Supplement to Statistics Canada's Generic Privacy Impact Assessment related to the 2024 Census Test

Date: March 2024

Program manager: Director General, Census Management Office

Reference to Personal Information Bank (PIB):

Personal information collected through the Census Test is described in Statistics Canada's "Census of Population - Census Program Content Test" Personal Information Bank (Bank number: StatCan PPU 007) which collects information related to individuals who have participated in content tests conducted to test Census of Population Program questions.

The bank describes individuals within households selected to participate in Census Program test surveys. Personal information may include name, contact information, demographic information (including age, date of birth, ethnicity, and religion), Social Insurance Number (SIN), citizenship status, languages spoken or understood, relationship to cohabitant(s), educational information, financial information, work and other social and economic characteristics depending on the particular census or survey.

The "Census of Population - Census Program Content Test" PIB (Bank number: StatCan PPU 007) is published on the Statistics Canada website under the latest Information about Programs and Information Holdings chapter.

Description of statistical activity:

Under the authority of the Statistics Act^Footnote1, Statistics Canada is conducting the mandatory Census Test from April to June 2024. The objectives of the Census Test which involves a sample of dwellings across the country are to determine whether new or revised questions under consideration for the 2026 Census of Population can be easily understood and correctly answered, to assess public reaction to these questions by testing them on a smaller scale basis, and to evaluate behaviour of staff when using new systems and procedures.

The Census of Population's purpose is to provide statistical information, analyses and services that measure changes in the Canadian population and, demographic characteristics. It serves as a basis for public and private decision making, research and analysis in areas of concern to the people of Canada.

The Census of Population is a reliable basis for the estimation of the population of the provinces, territories and municipal areas. The information collected is related to federal and provincial legislative measures and provides a basis for the distribution of federal transfer payments. The census also provides information about the characteristics of the population and its housing within small geographic areas and for small population groups to support planning, administration, policy development and evaluation activities of governments at all levels, as well as data users in the private sector.

Access to trusted statistical information is an essential foundation of democratic societies, both to support evidence-based decision-making in the public and private sectors and to inform debate on public policy issues. Particularly in today’s fast-paced environment, with an unprecedented pace and scope of change, accurate statistical information, comparable over time and across various levels of geography, is essential to help Canadians better understand their country in the context of timely, relevant and high-quality statistical information on Canada’s changing economy and society.

To ensure the continued relevance of the census to Canadians, Statistics Canada conducts a formal consultation at the start of each census cycle. During that time, Statistics Canada invites data users, stakeholders and the general public to provide feedback on what information they use, for what purpose and what, if any, data gaps Statistics Canada should consider addressing in the next census cycle. A Consultation Report, 2026 Census of Population Consultation Results: What we heard from Canadians, will be published on Statistics Canada's website in April 2024^Footnote2.

As in past censuses, extensive consultations on the questions to include in the 2026 Census of Population have been held with Canadians. New and modified questions, developed to reflect new needs identified in the consultations, have been qualitatively tested by Statistics Canada in 2023 using methods such as individual interviews and discussion groups.

Reason for supplement:

While the Generic Privacy Impact Assessment (PIA) addresses privacy and security risks related to statistical activities conducted by Statistics Canada, this supplement describes potential new risks associated with the collection, processing and use of data related to new census content being considered, and the possible concerns of Canadians about the intrusiveness of the collection. As is the case with all PIAs, Statistics Canada's privacy framework ensures that elements of privacy protection and privacy controls are documented and applied.

Statistics Canada uses its Content Determination Framework process to identify potential new census content for inclusion in the Census. The process begins by consulting external stakeholders on their uses of the data and related information needs, including requirements for relevance and quality. Statistics Canada also assesses the Canadian context which encompasses respondent burden and societal privacy concerns, and evaluates other considerations such as costs, operational factors, safeguards against loss of data quality and safeguards against loss of efficiency and/or quality in other Statistics Canada programs. The suitability of alternative sources (i.e., administrative data) is also considered as part of this process.

