Supplement to Statistics Canada's Generic Privacy Impact Assessment related to the Indigenous Peoples Survey 2022

Date: April 2022

Program manager: Director, Centre for Indigenous Statistics and Partnerships

Director General, Social Data Insights, Integration, and Innovation

Reference to Personal Information Bank (PIB):

Personal information collected through the Indigenous Peoples Survey is described in Statistics Canada's "Special Surveys" Personal Information Bank. The Personal Information Bank refers to information collected through Statistics Canada's ad hoc surveys, which are not part of the regular survey taking activities of the Agency. They cover a variety of socio-economic topics including health, housing, labour market, education and literacy, as well as demographic data.

The "Special Surveys" Personal Information Bank (Bank number: StatCan PPU 026) is published on the Statistics Canada website under the latest Information about Programs and Information Holdings chapter.

Description of statistical activity:

Statistics Canada, under the authority of the Statistics Act^{Footnote 1}, conducts the Indigenous Peoples Survey (IPS) every 5 years on behalf of Indigenous Services Canada, Crown Indigenous Relations and Northern Affairs Canada, and Employment and Social Development Canada. This voluntary targeted survey is a national survey of First Nations people living off reserve, Métis and Inuit. Each cycle of the IPS focusses on a high-priority theme based on new and emerging data priorities for Indigenous peoples, in addition to collecting a consistent set of core variables that can be tracked over time. The 2022 IPS will focus on Indigenous children and families while continuing to provide other essential socioeconomic, demographic, and cultural information, as well as a robust health module.

The survey supports Indigenous Services Canada's mandate ''to support and empower Indigenous peoples'' and aims to provide current and relevant data to inform policy and programming activities in education, employment and health. It is a valuable source of information for Indigenous organizations, communities, service providers, researchers, and governments to improve the well-being of Indigenous peoples.

Also, Employment and Social Development Canada uses information from the IPS to undertake the Nunavut Inuit Labour Force Analysis which provides a detailed analysis of the labour force of the Nunavut Settlement Area to determine the availability, interest and the level of preparedness of Inuit for government employment in accordance with Article 23.3.1 of the Nunavut Agreement. According to Article 23.3.2, the purpose of the analysis is "to assess the existing skill level and degree of formal qualification among the Inuit labour force and to assist in formulating Inuit employment plans and pre-employment training." Article 23 reflects the aspirational objective of increasing Inuit participation in government to a representative level.

Indigenous peoples invited to participate in the 2022 IPS are selected from those who reported having an Indigenous identity or having Indigenous ancestry on the 2021 Census long-form questionnaire. Consistent with the Census, the IPS only covers persons living in private dwellings in Canada. It also excludes individuals living on reserve and specific First Nations communities in Yukon and Northwest Territories, who are instead included in surveys conducted by the First Nations Information Governance Centre.

The survey includes questions on access to services, child care, education and general health. Some questions included in the 2022 survey may be deemed sensitive, particularly for the 15 to 17 year age group, including gender identity, sexual orientation, family history, family separation, victimization, missing and murdered Indigenous women and girls, alcohol consumption and drug use, mental health, suicide, victimization, discrimination, pregnancy and childbirth, basic needs, food security, and the COVID-19 pandemic. The survey content was developed in collaboration with the sponsoring departments and in consultation with National Indigenous Organizations (NIOs) and other Indigenous organizations.

The Nunavut Inuit Supplement questions were developed in partnership with Nunavut Tunngavik Incorporated, the Government of Nunavut (GN), Pilimmaksaivik, and Employment and Social Development Canada. The questions were designed to assess the availability, interest and preparedness of Inuit for government employment in Nunavut, and to eventually increase their representation in government.

Statistics Canada will publish aggregate results in the Daily (the Agency's official release bulletin) summarizing the survey findings along with data tables. These data will be fully anonymized and non-confidential, without any direct personal identifiers, which prevents the possibility of identifying individuals. Indigenous Services Canada, Crown Indigenous Relations and Northern Affairs Canada, and Employment and Social Development Canada will access the data file, with all personal identifiers removed, in the Research Data Centres^{Footnote 2} and will only be permitted to release aggregate results, which are fully anonymized and non-confidential.

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, a supplement was developed for the 2022 Indigenous Peoples Survey due to its sensitive content, and in the context of heightened awareness resulting from Truth and Reconciliation. 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.

Necessity and Proportionality

The collection of personal information for the Indigenous Peoples Survey (IPS) can be justified against Statistics Canada's Necessity and Proportionality Framework:

