Introduction
Statistics Canada has been leveraging a Client Relationship Management (CRM) solution to help support the provision of client service delivery, business respondent relations, microdata access and Census respondent relations. However, the existing system and underlying database have become increasingly more complex, hard to maintain and challenging to adapt to new realities.
Therefore, in line with the Statistics Canada's modernization objectives, the CRM system is being updated to support a strategic, holistic and consistent approach to the collection of quality client business intelligence data that can help to strategically respond to clients' needs and better serve Canadians.
Objective
A privacy impact assessment for the CRM System was conducted to determine if there were any privacy, confidentiality or security issues with this system and, if so, to make recommendations for their resolution or mitigation.
Description
The new CRM system is a cloud-based software solution that allows us to move to the Protected B cloud, in alignment with the Statistics Canada's cloud migration initiative, as well as leverage modern technology to integrate enhanced security features and better support our business processes.
The new platform will be used by Statistics Canada employees to record details about meaningful client interactions, as is done in the current software. The client information entered is related to:
- general inquiries from individuals, organizations and media
- transactions for paid and unpaid services and products (e.g., contracts, licensing agreements, invoices and method of payment)
- personal client information for recontact purposes (e.g., names, contact information)
- client requests for access to data and analytical platforms (e.g., research proposals, security clearance information)
- business respondent information to monitor and document operational decisions related to data collection and response burden for business data that is collected under the Statistics Act (e.g., respondent name, business name, contact information, business size and sector, correspondence).
Risk Area Identification and Categorization
The PIA identifies the level of potential risk (level 1 is the lowest level of potential risk and level 4 is the highest) associated with the following risk areas:
a) Type of program or activity
Administration of program or activity and services
Risk scale: 2
b) Type of personal information involved and context
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.
Risk scale: 1
c) Program or activity partners and private sector involvement
Within the institution (among one or more programs within the same institution)
Risk scale: 1
d) Duration of the program or activity
Long-term program or activity.
Risk scale: 3
e) Program population
The program's use of personal information for internal administrative purposes affects certain employees.
Risk scale: 1
f) Personal information transmission
The personal information is used in a system that has connections to at least one other system.
Risk scale: 2
g) Technology and privacy
Statistics Canada is proceeding with a cloud-based Client Relationship Management (CRM) solution (MS Dynamics 365) which is a Software-as-a-Service (SaaS) solution that will be hosted in the protected B Azure cloud. The system will only be used by internal staff of Statistics Canada as a method to consistently record inbound or outbound client interactions and personal information about clients or to record interactions with respondents for certain operational processes (e.g., response burden monitoring). Information will be sent to and received from other internal systems to ensure that complete and quality information can be efficiently generated in a safe and secure manner. Selected information from the CRM system will also be used to populate external dashboards so that clients requesting information using web forms can view the status of their requests on their personal dashboard. External users will not have access to the CRMS directly.
h) Potential risk that in the event of a privacy breach, there will be an impact on the individual or employee.
There is a very low risk of a breach of the personal information being disclosed without proper authorization. The impact on the individual would be low given the low sensitivity of the information being included in the system.
i) Potential risk that in the event of a privacy breach, there will be an impact on the institution.
There is a very low risk of a breach of the personal information being disclosed without proper authorization. There could be a negative impact on the institution with regards to the public's perception of Statistics Canada's information protection practices.
Conclusion
This assessment of the Client Relationship Management System did not identify any privacy risks that cannot be managed using existing safeguards.