Key content additions for the 2024 Census Test are:

• Household composition and marital status
  • Modifications have been made to the format of the household composition and marital status module to include new questions and changes to the response options and question wording to reduce respondent burden, use inclusive language, and to better reflect changes in Canada’s social context.
• Second address
  • A two-part question has been added to identify people who live or stay at more than one address, including children in joint custody or students who live elsewhere while studying, to improve measures of family dynamics and living arrangements and to better enumerate fluctuating populations, important for municipal and urban planning.
• General health
  • A new question on general health has been included to collect information on the health status of people in Canada, including vulnerable populations and those living in small areas.
• Homelessness
  • A set of three new questions has been included to capture Canadians’ experiences with homelessness and other housing challenges over the past 12 months and to identify people currently in precarious housing situations. These data aim to help inform governments and organizations on levels of homelessness and other housing challenges particularly for rural and hard to reach communities.
• Commuting
  • A new question has been included to collect more detailed data on which days workers typically commute to work to better understand changes in commuting frequencies as many workplaces shift to hybrid models or remote work.
• Childcare expenses
  • The question has been restructured to ask about the amount paid for childcare per child younger than 12 years in the household and to identify any unpaid childcare. To enhance its analytical and policy relevance in the early learning and childcare domain, the scope of the question was changed to include childcare for reasons beyond enabling parents or guardians to work.

Necessity and Proportionality

The collection and use of personal information for the 2024 Census of Population Test can be justified against Statistics Canada’s Necessity and Proportionality Framework:

1. Necessity: Statistics Canada's mandate is to ensure that Canadians have access to a trusted source of statistics that meet their highest priority information needs. The efficient production of relevant, accessible, high-quality statistics helps to ensure that the Canadian economy functions efficiently and our society is governed effectively. As part of this mandate, Statistics Canada is responsible under the Statistics Act (R.S.C., 1985, c. S-19) for conducting the Census of Population every five years. By law, the government (by an Order-in-Council) prescribes the questions to be asked in the census. By the same law, each person is required to provide the information requested in the census and Statistics Canada must protect the confidentiality of the personal information provided by respondents. The next census will be conducted in May 2026. Being a major statistical operation, the census presents a formidable challenge for Statistics Canada and requires careful planning to ensure its successful completion. An essential element to ensuring this success is the conduct of a census test, which traditionally is scheduled two years prior to the census. The content proposed for the census is the result of a Census Content Determination Framework that begins with consulting external stakeholders on their uses of the data and related information needs including the requirements for relevance and quality, followed by an assessment of the Canadian context which encompasses respondent burden and societal privacy concerns, and an assessment of Statistics Canada considerations including costs, operational factors, data quality and safeguards against loss of efficiency and/or quality in other Statistics Canada programs.

   The specific content under consideration responds to high priority data requirements identified through consultation, for example:

   • Household composition and marital status
     • The family and household data resulting from this question are essential for all levels of government to develop effective policies and legislation regarding the composition of families and households. Data help identify, plan, evaluate and administer federal, provincial and local programs for childcare, schools, support for people with disabilities, older adults living alone, one-parent families and other vulnerable populations.
   • Second address
     • The purpose of this question is to fill a data gap for a variety of census data users (urban planners, municipalities, provincial and federal departments) who require accurate population counts in their regions in order to better plan the delivery of services and programs. This information would also reflect family dynamics and living arrangements, for example, by enumerating populations who spend time at multiple addresses, including children in joint custody or students who live elsewhere while studying.
   • General health
     • General health assessments are unavailable from population-level administrative data sources and although general health assessments are commonly included in health surveys, those surveys have limited sample sizes and population coverage. Including a general health question in the Census would provide necessary health information for key specific and/or vulnerable populations, which can assist in health care planning and policies. General health assessments are unavailable for the entire population which has resulted in significant data gaps for key vulnerable populations (e.g., First Nations people living on reserves, individuals with disabilities, and children and youth living in unique family structures).
   • Homelessness
     • These data will help fulfill reporting requirements under the National Housing Strategy Act, which recognizes housing as a human right and commits the federal government to further the progressive realization of the right to adequate housing.
   • Commuting
     • The Census is the only cross-national source of place of work and journey to work data. It is heavily used by provincial and municipal governments across Canada, in addition to researchers within various organizations.
     • Place of work and journey to work data support numerous federal, provincial, and municipal programs related to infrastructure and public transportation, as well as such things as sustainable development and environmental goals.
   • Childcare expenses
     • Childcare has recently emerged as a critical social policy in Canada. In December 2022, Bill C-35, An Act respecting early learning and child care in Canada, (the Canada Early Learning and Childcare Act)^Footnote3 was introduced in the House of Commons. Bill C-35 declares that the Government of Canada has as a goal to support the establishment and maintenance of a Canada-wide early learning and childcare system where families of varying incomes have access to affordable, inclusive and high-quality early learning and childcare programs and services regardless of where they live.
     • Along with the income data obtained from personal income tax and benefit records through data integration, these questions help determine the disposable income for Canada’s official measure of poverty—the Market Basket Measure.