1. Necessity:
   Statistics Canada's Surveys on Indigenous Peoples program is a national, multi-year, multi-stakeholder program that provides critical data and research for developing effective policies and monitoring progress. The IPS provides information on Indigenous populations that is not available from other data sources. The survey is conducted on a 5-year collection cycle with fixed core content that allows for monitoring of trends, along with rotating thematic content which helps address new and emerging data priorities for Indigenous peoples.
   The information produced through the IPS is used to improve access to high quality services for First Nations, Inuit and Métis, such as Early Childhood Development programs and to increase representation of Inuit employed in government in Nunavut. The survey is run as a cost-recovery project for Indigenous Services Canada and supports their mandate "to support and empower Indigenous peoples".
   The 2022 IPS will focus on Indigenous children and families while continuing to provide other essential socioeconomic, demographic, and cultural information, as well as a robust health module. The 2022 survey theme and content was developed in collaboration with the survey sponsors, Indigenous Services Canada (ISC), Crown Indigenous Relations and Northern Affairs Canada (CIRNAC), Employment and Social Development Canada (ESDC), and in consultation with national indigenous organizations including:
   • Congress of Aboriginal Peoples (CAP)
   • Assembly of First Nations (AFN)
   • Inuit Tapiriit Kanatami (ITK)
   • Métis National Council (MNC)
   • Pauktuutit
   • Native Women's Association of Canada (NWAC)
   • National Association of Friendship Centres (NAFC)
   These consultations with Indigenous organizations highlighted the need for the IPS to collect information on sensitive, but important issues for Indigenous peoples in Canada, such as Missing and Murdered Indigenous Women and Girls, residential school attendance and experienced racism. This information could help with further acknowledgment of these issues and with the path to reconciliation.
   The survey data file, with all personal identifiers removed, will be made available to researchers in the Research Data Centres (RDC)^{Footnote 3} upon approval of requests to access the data for statistical research^{Footnote 4}. Statistics Canada's directives and policies ensure the confidentiality of any data released from the RDC. Only aggregate results, which are fully anonymized and non-confidential, without direct personal identifiers, which precludes the possibility of re-identifying individuals, can be released from the RDC. Individual responses will be grouped with those of others when reporting results 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 protect the confidentiality of individual responses.
   Participants in the survey will be informed that the survey data will be linked to 2021 Census data to provide additional contextual information, and to help reduce respondent burden. Statistics Canada's microdata linkage and related statistical activities were assessed in Statistics Canada's Generic Privacy Impact Assessment.^{Footnote 5} All data linkage activities are subject to established governance ^{Footnote 6}, and are assessed against the privacy principles of necessity and proportionality^{Footnote 7}. All approved linkages are published on Statistics Canada's website^{Footnote 8}.
2. Effectiveness - Working assumptions:
   The 2022 IPS will produce estimates for First Nations, Inuit and Métis at the provincial and territorial level to help advance programs and policies. The survey is conducted on a 5-year collection cycle with fixed core content that allows for monitoring of trends along with rotating thematic content which helps to address new and emerging data priorities for Indigenous peoples.
   The 2022 IPS Nunavut Inuit Supplement is designed to support the federal government's obligation under Article 23 of the Nunavut Agreement to conduct an ongoing Nunavut Inuit Labour Force Analysis (NILFA). It includes a large supplemental sample designed to produce community-level estimates for Inuit aged 15+ enrolled under the Nunavut Agreement.
   The supplemental questions were jointly developed by the NILFA Technical Working Group, including members of Nunavut Tunngavik Incorporated, the Government of Nunavut and the Government of Canada.
3. Proportionality:
   The population for this survey consists of anyone who identified as Indigenous or indicated Indigenous ancestry on the 2021 Census. In order to achieve the desired level of data quality, a minimum sample size was computed. Based on a projected response rate, the sample size for the IPS is approximately 68,000 plus an additional required sample of 5850 specific to the Nunavut Inuit Supplement. To ensure that Indigenous priorities were reflected in the survey content and that it was culturally sensitive and relevant, National Indigenous Organizations (NIOs) were engaged and consulted with the support of the survey sponsors (ISC and ESDC). Additionally, the NIOs and other Indigenous organizations/groups completed a Ranking Questionnaire which allowed them to prioritize the themes and questions that they considered most important and that would be retained. Every effort was made to ensure that the feedback received from these groups was addressed and incorporated where possible. Themes or questions that raised major concerns were revised accordingly. In regards to the sensitive nature of some of the questionnaire modules, NIOs indicated that while these were difficult for respondents to answer, their inclusion in the questionnaire was deemed necessary. Questions were retained based on the data needs of the sponsoring departments and on those expressed by the NIOs that were consulted.
4. Alternatives:
   The IPS is designed to allow for distinctions-based analysis of Indigenous Peoples at the national, provincial and territorial levels. While other surveys include Indigenous populations in their sample, given the relatively small population of First Nations, Métis and Inuit in Canada, those surveys can often only produce pan-Indigenous estimates at the national level. The IPS, which collects information specifically and directly from Indigenous populations is required to gather data on issues that are relevant to First Nations, Métis and Inuit.

Mitigation factors:

Some questions contained in the IPS are considered sensitive as they relate to family history and family separation, smoking, drug use, alcohol consumption, suicide, mental health, discrimination, victimization, missing and murdered Indigenous women and girls, basic needs and food security. 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, as well as with the following measures:

• Helpline resources from across Canada will be available to respondents in the electronic questionnaire help button.
• Escape buttons will allow respondents to skip the more sensitive victimization module of the questionnaire.
• Interviewers will be trained on and have access to information on mental health supports to provide to respondents who share information or show signs of distress triggered by sensitive questions.
• For respondents 14 years of age and under, the survey is completed by the adult most knowledgeable about that child. For youth 15 to 17, although parental permission is not required, interviewers will be instructed not to complete the survey with this age group if the parent refuses.
• As for all surveys, respondents will be informed through the invitation letter, brochure, promotional and advertising materials, along with the questionnaire and on Statistics Canada's website, that participation is voluntary and of the nature of the survey to inform their decision to participate. For the Nunavut Inuit Supplement target population, some of this information is made available in the four official languages of Nunavut (Inuktitut, Inuinnaqtun, English and French), as required by the Nunavut Agreement.

Conclusion

This assessment concludes that, with the existing Statistics Canada safeguards and 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.

Appendix 1 – Promotional Material

Brochure

Poster