Supplement to Statistics Canada's Generic Privacy Impact Assessment related to 2022 Mental Health and Access to Care Survey

Date: February 3, 2022

Program manager: Director, Centre for Population Health Data

Director General, Health, Justice, Diversity and Populations Branch

Reference to Personal Information Bank (PIB):

Personal information collected and used in the Mental Health and Access to Care Survey is described in Statistics Canada's "Health Surveys" Personal Information Bank. The Personal Information Bank refers to personal information that is related to participants of health surveys conducted by Statistics Canada.

The "Health Surveys" Personal Information Bank (Bank number: StatCan PPU 806) is published on the Statistics Canada website under the latest Information about Programs and Information Holdings chapter.

Description of statistical activity:

Statistics Canada is conducting the Mental Health and Access to Care Survey (MHACS) under the authority of the Statistics Act. The purpose of the MHACS is to collect information about the mental health status of Canadians, as well as their access to and need for services and supports, whether formal or informal. This voluntary survey also intends to assess the impact of the COVID-19 pandemic on population health as well as evaluate changes in patterns of mental health, service use and functioning in the last ten years.

A master microdata file will be produced and made available in Statistics Canada's Research Data Centres (RDC)Footnote 1. A subset of the master microdata file which contains only information of respondents who have consented to share their information, called the share file, will be made available to the Public Health Agency of Canada (PHAC), Health Canada (HC), the Institut de la statistique du Québec (ISQ) and provincial and territorial ministries of health.

The sample size is 40,000 Canadians aged 15 and over, as of March 1, 2022, living in private dwellings in the 10 provinces. Individuals living in the territories, in institutions, and on First Nations reserves are excluded from the sample. Full-time members of the Canadian Armed Forces are also considered out of scope for this survey. The sample will be composed of randomly-selected individuals who responded to the Census 2021 long questionnaire, with stratification by population group (South Asian, Chinese, Black, Filipino, and other), gender, and age groups (15-24, 25-44, 45-64 and 65+).  A general random selection of individuals in the 10 provinces cannot achieve the same level of precision without a substantial increase of the sample size.

This voluntary household survey collects information about symptom-based assessment of DSM-IV lifetime and 12 month mental disorders (depression, bipolar disorder, social phobia, generalized anxiety disorder, alcohol and other substance use and dependence), mental health service use and perceived need for care, positive mental health, suicide ideation and attempts, functioning, chronic conditions, medication use, and health behaviours such as smoking, physical activity, social support, childhood experiences of maltreatment (for respondents aged 18 and over), and work stress.

In addition, demographic information such as age, gender, postal code, Indigenous identity, population group, immigration and citizenship, education and income will be collected, as well as email address for contact information. Responses will be aggregated and processed to ensure that no individual can be identified.

To further reduce respondent burden, record linkage to tax data will be used to provide total household income for all respondents.  Respondents will be informed that Statistics Canada will link their data to tax data. Furthermore, respondents will be asked to provide their consent to share their linked tax data with the Public Health Agency of Canada, Health Canada and provincial and territorial ministries of health, and for Quebec residents, the Institut de la statistique du Québec.  Respondents will be asked in a separate statement for consent to share their survey response data with the Public Health Agency of Canada, Health Canada and provincial and territorial ministries of health (for Quebec residents, the Institut de la statistique du Québec) for statistical and research purposes. No other immediate requirements for linking results from the MHACS to other administrative datasets, surveys or the Census have been identified. However, given the importance of mental health for social and economic recovery from the pandemic, there is a potential need to have data on mental health impacts in the future. Any requirements for record linkage would follow established procedures for approval from the Chief Statistician and a record linkage rationale would be provided. If approved, all record linkages would be performed within Statistics Canada's secure Social Data Linkage Environment. Any data products released will be based on aggregated responses 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, a portion of the survey respondents being minors, and targeted oversampling of population groups (South Asian, Chinese, Black, Filipino, and other). 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. The Mental Health and Access to Care Survey will collect information on mental health as well as sensitive personal information such as gender identity. This supplement describes how Statistics Canada designed and developed this survey while taking into account the possible impact to vulnerable populations, and integrating relevant principles of the Office of the Privacy Commissioner of Canada'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 personal information for the Mental Health and Access to Care Survey can be justified against Statistics Canada's Necessity and Proportionality Framework:

  1. Necessity:
    This is the third iteration of the survey (previous collections were in 2012 and 2002). Since it has been 10 years since the last survey, the information collected in this survey will provide new data to analyze the overall mental health of Canadians, as well as guide decision-making about the development and funding of targeted programs. The findings will support decision-making at all levels of government and improve knowledge and understanding of the impact of the COVID-19 pandemic on the mental health, functioning and determinants of health of Canadians. It will also help inform government decision‐making and policy development in order to support vulnerable Canadians and their families dealing with mental health issues. Survey results regarding the unmet need for mental-health services will also help guide decisions about which parts of the mental-health services system need to be improved, where awareness and treatment programs are most needed, and how such targeted treatment programs should be developed.
    The demographic data collected will be used for analysis of subgroups of the survey population. Government of Canada Budget 2021 has committed Statistics Canada to produce more disaggregated data to help better understand health inequities between various population groups Footnote 2. Understanding which groups are at higher risk of mental health disorders and those experiencing challenges accessing mental health services and supports will help guide decisions about where awareness and treatment programs are most needed.
    To evaluate concerns that the pandemic may have had a disproportionately negative impact on certain population groups, the survey is designed to oversample the people identifying with population groups designated as visible minorities. As the 2016 Census showed that roughly 75% of the population in these groups are immigrants, it is expected that the number of immigrants in the sample will indirectly be oversampled as well. To ensure the precision targets are reached for these subpopulations, the 2021 Census long questionnaire sample will be used as a sampling frame. This will allow the selection of targeted individuals from these population groups, which will be much more efficient than selecting dwellings from the general population.
    The master microdata file, in which direct identifiers other than postal code will be removed, will be made available to researchers in the Research Data CentresFootnote 3 (RDC) upon approval of requests to access the data for statistical research. Statistics Canada's directives and policies on data publication will be followed to ensure the confidentiality of any data released from the RDC. Only fully anonymized and non-confidential aggregate results without direct identifiers, which precludes the possibility of re-identifying individuals, can be released from the RDC. Statistics Canada will retain this data as long as required for statistical purposes, in order to conduct analysis of long‐term impacts.
  2. Effectiveness - Working assumptions:
    The content for this survey is a repeat from the previous one; the 2012 Canadian Community Health Survey on Mental Health (CCHS Mental Health). The objective is to measure changes in prevalence rates of mental disorders prior to and during the COVID-19 pandemic. The prevalence rates of these disorders were previously measured in 2002 and 2012. This survey will result in national estimates of mental disorders prevalence for 2022.
    In light of concerns about negative impacts of the COVID-19 pandemic on mental health, mental health care access has been identified as a high priority topic for many partners, including Health Canada and the Public Health Agency of Canada, as was measuring the changes in the disorder prevalence rates since the last major mental health survey in 2012. The 2012 CCHS Mental Health survey had significant portions of service use and unmet need content that could be useful for comparisons during the pandemic. Content was selected to ensure coverage for disorders with the highest social and economic burden. Additional topics covered on these surveys included access to and perceived need for formal and informal support and services, social functioning, disability and other sociodemographic characteristics. In contrast to the 2002 and 2012 surveys, which were administered in person and lasted about one hour, the 2022 MHACS is planned to take 50 minutes to administer by phone interview. The 50 minute questionnaire will ensure that the main objectives related to measuring mental disorders prevalence rates and service use are being met, as well as informing on the changes from 2012.
    As the content was previously administered in 2012, qualitative testing of new content was not required. The 2022 data will be representative of the Canadian population at a national level, and may be broken down (disaggregated) at lower levels of geography or by other characteristics (such as ethnicity or immigration status) when the quality of the estimates is sufficient and the identity of respondents is protected.
  3. Proportionality:
    Questions on mental health and suicidal thoughts included in this survey are highly sensitive. Moreover, mental-health issues may be exacerbated due to COVID‐19 isolation protocols. For these reasons, experts at Statistics Canada, the Public Health Agency of Canada, and Health Canada have been consulted on the scope and methodology of the survey. The questions about mental health and well‐being are repeated from the 2002 and 2012 Canadian Community Health Survey on Mental Health. They were also used in the Canadian Armed Forces and Veterans Mental Health Survey in 2002 and 2013. These questions come from the World Health Organization Composite International Diagnostic Instrument (WHO-CIDI), developed for assessing mental disorders by lay interviewers in population health surveys. This tool is considered the gold standard for assessing the prevalence of mental disorders in community populations. It does not provide a clinical diagnosis. Rather, it asks respondents about their symptoms and feelings. During data processing, responses will be mapped to the criteria set out in the DSM-IV Diagnostic Manual for Mental Disorders.
    The demographic data collected such as the respondent's age, gender, ethnicity, immigration status and education level, are important to include in order to analyse survey results across the population in order to effectively measure progress towards mental health and well-being objectives.
    All the data to be collected are required to fulfill the purpose of the survey as described above. All questions and response categories were carefully considered ensuring they accurately capture the data in question to help inform and develop policies and programs related to mental health and substance use.
    Statistics Canada directives and policies with respect to data collection and publication will be followed to ensure the confidentiality of the data, including the following two measures:
    • Grouping individual responses with those of others when reporting results, and
    • Excluding individual responses and results for small groups (as established by minimum prevalence levels for each variable among these small groups) from information that will be published or shared with government departments or agencies.
    This approach will also reduce any potential privacy risks on vulnerable populations or subsets of populations, as the grouping of results will protect the confidentiality of individuals within a particular subset of the population. As permitted by the Statistics Act and with consent of individual respondents, survey responses may be shared with the Public Health Agency of Canada, Health Canada and provincial and territorial ministries of health, and for Quebec residents, the Institut de la statistique du Québec. The data is to be used strictly for statistical and research purposes, to aid in future policy decisions for the support and planning of mental health resources, in accordance with Statistics Canada's security and confidentiality requirements.
    The privacy measures taken are proportional to the potential risks to an individual's privacy. Proportionality has also been established based on ethical considerations:
    Prior to collection, individuals selected to participate in the survey will be clearly informed that the survey is voluntary. They will also be informed of the survey's purpose and topics, so that they can make an informed decision about whether they want to participate. This notification to all potential participants will be done through the survey invitation letter, which will be mailed to potential respondents prior to collection, and this information will be repeated verbally by the interviewer before any questions are asked. They will also be asked if they agree or not to share their data with the Public Health Agency of Canada, Health Canada and provincial and territorial ministries of health.
    Since the topic of the survey is sensitive and could lead to distress, mental health resources will be mailed to the respondents along with the survey invitation and can be provided verbally by interviewers at any time during the interviews.
    The survey findings will support decision-making related to mental health and well-being at all levels of government. These benefits are believed to be proportional to the invasion of privacy and associated risks.
  4. Alternatives:
    A literature review and consultations with internal and external partners were conducted on existing administrative data and other surveys on mental health of Canadians. While other sources of data were considered, none would provide the information required to fulfill the survey's primary objectives, namely to examine changes in the prevalence of mental disorders, as well as changes in service use and unmet needs for mental health services before and after the pandemic. Other surveys use screening tools, but the proposed measures and ability to compare results to previous iterations represents the gold standard for assessing mental disorders in community populations. Administrative data will be used to provide information on the income of the household in order to reduce respondent burden on the survey.