   Note also that the 2024 Census of Population Test will collect data on sex at birth and gender, which was introduced in the 2021 Census so that more Canadians could see themselves in their census data, and to meet new data needs and adapt to societal changes. It allowed for the dissemination of information on transgender and non-binary populations. The historical question on “sex” was modified in 2021 to ask about “sex at birth”, for added precision.

   StatCan has assessed the Gender-based Analysis Plus implications with respect to the 2026 Census of Population cycle. The Census is representative of Canada’s entire population and data will be collected and presented in a way that allows for gender-based analysis. Data will be presented separately for males and females and by other identity characteristics. Prior to 2016, the census collected sex with binary options of male or female. In the 2016 Census, respondents who could not respond in a binary fashion were asked to leave their answer blank and provide a comment at the end of the questionnaire. After consulting with LGBTQ2+ organizations and conducting focus groups with transgender, non-binary and cisgender individuals, the 2021 Census collected sex at birth and gender. In preparation for the 2026 Census, Statistics Canada will consult with LGBTQ2+ organizations. The results of these discussions will contribute to content determination for the 2026 Census.

   More information on how Statistics Canada balances the protection of confidentiality with the needs for disaggregated census data is available in the Age, Sex at Birth and Gender Reference Guide, Census of Population, 2021.

2. Effectiveness – Working assumptions: The collection and use of this data during the 2024 Census Test will be effective in meeting Statistics Canada's objectives because it is necessary to ensure that the 2026 Census of Population produces relevant, high priority, statistically meaningful information.

   Many of the content changes proposed for the 2026 Census and that will be tested in 2024, affect smaller population groups such as hybrid workers, children in joint custody and students, Veterans, visible minorities, Canadians in housing need, Indigenous populations etc. To be effective, the content test needs to accurately discern statistical differences between 2021 content (benchmark) and modified content to ensure that proposed content can produce relevant and statistically meaningful information.

3. Proportionality: Data from the Census of Population Program provide a comprehensive socioeconomic portrait of Canada's population over time that supports key requirements for policy areas, including labour market conditions, immigration, Indigenous peoples, education, mobility, skills development, official languages, housing and income. This information is vital to all levels of government, the private sector, academia, and non-profit organizations for decision-making and for developing and monitoring of programs and policies. To ensure the efficient and successful conduct of the 2026 Census of Population, Statistics Canada is conducting the 2024 Census Test, which will comprise a sample of approximately 198,000 households across Canada. The test serves multiple purposes, from testing improved or new questions to testing improvements to collection tools and procedures. The sample size and the complex test design were determined in such a way as to ensure that all the test objectives are met, while minimizing as much as possible the respondent burden and the cost. Smaller qualitative tests were previously conducted to help minimize the sample size of the 2024 Census Test. The test is the perfect opportunity to gather data that supports the analysis of the impacts of proposed content changes on data quality, response burden, etc. The data provides a solid foundation upon which Statistics Canada’s final recommendations for census content changes are based, and upon which Cabinet can base their decision on the final content for the next census cycle.
4. Alternatives: The Census of Population is one of the only sources of information for small geographic areas based on the same statistical concepts for the entire country, and the only source of information for many socioeconomic characteristics. The most efficient method for effectively testing possible changes to the Census questionnaire is the mandatory sample survey to be conducted in May 2024.

