Supplement to Statistics Canada’s Generic Privacy Impact Assessment related to 2023 National Cannabis Survey

Date: June 2023

Program manager: Director, Centre of Population Health Data
Director General, Health Statistics

Reference to Personal Information Bank (PIB):

Personal information collected and used in the National Cannabis 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 National Cannabis Survey (NCS), under the authority of the Statistics ActFootnote 1, on behalf of Health Canada. The National Cannabis Survey was conducted by Statistics Canada in 2018, 2019 and 2020, and was deemed covered under Statistics Canada’s Generic Privacy Impact Assessment. The survey aims to gather detailed information on Canadians' cannabis habits, including their purchasing and use behaviours to provide insights into the types of cannabis products Canadians use, how they access them, and associated impacts on the Canadian economy.

This voluntary household survey collects information from individuals aged 18 years or older living in Canada's ten provinces, who are not members of collective dwellings or living on reserves.

Topics collected in previous cycles of the NCS include cannabis use behaviours, use of different cannabis products, money spent on cannabis products, change in consumption habits due to legalization, symptoms of impaired control over cannabis use, and cannabis use while driving. The 2023 cycle will additionally collect information on cannabis purchasing behaviours from both the legal and illegal markets and growing cannabis at home.

Sociodemographic information such as age, gender, postal code, education, income, general heath, and mental health will continue to be collected, with the additional collection of indigenous identity, population group (racialized population), sexual orientation, and long-term conditions (disability).

A master microdata file will be produced and made available in Statistics Canada’s Research Data Centres (RDC)Footnote 2. A public use microdata fileFootnote 3 may also be produced, following standard disclosure control processes to mitigate against the risk of reidentification.

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 was developed to address the sensitive nature of the new information being collected through the 2023 cycle. This includes information about participation in illegal activities and sociodemographic content including indigenous identity, population group, sexual orientation, and long-term conditions (disability). 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 National Cannabis Survey (NCS) can be justified against Statistics Canada’s Necessity and Proportionality Framework:

  1. Necessity: Collecting data on cannabis use and purchasing patterns since 2018 has been essential to understanding the impact of cannabis legalization in Canada. Data collected are critical for monitoring changes in patterns of cannabis use, its effects on health and social outcomes, how Canadians access cannabis, and the effectiveness of harm reduction strategies such as education and prevention programs. Policy makers, health researchers and other Canadians will benefit from this information to inform evidence-based strategies, policies, and programs related to cannabis use in Canada. Failure to collect this data could lead to uninformed policies that could be harmful to Canadians. For example, without data on purchasing patterns, authorities may not be able to adequately regulate the legal market or ensure that consumers have access to safe and quality-controlled cannabis products.

    The inclusion of questions on sexual orientation, disability, racialized population, and Indigenous identity in the National Cannabis Survey (NCS) is important for a comprehensive understanding of cannabis-related behaviors and experiences within diverse population groups. Even before legalization, certain populations were identified as having higher cannabis use rates and being more at-risk of cannabis related harms and addiction. By collecting data on these sociodemographic variables, the NCS can help in designing targeted prevention and intervention programs that address the specific needs and challenges faced by these populations. For example, if the survey data reveals higher rates of cannabis use among certain communities or vulnerable groups, targeted information campaigns can be developed to raise awareness about the potential risks and provide resources for safer use practices. The data can also shed light on the effectiveness of harm reduction strategies, such as educational programs, in reducing cannabis-related harm. Policymakers can use these insights to refine existing policies or develop new ones that are better aligned with the needs and experiences of diverse populations.

    The inclusion of these sociodemographic variables align with the goals of program evaluation related to the Cannabis Act (C-45), including the Cannabis Act Legislative Review. Furthermore, the NCS aligns with the principles of equity, inclusivity, and accurate representation outlined in the Framework for the Legalization and Regulation of Cannabis in Canada. It aims to address the impacts on the health and cannabis consumption habits of Indigenous peoples, racialized communities, women, and other populations facing barriers to participation or at greater risk of harm. The sociodemographic information collected in the NCS align with the principles of surveillance and monitoring highlighted in the Framework for the Legalization and Regulation of Cannabis in Canada. It acknowledges the need for baseline indicators and population-level monitoring to measure the impact of changes resulting from cannabis legalization. By capturing information on these sociodemographic variables, the NCS contributes to best practices with ongoing surveillance and monitoring efforts, providing essential data to inform evidence-based decision-making, policy development, and retrospective evaluation of the Cannabis Act.

    The inclusion of these variables is necessary to enhance the survey's ability to capture a comprehensive picture of cannabis-related behaviours. By including these variables, the NCS aims to provide insights into potential disparities or variations in cannabis use and behaviors across various sociodemographic groups. This information is important for developing targeted interventions, policies, and programs that address specific needs and challenges faced by different populations. Although direct correlations between population sub-groups and cannabis behaviour may not be established, Statistics Canada will continue to approach the analysis of survey findings with caution and sensitivity, ensuring that analytical interpretations align with current research and avoid causing harm or perpetuating stereotypes.

    Including the variable on sexual orientation in the NCS is in line with the practices of established Statistics Canada surveys collecting data on cannabis use, such as the Canadian Community Health Survey, the Canadian Tobacco and Nicotine Survey, and the Canadian Alcohol and Drugs Survey. Additionally, the Canadian Cannabis Survey conducted by Health Canada also includes this variable. By aligning with these existing surveys, the NCS ensures consistency in data collection practices and facilitates comparisons across different health and substance use surveys in Canada over time.

