Supplement to Statistics Canada’s Generic Privacy Impact Assessment related to the Canadian Survey on the Provision of Child Care Services

Date: February 2024

Program manager: Director, Centre for Special Business Projects
Director General, Agriculture, Energy and Environment Statistics

Reference to Personal Information Bank (PIB):

In accordance with the Privacy Act, Statistics Canada is submitting an amendment to the institutional personal information bank (PIB) StatCan PPU 116, Sociodemographic Information on Business Primary Decision Makers to describe any personal information about individuals that work for, own or operate businesses, non-profits and other organizations as volunteers, employees, and/or primary decision-makers, collected in surveys or acquired administrative data for use in Statistics Canada’s Economic and Environmental Statistics programs operating under the authority of the Statistics Act.

Sociodemographic Information on Business Owners, Primary Decision Makers, Employees, and Volunteers

Description: This bank describes personal information that relates to individuals that work for, own or operate businesses, non-profits and other organizations as volunteers, employees, and/or primary decision-makers, collected in surveys or acquired administrative data for use in Statistics Canada’s Economic and Environmental Statistics programs operating under the authority of the Statistics Act. Personal information may include gender, sexual and gender diversity, First Nations (North American Indian), Métis, or Inuk (Inuit), visible minority, persons with a disability, citizenship and immigration status, education and age.
Class of Individuals: Business owners, primary decision makers, employees and volunteers of non-profits and other organizations or businesses that are included in Statistics Canada’s Economic and Environmental Statistics programs.
Purpose: The personal information is used to produce statistical data that help provide insight into various gaps in the economy for a variety of minority groups, and serves to inform evidence-based decisions on funding and support for specific groups of businesses, non-profits or other organizations. Personal information is collected pursuant to the Statistics Act (Sections 3, 7, 8).
Consistent Uses: When collected directly and with informed consent, identifiable sociodemographic personal information may be shared with provincial and territorial statistical agencies and other government organizations that have demonstrated a requirement to use the data, and as permitted under the provisions of Sections 11 or 12 of the Statistics Act.
Retention and Disposal Standards: Information is retained until it is no longer required for statistical purposes and then it is destroyed.
RDA Number: 2007/001
Related Record Number: To be assigned by Statistics Canada
TBS Registration: To be assigned by TBS
Bank Number: StatCan PPU 166

Description of statistical activity:

Under the authority of the Statistics Act^{Footnote 1}, Statistics Canada conducts the Canadian Survey on the Provision of Child Care Services (CSPCCS). This irregular voluntary survey is funded by Employment and Social Development Canada (ESDC) and its purpose is to collect information on the provision of child care services in Canada for children ages 12 and under at the national, provincial, and territorial levels. Information about staffing levels and training, services provided, enrollment and daily fees is collected from licensed and unlicensed home-based and centre-based child care providers. 

Starting with the 2024 survey cycle, four new sociodemographic questions pertaining to only home-based child care operators will be asked: 

• Gender
• First Nations (North American Indian), Métis, or Inuk (Inuit)
• Landed immigrant within the last 10 years 
• Person with a disability

Home-based child care operators make up approximately 69% of child care providers in Canada. They are often run and operated by the same individual and thus the sociodemographic questions will typically be answered directly by the individual to whom they pertain. 

Respondents have the option to select the response “Prefer not to answer” or “Don’t know” for the questions pertaining to the gender of the home operator, whether the home operator is First Nations, Métis, or Inuk (Inuit), whether the home operator is a landed immigrant to Canada in the last 10 years, and whether the home operator is a person with a disability. Further, the respondent may leave any of these questions unanswered and continue the survey. As such, the respondent may choose to answer these questions to the best of their knowledge or not. Furthermore, the survey respondent is instructed in the beginning of the questionnaire that the owner or operator of the child care service is the best person to respond to the 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, this supplement was conducted due to the potentially sensitive nature of the sociodemographic information about home child care operators. 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 Canadian Survey on the Provision of Child Care Services can be justified against Statistics Canada’s Necessity and Proportionality Framework: 

1. Necessity: Child care was included as part of Budget 2021 to support and create more high quality, affordable child care spaces across the country. The CSPCCS is funded by the $95 million that was previously allocated to child care data collection and research in Budget 2017^{Footnote 2} as data gaps exist in Canada in terms of profiles of home-based child care providers. Home-based providers service a wide range of child care needs, and it is important to understand whether they reflect the demographics of the population to whom their services are being provided. It is expected that building the capacity of the national child care sector will necessitate supporting diverse groups to develop their skills to take on greater leadership roles, building the entrepreneurial capacity and business skills of under-represented groups (such as Indigenous communities, women, immigrants and persons with disabilities), facilitating the sharing of industry experience, best practices and knowledge to help under-represented groups manage transformation, and reinforcing the child care sector by incorporating the views of a more diverse set of industry players. Better data, analysis and information can highlight inequities and promote fairness and inclusion in the delivery of programs, services, and policy decisions. 