Mitigation factors:

Some questions contained in the Mental Health and Access to Care Survey are considered sensitive as they relate to an individual's mental health and well-being. The overall risk of harm to the survey respondents is 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:

Mental-Health Resources

As with other mental health surveys conducted by Statistics Canada, mental health resources and contact information will be mailed to respondents along with the survey invitation letter, and can be provided verbally by interviewers at any time during the interviews. Because all interviews will be conducted over the phone with a Statistics Canada interviewer, interviewers will be trained and equipped to offer mental health resources and contact information to survey respondents.

Transparency

Prior to collection, individuals selected to participate in the survey will be clearly informed that the survey is voluntary. They will also be informed of the survey's purpose and topics, so that respondents can make an informed decision about whether they want to participate. This notification to all potential respondents will be done through the survey invitation letter, which will be mailed to potential respondents prior to collection, and this information will be repeated verbally by the interviewer before any questions are asked. The topics listed as part of the survey will include: depression, anxiety, mania, social phobia, suicidal thoughts and behaviours, childhood maltreatment (collected among respondents aged 18 and over only), substance use and problems, disability, general and positive mental health, social support, and access to and use of mental health care services and supports. This information will be provided at the beginning of the questionnaire by the interviewer before the survey commences. Information about the survey, as well as the survey questionnaire, will also be available on Statistics Canada's website.

Confidentiality

Following are the confidentiality measures that will be followed with respect to the use of personal information collected in the Mental Health and Access to Care Survey:

  • Variables that directly identify respondents will be separated from the data files in the first stage of data processing and placed in a secure location with controlled access.
  • 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, with the following exceptions:
    • As permitted by the Statistics Act, and only with the consent of the respondent, survey responses may be shared with PHAC, Health Canada, provincial and territorial ministries of health (for Quebec residents, the Institut de la statistique du Québec) strictly for statistical and research purposes, and in accordance with Statistics Canada's security and confidentiality requirements.
  • Following careful analysis of the data, considerations will be given prior to the release of aggregate data to ensure that marginalized and vulnerable communities are not disproportionally impacted.
  • Postal codes will not be used to identify respondents given that only aggregated data will be released.
  • Respondents will be asked about their email address at the end of the survey and informed that the provision of their email address is voluntary and that it may be used as part of a contact list to send out future survey invitations for participation in a potential follow-up survey or other mental-health surveys, which they can then choose to participate in or not. These email addresses will be removed and separated from the final data file and 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.

Pierre Desrochers
Chief Privacy Officer
Date: February 25, 2022

Eric Rancourt
Director General,
Modern Statistical Methods and Data Science
Date: February 28, 2022

Lynn Barr-Telford
Assistant Chief Statistician,
Social, Health and Labour Statistics
Date: February 28, 2022

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.

Anil Arora
Chief Statistician of Canada