    To ensure a more comprehensive understanding of cannabis use and purchasing patterns in Canada, the NCS has expanded its sample size from 12,000 in previous iterations to 18,200 in the 2023 cycle. This increase in sample size is necessary to ensure the statistical qualityFootnote 4 of the survey, allowing for more robust analysis and disaggregation of data by subgroups of the population. By having a larger and more representative sample, the NCS can provide more precise estimates and insights into cannabis-related behaviors and their variations across different sociodemographic groups. This enhanced statistical quality will enable researchers, policymakers, and health professionals to better understand the nuances and complexities of cannabis use patterns and make informed decisions based on the findings, while also providing a sufficient number of responses to allow for the publication of aggregate results that effectively protect the personal information of respondents.

  2. Effectiveness - Working assumptions: To ensure the effectiveness of the personal information collected and used in the National Cannabis Survey (NCS), rigorous measures have been taken, both in the pre-2023 cycles and in the upcoming 2023 cycle. The questions pertaining to cannabis were sourced from established surveys such as Statistics Canada's Canadian Community Health Survey (CCHS) and the Canadian Tobacco and Nicotine Survey (CTNS). These questions have previously undergone qualitative testing, affirming their effectiveness in capturing relevant information on cannabis-related behaviors. By leveraging questions from well-established surveys, the NCS benefits from their proven track record in accurately capturing data. Using these questions also allows for comparison of the results of the NCS with those of the CCHS and CTNS surveys, enabling improved interpretation and analysis of the data and providing valuable insights into trends and patterns related to cannabis use and behaviors over time.

    In the 2023 cycle of the NCS, additional personal information variables have been included to better capture desired sub-populations in order to gain a deeper understanding of how cannabis-related behaviors may differ among different groups. These personal information variables have also been drawn from existing Statistics Canada surveys. These variables have likewise been carefully reviewed and undergone comprehensive testing and validation processes, ensuring their effectiveness as indicators of key population characteristics and behaviors.

    By employing established and rigorously tested questions and expanding the range of variables in the 2023 cycle, the NCS maintains a robust framework for collecting and utilizing personal information effectively. The inclusion of these new variables aligns with Statistics Canada’s best practices in survey research and enhances the effectiveness of the NCS in addressing the specific needs and experiences of diverse populations. These measures ensure that the NCS is well-equipped to provide reliable and valuable insights into cannabis-related behaviors and their impacts on various population groups.

  3. Proportionality: The National Cannabis Survey is an essential tool for monitoring changes in cannabis use patterns since the legalization of cannabis in Canada and understanding its impact on health, social outcomes, and the Canadian economy. In the 2023 cycle of the National Cannabis Survey (NCS), several adjustments will be made to accommodate the inclusion of new variables. As part of this process, certain questions from previous NCS cycles will be removed, proportional to what will be added. Specifically, questions related to the impact of legislation on the decision to try cannabis or modify consumption habits, impaired control in relation to cannabis use, and the use of cannabis while operating motor vehicles will no longer be included as the focus of the 2023 cycle is primarily on gathering data related to cannabis use and purchasing patterns, as well as socio-sociodemographic characteristics; the decision to remove these specific questions was made to streamline the survey and allocate more resources towards obtaining detailed information on these key areas.

    Two other questions will be removed – one regarding marital status and one inquiring about the respondent's main activity, such as employment or studying – to streamline the survey and ensure that the new variables introduced in 2023 could be effectively incorporated.

    The sample size of 18,200 people living in Canada's ten provinces has been assessed as the minimum required to meet Statistics Canada’s quality guidelines. This increase in the sample size is considered proportional to get publishable results on the new content, and to disaggregate results by different population subgroups. Careful consideration was made to ensure that each question would accurately respond to the research questions and help inform future decisions related to cannabis use policies.

    The adjustments made to the NCS 2023 cycle reflect the evolving nature of the survey and the ongoing commitment to collecting relevant and meaningful data. These modifications help to optimize the survey's focus and ensure the efficient use of respondents' time, while still providing valuable insights into cannabis use patterns and their associated factors. The findings are expected to support evidence-based strategies, policies, and programs related to cannabis use in Canada. As mentioned above, without this data policymakers would lack valuable information about cannabis use, which could lead to uninformed policies that could be harmful to Canadians. As such, the benefit to be derived from the National Cannabis Survey by Canadians can be considered proportional to its privacy intrusiveness.

  4. Alternatives: Consultations with internal and external partners were conducted on existing administrative data and other surveys on cannabis use behaviors among Canadians, such as the Canadian Community Health Survey (CCHS) and the Canadian Tobacco and Nicotine Survey (CTNS). While other sources of data were considered, none would provide the combination of sociodemographic, health and cannabis-specific indicators required to fulfill the survey’s primary objective of obtaining detailed information about the habits of people who purchase and use cannabis.

Mitigation factors:

Some questions contained in the National Cannabis Survey are considered sensitive as they relate to substance use and illegal purchasing of cannabis among various sociodemographic subgroups. 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, which include the following measures:

  • Transparency
    Prior to participating in the voluntary survey, respondents will be informed of the survey purpose and topics, allowing them to assess whether they wish to participate. 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. Confidentiality reminders have also been placed before questions that may be perceived as more sensitive. Information about the survey, as well as the survey questionnaire, will also be available on Statistics Canada's website.
  • Confidentiality
    To mitigate against the risk of re-identification, 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. Additionally, 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.

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.