Supplement to Statistics Canada’s Generic Privacy Impact Assessment related to Canadian Housing Survey (CHS)

Date: October 2024

Program manager: Director, Centre for Income and Socioeconomic Well-being Statistics
Director General, Labour Market, Education and Socioeconomic Well-being Branch

Reference to Personal Information Bank (PIB):

Personal information collected through the Canadian Housing Survey (CHS) is described in Statistics Canada’s “Housing Data” Personal Information Bank (PIB).

The “Housing Data” PIB (StatCan PPU 143) is published on the Statistics Canada website under the latest Information about Program and Information Holdings chapter.

Description of statistical activity:

Under the authority of the Statistics Act,^Footnote1 Statistics Canada has been conducting the Canadian Housing Survey since 2018.

Sponsored by the Canada Mortgage and Housing Corporation (CMHC), this voluntary survey which is conducted every two years collects information about housing needs and experiences from a sample of approximately 120,000 Canadian households. The survey provides information on housing conditions and how they may change over time. The content and scope of the questions which include core housing need, dwelling and neighbourhood satisfaction, housing moves, housing aspiration, housing discrimination, and other aspects of well-being related to housing, has been developed in consultation with a broad range of stakeholder including other federal agencies, specifically:

Canadian Mortgage and Housing Corporation (CMHC)
Ministry of Housing, Infrastructure and Communities of Canada, and
Office of the Federal Housing Advocate.

In June, 2019, Parliament passed the National Housing Strategy Act which affirmed for the first time in federal legislation that housing is a fundamental human right in Canada. In response, the CMHC created the National Housing Strategy (NHS) which is an $82+ billion plan that aims to strengthen the middle class, cut chronic homelessness in half and fuel the Canadian economy. The human rights-based approach to housing adopted in the Act and the NHS underlines that housing must provide more than four walls and a roof. It should be equitable and accessible to all without discrimination based on gender, race, Indigenous identity, disability, faith, place of birth, age, family status, sexual orientation, gender identity or other factors.

To support new housing data and research under the NHS, CMHC engaged Statistics Canada to expand the Canadian Housing Survey (CHS) to include questions on age, sex at birth, gender identity and expression, sexual orientation, immigration and citizenship, ethnic and cultural origins, religion, long-term conditions and disability, and marital status.

The CHS asks that the survey be completed by the household member with the most knowledge of the household's housing situation. This includes minor respondents aged 15-17 years old. Proxy response is accepted for questions about other household members. This allows one household member to answer questions on behalf of any or all other household members.

To reduce the burden on respondents and enhance CHS data, survey responses are linked to the Administrative Personal Income Masterfile (APIM). This allows for accurate personal and household income information. Statistics Canada’s microdata linkage and related statistical activities were assessed in Statistics Canada’s Generic Privacy Impact Assessment.^Footnote2 All data linkage activities are subject to established governance,^Footnote3 and are assessed against Statistics Canada’s principles of necessity and proportionality.^Footnote4 All approved linkages are published on Statistics Canada’s website.^Footnote5

Aggregate survey results will be published in The Daily (the Agency's official release bulletin) summarizing the survey findings along with data tables and Public Use Microdata File (PUMF).^Footnote6 Data is fully anonymized and non-confidential, without any direct personal identifiers, which prevents the possibility of identifying individuals.

Deemed employees^Footnote7 from the CHMC and public university researchers with vetted and approved research projects will access the data file, with all personal identifiers removed, in Statistics Canada's Research Data Centres (RDC)^Footnote8 and will only be permitted to release aggregate results, which are fully anonymized and non-confidential.

There are no data sharing agreements in place for the Canadian Housing Survey.

Reason for supplement:

While the Generic Privacy Impact Assessment (PIA) addresses most of the privacy and security risks related to statistical activities conducted by Statistics Canada including the Canadian Housing Survey, this supplement addresses privacy and security risks associated with the new collection of sensitive sociodemographic information of adults and minors particularly through proxy response for other members of the household. 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^Footnote.

Necessity and Proportionality

The collection and use of personal information for the Canadian Housing Survey can be justified against Statistics Canada’s Necessity and Proportionality Framework:

Necessity:

In keeping with Statistics Canada’s mandate to provide statistical information and analysis on Canada’s socioeconomic conditions that can be used to develop and evaluate public policies and programs, as well as improve public and private decision making for the benefit of all Canadians, the CHS will provide a broad range of stakeholders with an understanding of the housing conditions and experiences of Canadian households, including housing inequalities directly related to sociodemographic inequalities.

