa. CMHC will benefit from this access by being able to create statistical information to improve policy decision-making, specifically, the Federal Government's National Housing Strategy.
This arrangement is referred to as a vFRDC because the anonymized data are no longer housed in the designated certified room. They are housed on secure servers at Statistics Canada headquarters and are accessed through Statistics Canada IT access protocols and devices in the designated certified room with a controlled entry swipe card system. Until now, this room has been open to only approved federal employees when a Statistics Canada employee is present (this security protocol was put in place to protect the data when they were housed on servers inside the designated certified room). Under the new prototype, where data are no longer housed in the secure room, a camera system will be used as an additional measure to monitor activities and access to the designated certified room when a Statistics Canada employee is not present.
The additional layer of camera monitoring of the designated certified room will provide more hours of operation with similar levels of security monitoring and decreased personnel costs for the client. Statistics Canada's use of the camera monitoring includes making recordings of activities in the secure designated room to offer enhanced protection of employees and assets.
Risk Area Identification and Categorization
The PIA also identifies the risk areas and categorizes the level of potential risk (level 1 representing the lowest level of potential risk and level 4, the highest) associated with the collection and use of personal information of employees.
- Type of program or activity – Level 2: Administration of program or activity and services.
- Type of personal information involved and context – Level 1: Only personal information, with no contextual sensitivities, collected directly from the individual or provided with the consent of the individual for disclosure under an authorized program.
- Program or activity partners and private sector involvement – Level 2: With other government institutions.
- Duration of the program or activity – Level 3: Long-term (ongoing) program.
- Program population – Level 1: The program's use of personal information for internal administrative purposes affects certain employees.
- Personal information transmission – Level 2: The personal information is used in a system that has connections to at least one other system.
- Technology and privacy: The new project involves the implementation of a new electronic system to support the program but does not involve the implementation of new technologies.
- Privacy breach: There is a very low risk of a breach of some of the personal information being disclosed:
- The impact on the employee would be minimal as it would only divulge a digital recording of the individual taken in the designated certified room.
- The impact on the institution would be minimal due to the low sensitivity of the information.
Conclusion
Statistics Canada has ensured that there are measures in place that meet central agency and Statistics Canada security standards for the protection of personal information captured by the system and the program.
This assessment concludes that, with the existing safeguards, any remaining risks are such that Statistics Canada is prepared to accept and manage the risk.