Date: September 2020
Program managers: Director, Centre for Social Data Integration and Development
Director General, Census Subject Matter, Social Insights, Integration and Innovation
Reference to Personal Information Bank (PIB)
Not applicable as there are no direct personal identifiers being collected and retained.
Description of statistical activity
In the context of the COVID-19 pandemic and the significant disruption in households across Canada, Statistics Canada is conducting the Survey on COVID-19 and Mental Health, under the authority of the Statistics Act, on behalf of the Public Health Agency of Canada (PHAC). The purpose of the survey is to gather information that will help governments assess the impacts of the pandemic on Canadians' mental health and well-being, and develop strategies to address these impacts. These could include programs and services for Canadians, namely vulnerable Canadians and their families. In addition, the data will provide insights on how the restrictions and provincial lockdowns have led to or exacerbated symptoms related to mental health. They can also be used to analyze the longer-term impacts of COVID-19 on mental health.
This voluntary household survey collects information from individuals aged 18 years and older who live in Canadian provinces and the territorial capitals. Topics include mental health behaviours and symptoms associated with depression, anxiety and post-traumatic stress disorder (PTSD), suicide risk, parenting style, substance use, household violence and general mental health. In addition, information such as age, gender, postal code, email address, indigenous identity, visible minority status, immigration and citizenship, education and income will be collected. Reponses will be aggregated and processed to ensure that no individual can be identified.
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, this supplement describes additional measures being implemented due to the sensitivity of the information being collected. The Survey on COVID-19 and Mental Health will be collecting information on mental health and well-being, which is contextually rendered even more sensitive while collected alongside personal information such as gender identity. This SPIA also describes how Statistics Canada has accounted for the unique impact to vulnerable populations when designing and deploying this survey, and integrates relevant principles of the Office of the Privacy Commissioner's Framework for the Government of Canada to Assess Privacy-Impactful Initiatives in Response to COVID-19.
Necessity and Proportionality
The collection and use of aggregated responses and personal information for the Survey on COVID-19 and Mental Health can be justified against the following four-part test from Statistics Canada's Necessity and Proportionality Framework:
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Necessity: Given the unprecedented nature of the COVID-19 pandemic and the measures put in place to contain it, the extent of the impacts on mental health and other aspects of life within households are currently in great part unknown. A quick and timely assessment of the mental health and well-being of Canadians will help inform government decision-making in order to support vulnerable Canadians and their families during this pandemic. In addition, the information will help governments assess how the COVID-19 restrictions and provincial lockdowns have led to or exacerbated symptoms of depression and PTSD, suicide risk, substance use, parenting style and household violence, and help inform future decisions.
The survey data file, without direct identifiers, will be retained as long as required for statistical purposes, in order to conduct analysis of long-term impacts.
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Effectiveness (Working assumptions): Due to the urgent need for the information, a short questionnaire was developed that follows Statistics Canada's processes and methodology in an accelerated manner to produce timely results. The survey will be administered using a self-reported electronic questionnaire. A random sample of households from Statistics Canada's survey frame will receive an invitation letter to complete the survey and be provided with a secure access code to access the survey on Statistics Canada's secure survey infrastructure. Interviewers will follow up after three weeks with households that have not responded, to reiterate the invitation and follow a protocol to randomly select someone in the household (age order selection) ages 18 and older, to respond to the survey. The collection period will be approximately two months. All Statistics Canada directives and policies for the development, collection, and dissemination of the survey will be followed, and survey responses will not be attached to respondents' addresses or phone numbers. The data will be representative of population and may be disaggregated by province, ethnicity, gender, age groupings, etc.
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Proportionality: Data on mental health, substance use and household violence are highly sensitive, and may be amplified due to the recent COVID-19 pandemic isolation procedures. As such, experts at Statistics Canada and PHAC have been consulted on the scope and methodology of the survey. Wherever possible, questions about mental health and well-being from existing surveys have been used. These questions were taken from the Canadian Community Health Survey (CCHS), the Mental Health Survey (MHS), and the General Social Survey – Victimization (GSS). These questions have previously undergone qualitative testing, and the results of this survey could be compared to these other surveys, allowing for improved interpretation of the results.
All the data to be collected are required for the purpose of the survey as described above. Careful consideration was made for each question and response category to ensure that it would measure the research questions and help inform future decisions related to mental health and the COVID-19 pandemic.
The sample size of 18,000, which will represent people living in each province and in the three territorial capitals, has been assessed as the minimum required to meet quality estimates of the collected data. Increasing the sample size would not necessarily mitigate data findings for vulnerable populations.
Statistics Canada directives and policies with respect to data collection and publication will be followed to ensure the confidentiality of the data. Individual responses will be grouped with those of others when reporting results. Individual responses and results for very small groups will not be published or shared with government departments or agencies. This will also reduce any potential impact on vulnerable populations or subsets of populations, as the grouping of results will make it impossible to identify individual responses. As permitted by the Statistics Act, with consent of individual respondents, survey responses may be shared with PHAC strictly for statistical and research purposes, for example, to aid in future policy decisions for the pandemic, and in accordance Statistics Canada's security and confidentiality requirements.
The benefits of the findings, which are expected to support decision making at all levels of government aimed at improving mental health and well-being are believed to be proportional to the potential risks to privacy.
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Alternatives: Currently, there are no other surveys that gather information on the impact of the COVID-19 pandemic on the mental health and well-being of Canadians that describe these conditions by provinces and territorial capitals. The possibility of using crowdsourcing or web-panel survey methodologies was explored. However, based on discussions between mental health and methodology experts within Statistics Canada and PHAC, it was determined that a survey with at least 18,000 units was necessary to produce reliable and accurate results by provinces and territorial capitals. Releasing data at these aggregated levels will reduce the potential to identify impacts on vulnerable populations, subsets of populations, and groups.
Mitigation factors
Some questions contained in the Survey on COVID-19 and Mental Health can be considered sensitive as they relate to an individual's mental health and well-being, but the overall risk of harm to the survey respondents has been deemed manageable with existing Statistics Canada safeguards as well as with the following measures:
Mental Health Resources
Transparency
Prior to the survey, respondents will be informed of the survey purpose and topics, allowing them to assess whether they wish to participate. Topics listed will include: behaviours and symptoms associated with depression, anxiety and post-traumatic stress disorder (PTSD), suicide risk, pressure on parents, substance use, household violence, as well as general mental health. This information will be provided via invitation and reminder letters, and will be reiterated at the beginning of the questionnaire. Respondents will also be informed, in both invitation and reminder letters as well as in the questionnaire itself, that their participation is voluntary before being asked any questions. Information about the survey, as well as the survey questionnaire, will also be available on Statistics Canada's website.
Confidentiality
Individual responses will be grouped with those of others when reporting results. Individual responses and results for very small groups will never be published or shared with government departments or agencies. Careful analysis of the data and consideration will be given prior to the release of aggregate data to ensure that marginalized and vulnerable communities are not disproportionally impacted. As permitted by the Statistics Act, survey responses may be shared with PHAC strictly for statistical and research purposes, in accordance Statistics Canada's security and confidentiality requirements, and only with the consent of the respondent. The postal code will be used to derive the province or territory of the respondent and could also be used to identify regions that have been more impacted by the pandemic. It will not be used to identify respondents as only aggregated data will be released. The email address may be used to send out survey invitations for participation in a follow-up survey or other mental health surveys. It will be removed and separated from the final data file and it will not be used to identify respondents.
Conclusion
This assessment concludes that, with the existing Statistics Canada safeguards and additional mitigation factors listed above, 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.