The CHS collects a variety of information that speaks to the expenses and other conditions related to housing as they relate to all members of a household, including those that are part of otherwise unidentified minority groups in all housing situations. In response to housing precarity including ongoing affordability problems, there are emergent trends leading to undesired sharing and overcrowding. In the context of the CHS, vulnerable individuals may not be responsible for housing decisions in the household and therefore were not previously represented in statistics derived based solely on the characteristics of the responding member of the household. To fill that gap, the CHS will now request that the respondent answer on behalf of all members of the household. Collection of additional sociodemographic information for other members of the household is necessary to address data needs derived from the National Housing Strategy Act through a rights-based approach to housing research.

There is also a specific need to gather sociodemographic characteristics for minors as they are seldom responsible for making housing decisions and were not generally previously represented in household statistics based on the responding member. Further, to express the depth and variety of housing needs for population groups that are typically underrepresented in household-level statistics, population-level statistics that represent diverse population groups, including those who identify as 2SLGBTQI+, are required. National Point in Time studies have shown that despite comprising only 5 to 10% of all youth, 21% of homeless youth identified as 2SLGBTQI+, and transgender youth experienced even higher rates.^Footnote9 This overrepresentation among young Canadians demonstrates a need for more housing data for these groups. The extent to which minors are impacted by these and other housing issues also needs to be expressed for the survey to fulfil its objective of informing the National Housing Strategy.
Effectiveness - Working assumptions:

To help address new and emerging data priorities, the CHS content was reviewed and updated to reflect the changing data needs of stakeholders. New thematic content modules have been introduced to inform on housing aspirations, discrimination, and harassment. The new content was tested by Statistics Canada’s Questionnaire Design Resource Centre to ensure the concepts were well-understood by Canadians.

In the context of the right to housing, this new content is particularly relevant as it can be disaggregated by the population groups identified in the National Housing Strategy, as a way to specifically demonstrate the impacts on the various demographic groups that have been previously mentioned. Discrimination and harassment are often experienced by racialized and other minority groups and the right to adequate housing dictates that housing must provide protection from harassment, among others, and all people should have equitable access without discrimination. The extent to which minors are impacted by these and other housing issues is an important indicator of housing needs examined in the survey to address the objective of informing the National Housing Strategy and allow for the proper program and policy measures to be adopted to address these issues.
Proportionality:

The sample size of 120,000 dwellings across the 10 Canadian provinces has been assessed by methodologist as required to publish reliable estimates on key indicators including core housing needs of Canadian households for the 10 provinces, and housing markets in select Census Metropolitan Areas.^Footnote10 This sample size also helps to protect the privacy and confidentiality of respondents, particularly the diverse population groups that this survey aims to address.

Respondents aged 15 years and older can respond to the CHS on behalf of themselves and all members of the household. In keeping with Statistics Canada internal policy and consistent with guidance from the Office of the Privacy Commissioner of Canada,^Footnote11 parental or legal guardian consent of eligible minors (15 years and older) will not be sought as it is deemed the minor is reasonably expected to understand the nature of the questions and make an informed decision regarding their participation, the responses, and the use of the personal information provided through the survey.

The public benefits of collecting these sociodemographic characteristics and the subsequent data products that will be derived are expected to inform policies, laws, programs and support services^Footnote12 aimed at improving housing conditions and experiences of Canadian residents and speak to housing equity in the context of the right to housing in Canada including currently unknown housing inequities for vulnerable groups.

While most sociodemographic characteristics are asked for all household members, sexual orientation will only be asked for household members that are 15 years or older. In some cases, persons between the ages of 15 and 17 years could be responding on behalf of the household, or in households of their own. In these cases, not asking the question for this age group could lead to underestimation of housing needs for sexually diverse population groups.
Alternatives:

While alternative data are available on housing conditions, including the Census of Population, these alternatives do not elaborate on individual and household experiences. No other quality data source of self-reported housing experience and sociodemographic characteristics that influence housing experiences currently exists. The CHS is specifically aimed at filling this gap.