   Prior to conducting the 2026 Census, extensive testing will be done to assess changes to content, communication materials, field procedures, and collection methodologies. The 2024 Test is designed to accurately measure respondent behaviours to changes in content, field and collection methodologies. Mandatory census tests provide the most accurate impact measurement when studying small sub-groups of the population.

   Voluntary tests in 2024 would increase the chance of inaccurate or inconclusive findings for many of the proposed changes to questionnaire content. If responding to the test was voluntary, non-response bias could occur, specifically for smaller population groups. Similar concerns were raised in the context of the 2011 National Household Survey (NHS). The 2011 NHS demonstrated that in a voluntary context, some respondents tend to skip questions or abandon more often, amplifying non-response for certain questions, especially those closer to the end of the questionnaire. These questions could be more impacted, leading to wrong conclusions being drawn, and, as a result, recommendations for new or changed content for the 2026 Census being based on incomplete test results. In addition, without reducing the risk of non-response bias, a voluntary test would require a larger sample size to account for total non-response. Based on a preliminary design, a significant number of additional dwellings would need to be part of the test, and with anticipated higher proportion of non-response, there would be an increase in the number of reminders and contact attempts for selected households.

   Further, although Statistics Canada continues to explore the use of new administrative sources to replace data collection from respondents, the research has shown the sources of administrative data currently available are not adequate to replace collection of the new content under consideration for the 2026 Census of Population.

Mitigation factors:

The 2024 Census Test will adhere to all Statistics Canada policies on collection, processing, and dissemination of information.

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, including the following that relate to this specific activity.

Storage

Respondents' personal information is transmitted directly to Statistics Canada via secure, web-enabled electronic questionnaires, or, in the case of paper questionnaire formats, through the mail directly to a Statistics Canada secured processing site, where the information is captured, and an electronic record created.

Records are stored in a response database containing household responses, including personal information to perform record linkages to the 2021 Census of Population response files and to tax files.

All electronic records are stored within the secure Statistics Canada information technology environment. Paper questionnaires are securely stored within the Statistics Canada access-controlled processing environment.

Records are retained for a period of five years after the completion of the Census Test and then are destroyed.

As well, Statistics Canada complies with the Policy on Government Security and the Policy on Service and Digital.

Processing and analysis

The Agency's longstanding linkage experience has shown that particular combinations of personal information elements can be used to identify individuals in different data sources with a very high level of confidence, and thus link individuals across various files.

The following personal information will be collected and used to perform record linkages:

• First and last names (collected)
• Date of birth (collected)
• Sex/Gender (collected)
• Full civic address (from frame and collected)
• Phone number (from frame and collected)
• Mobility one and five years (collected)
• Country of citizenship (collected)
• Place of birth (collected)
• Immigrant status (collected for respondents getting Control questionnaire or Test questionnaire version 2; added through linkages for respondents getting Test questionnaire version 1)
• Year of immigration (collected for respondents getting Control questionnaire or Test questionnaire version 2; added through linkages for respondents getting Test questionnaire version 1)
• Frame identifier (from frame)
• Relationship to Person 1 (collected)
• Marital Status (collected)
• Common-law Status (collected)

The linkage of Census of Population Program data and 2024 Census Test data will be used in statistical analyses to evaluate the impact of new or modified questions of the questionnaire by comparing the 2024 Census Test to other existing sources or to the data collected in the 2021 Census. The linkage file will be used only within Statistics Canada, for methodological research, development, and processing. No statistical estimates will be published from the linked data.

Personal identifiers such as name, phone number and address (excluding postal code) will be removed from linked files and replaced with an anonymized statistical identifier.

Access

Access to any confidential data held by Statistics Canada is closely monitored and restricted to designated individuals as per the program's operational requirements. Employees are required to provide the justification for access and obtain the necessary approval. Furthermore, all access permissions are only applicable for a set duration of time and must be regularly renewed including justification for re-approval.