Mitigation factors:

Some demographic questions in the Canadian Housing Survey can be considered sensitive, particularly when asked of minors aged 15 or older. 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, of which the following are of particular importance for this initiative, and some additional measures:

Information about the survey, including a copy of the survey questionnaire, will be publicly available on Statistics Canada's website before the start of collection.
Individuals selected to participate in the survey will be clearly informed of the survey's purpose and topics and informed that their participation is voluntary prior to beginning the questionnaire.
The survey questions that relate to housing discrimination, forced moves and lifetime experience of homelessness could be sensitive or triggering for some respondents. Respondents will be informed of the potentially sensitive nature of the survey content via a letter and a survey brochure prior to participation.
A specific response category of “I don’t know how this person defines their sexual orientation” was considered for the sexual orientation question. However, the results of testing indicated that the additional response category was not needed since respondents use the “or, please specify” open text box option to report additional responses such as “I don’t know”. This is consistent with other sociodemographic questions (e.g., gender, population group, ethnic origins or cultural origins, religion etc.)
Information on support services and resources for housing provided by CMHC will be made available to respondents on the survey questionnaire and on Statistics Canada’s website.

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.

Formal approval:

This Supplementary Privacy Impact Assessment has been reviewed and recommended for approval by Statistics Canada’s Chief Privacy Officer, Director General for Modern Statistical Methods and Data Science, and Assistant Chief Statistician for Social, Health and Labour Statistics.

The Chief Statistician of Canada has the authority for section 10 of the Privacy Act for Statistics Canada, and is responsible for the Agency's operations, including the program area mentioned in this Supplementary Privacy Impact Assessment.

This Privacy Impact Assessment has been approved by the Chief Statistician of Canada.

Footnotes

Footnot 1

Paragraph 3(a) of the Statistics Act mandates Statistics Canada to collect, compile, analyze, abstract and publish statistical information relating to the commercial, industrial, financial, social, economic and general activities and condition of the people. Paragraph 7(1) gives the Chief Statistician the authority to prescribe the rules, instructions, and requests for information for conducting the work and business of Statistics Canada, and Paragraph 8(1) provides the Chief Statistician the authority to determine whether a request for information is mandatory or voluntary.

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Footnote 2

See:

Section 1: Overview - 1.6.1 GSBPM 5.0 - Phase 5. Process Phase - Phase 5.1. Integrate data
Section 3: Analysis of the Personal Information Elements for the Program – Identifiers - A – Direct personal identifiers
Section 5: Privacy Compliance Analysis - Principle 2: Purpose - Principle 3: Consent - Principle 4: Limiting Collection - Principle 5: Limiting Use, Disclosure and Retention - Principle 8: Openness

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Footnote 3

See: Directive on Microdata Linkage

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Footnote 4

See: Principles of Necessity and Proportionality

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Footnote 5

See: Approved microdata linkages

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Footnote 6

PUMFs contain anonymized, non-aggregated data and are governed by the Statistics Canada Open Licence.

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Footnote 7

Sub-sections 5(2) and 5(3) of the Statistics Act make provision for the use of persons or contractors, as well as federal public servants, to carry out any function or perform work pursuant to the Statistics Act. Similarly, section 10 of the Act allows for arrangements with the government of a province or territory to use provincial/territorial officers, or their contractors, to carry out any power or duty under the Act. These persons are deemed to be employed under the Statistics Act while performing this service. Further, the mandate of Statistics Canada, as set out in section 3 of the Act, includes the requirement "to collaborate with departments of government (federal, provincial and territorial) in the collection, compilation and publication of statistical information". In fulfilling its mandate and in order to provide improved statistical support to departments for policy development, Statistics Canada may use the services of employees of those departments to carry out statistical work that requires access to protected information. In all cases, as deemed employees of Statistics Canada, such individuals are subject to the same confidentiality obligations and penalties under the Statistics Act as are all Statistics Canada employees.

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Footnote 8

RDCs are covered under Statistics Canada's Generic Privacy Impact Assessment (5.5.9 Confidentiality measures at Statistics Canada, 5.5.12 Access to confidential information by researchers as deemed employees of Statistics Canada; and Threat Risk Assessment (TRA) Grid U: Statistics Canada Research Data Centres).

Information on RDCs and RDC projects are published on Statistics Canada's website at the following links: Research Data Centres, List of RDC active projects.

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Footnote 9