The response database for the 2024 test has not yet been created. The number of employees with access to the 2024 Census Test response database will vary depending on the timing of 2026 Census preparation activities and the need for staff to have access for their job function. Access to the identifying information (names, address, and phone numbers) within this database will be controlled and limited to a small set of staff requiring such access. Most staff who will analyze the data will not have access to any identifying information within the database.

Dissemination

Data collected during the 2024 Census Test will be used for Statistics Canada's analytical purposes only and will not be publicly disseminated. Statistics Canada will not disclose personal information from the 2024 Census Test without the consent of the respondent.

Openness

It is the policy of Statistics Canada to provide all respondents with information about: the purpose of a survey (including the expected uses and users of the statistics to be produced from the survey), the authority under which the survey is taken, the mandatory or voluntary nature of the survey, confidentiality protection, the record linkage plans and the identity of the parties to any agreements for sharing of the information provided by those respondents, where applicable.

For the 2024 Census Test, this information is provided in the letter of invitation to complete the Census Test questionnaire, in the electronic questionnaire itself and in Frequently Asked Questions (FAQs) accessible through the Census website and used by Census Help Line operators to respond to callers’ questions.

This supplemental PIA will be publicly available on the Statistics Canada website as an addendum to the Generic PIA. In addition, Statistics Canada has prepared FAQs and speaking points to assist its internal staff to deal with inquiries from the public regarding the Test.

Other factors:

This section identifies other privacy considerations related to the 2024 Census Test.

Use of administrative data for collective dwellings

Statistics Canada attempts to collect the same information from residents in collective dwellings that is collected from other Canadians and has used various collection approaches in the past. The 2024 Census Test will repeat the methodology used for the 2021 Census whereby the administrators of collective dwellings are required to answer a series of questions about the facility or establishment and complete the Census Test questionnaire for residents. For the 2024 Census Test, administrators will primarily use the electronic questionnaire, whereas data for collective dwellings without administrators will be collected by field enumerators. If the administrator is unable to complete the Census Test questionnaire online, a Census Test employee will follow up by phone or in-person. Residents will also be able to self respond if they wish using the electronic questionnaire.

Test of “informed replacement” letter

As part of the 2024 Census Test, with the goal of reducing response burden, a sample of approximately 8,700 respondents will be provided with an “informed replacement” letter with an offer by Statistics Canada to complete their questionnaire using data already provided to the government. Respondents can still choose to complete their questionnaire themselves if they prefer. The letter states that “Statistics Canada will automatically use information your household has already provided to other government sources about the number of residents, their age, and sex at birth or gender”, and includes a link to the Census website where respondents are provided with an exhaustive list of the administrative data that would be used should the dwelling choose this option. Qualitative testing for the content of this letter demonstrated that the sources of administrative data should be listed on the Census website rather than in the text of the letter itself. The best way to communicate the administrative data sources will continue to be tested. The results will be used to help evaluate the social acceptability and effectiveness of this approach for future censuses (post 2026 cycle).

Cellular phone text message and landline voice broadcast reminders

In 2021, as a final reminder before starting field follow-up activities with non-respondents, the census used text messaging, voice broadcast, and email to remind Canadians living in mailout areas (where mail delivery to a civic style address is possible) to complete their Census. Non-responding dwellings with cellular phone numbers received a single text message reminder. Non-responding dwellings associated only with a landline phone number received a voice broadcast reminder. The census also tested the use of email addresses collected during the 2016 Census (updated by the Labour Force Survey and/or the 2019 Census Test when possible) to send a reminder to non-responding dwellings for which no phone number was listed on the census file.^Footnote4

Results from the 2021 Census demonstrated that there was a clear increase in online responses for non-responding dwellings that received the text message or the voice broadcast reminder. On the other hand, email reminders were not effective to increase self response in the 2021 Census. Based on these results, the census explored opportunities to expand the use of text and voice broadcast messages. To determine email reminders’ full potential, additional testing is required but is being postponed indeterminately due to current operational limitations (maximum number of email reminders that can be sent per day is insufficient). 

Consultations with 2021 Census respondents and non-respondents revealed that some mailout households receive their census invitation letter late because they do not check their community mailboxes regularly. An early text reminder could incite more Canadians to check their mailboxes, complete their census questionnaire earlier, and avoid receiving additional reminders. During January 2023 qualitative testing, participants were asked about their initial reaction to such a text message.  Most of the reactions were quite neutral, while some suggested that it would prompt them to check their mailboxes and felt that it added significance to the letter. Therefore, the 2024 Census Test will attempt to measure the impact of a text message on self-response. On May 16 and 17, 2024, all non-responding dwellings in-scope for the test (approximately 57,000 dwellings) will receive a text message. This timing has been chosen to encourage households to retrieve their census invitation letter from their mailbox close to Census Test reference day (May 14) while accounting for operational capacity. Dwellings selected for the test that have not responded around the end of May could also receive a text reminder on June 3, 2024 (approximately 36,000 dwellings). Additionally, the test will be used to measure the impact of a second text message on self-response. Note that some non-responding dwellings will only receive the June 3rd text reminder because of the design of the test and that approximately 20,000 dwellings associated with a landline phone number will receive a voice broadcast message.

Another area where the Census is considering expanding the use of text message and voice broadcast is outside the mailout areas. Non-responding dwellings located outside mailout areas have their invitation letters delivered by census staff. The only contact with these dwellings prior to the field follow-up activities is a postcard sent to all dwellings to thank respondents and ask non-respondents to complete their census questionnaire as soon as possible. The postcard has not demonstrated to have a significant impact on self-response. The 2024 Census Test will attempt to measure the impact on self-response of sending a text or a voice broadcast reminder to non-responding dwellings. On May 26, 2024, non-responding dwellings outside the mailout areas in scope for the test (approximately 2,000 dwellings) will receive a text or a voice broadcast reminder. The type of reminder received by a dwelling will depend on the type of telephone number present on the census file.

Statistics Canada’s website will provide answers to questions related to the collection of phone numbers and the use of text message and voice broadcast campaigns. Note that on the third mail reminder (only in mailout areas), non-respondents will be informed that they can subsequently be contacted by Statistics Canada by phone, text message, email, or in person.

Statistics Act employee recruitment

Prospective candidates for Census Field Operations are required to complete an application through the secure, web-based Census Online Recruitment Application. The personal information associated with the application is stored in the Collection Management Portal (Statistics Canada's secure corporate tool for field staff), which is addressed in Statistics Canada's Generic PIA. This information includes name, address, contact information, citizenship status, experience, abilities, and references. This information is used by recruiters to screen, test, and interview candidates, as well as to initiate the security clearance process.

In compliance with the Policy on Government Security, all personnel hired for the census must be granted Reliability Status. This process includes verifying personal data, employment history and references. It also involves declaring any criminal convictions for which a pardon has not been granted. A criminal record name check is completed via the Royal Canadian Mounted Police database, and a credit check is conducted by a licensed credit reporting agency. All security checks are performed by personnel security officers on behalf of Statistics Canada. Approximately 600 candidates are expected to undergo security screening for the 2024 Census Test.

Census chatbot:

Statistics Canada will use a new chatbot for the 2026 Census to provide Canadians with timely, accurate, and automatic responses to frequently asked questions and a pathway to a live agent, if needed. The chatbot does not collect personal information and only uses responses that have been written and reviewed by subject-matter experts from Statistics Canada to ensure accuracy. Statistics Canada is developing a separate Privacy Impact Assessment (PIA) for the Census Chatbot which will be tested during the 2024 Census Test. Statistics Canada is committed to using artificial intelligence in a responsible and ethical manner and operates in accordance with governing instruments and frameworks that guide its responsible use including all Government of Canada directives on the responsible use of artificial intelligence.

New tool to retrieve secure access codes:

Respondents are required to provide their secure access code^Footnote5 to complete the Census Test on-line questionnaire. Statistics Canada will test the use of a new on-line tool that enables respondents to retrieve their secure access code using their address. Previously, respondents could only retrieve their code by calling the Census Help Line. The purpose of this initiative is to reduce burden for respondents by offering an alternative to calling the Census Help Line.

Conclusion:

This assessment concludes that, with the existing Statistics Canada safeguards, any remaining risks are such that Statistics Canada is prepared to accept and manage the risk.