   Collecting this data allows for baseline metrics of participation by underrepresented groups (i.e., to what extent are each of the groups represented among home-based child care providers and how does this compare to representation of the children served in the population?). 

   Employment and Social Development Canada (ESDC) and other Government of Canada departments will use the resulting information to better understand the child care sector in order to make recommendations to policy departments regarding the development and support of child care programs in Canada. The information will also allow national, provincial and territorial governments as well as researchers to further support and foster collaboration in the child care sector. 

   Specifically, the sociodemographic information collected may help strengthen the sector by leading to the creation of policies that better reflect the diversity of Canadian communities, enhance collaboration across different jurisdictions, secure and support public trust in the sector, and improve client services. In addition, the data may be used to inform upcoming child care workforce strategies. 

   Questions on immigrant status and Indigenous identity of home-based child care providers contribute to an understanding of the Early Learning and Child Care Framework (ELCC) home-based workforce. The CSPCCS can provide insights into the intersection between low remuneration in this nearly entirely female field and its demographic characteristics of which nearly half are immigrants or non-permanent residents. Further, comparatively little information has been collected on Indigenous home-based child care providers. It is possible that this information may be relevant to gaining a better understanding of the supply of child care services across Canada. For example, the Indigenous Early Learning and Child Care Framework (IELCC) represents the Government of Canada and Indigenous peoples’ work to co-develop a transformative Indigenous framework that reflects the unique cultures, aspirations and needs of First Nations, Inuit and Métis children across Canada. Having information about the supply of Indigenous owned home-based child care services across Canada would be crucial to evaluate the effectiveness of the IELCC.

   Questions on gender and persons with disabilities provide a comprehensive view of the population of home-based child care operators. Understanding the gender distribution and prevalence of persons with disabilities among child care operators provides valuable insights on any disparities in the sector. For example, to what extent are each of these groups represented among home-based child care providers and how does this compare to representation of the children served in the population.

2. Effectiveness - Working assumptions: Although the survey is voluntary and the respondents have the option to select the response “Prefer not to answer” or “Don’t know”, it is expected that those that choose to provide the information will do so as accurately as possible. Further, the survey instructions identify the owner or operator of the child care service to be the best person to respond to the survey, increasing the likelihood of direct collection of personal information. When these questions are received by proxy, the small size of daycares is a factor, as it would be reasonably expected that any others at the daycare would be aware of this information, or would decline to respond or select “Prefer not to answer” or “Don’t know” in cases where they were not. 

3. Proportionality: The information will be collected to better understand participation in the sector by underrepresented population groups, allowing for the implementation of evidence-based policies in the child care sector to further encourage more widespread participation. The five sociodemographic variables represent the minimum required to best represent Canada’s diverse communities as determined by subject matter experts at Statistics Canada and ESDC and are only collected from home-based child care services which make up approximately 69% of child care providers in Canada. Practices in the child care sector vary significantly across the provinces and territories, necessitating good information for each jurisdiction. As such, the sample has been designed to support the production of quality estimates at the provincial and territorial level. Further, linking to Statistics Canada’s only linkable dataset that contains these types of variables – the Census of Population long-form, to which only a portion of Canadians were asked to respond – would result in a linkage rate that would be too low to meet Statistics Canada’s quality guidelines. 

   This effort ultimately aims to address inequalities and disparities affecting underrepresented population groups, allowing for a broader reach in participation across the child care sector and to foster future generations of child care operators. As such, the collection of the new sociodemographic information is considered proportional to the potential benefits.

4. Alternatives: The following alternative modes of collecting the sociodemographic information were considered, and due to their limitations, the voluntary collection of sociodemographic information about operators was identified as being the most efficient and effective method to achieve the identified needs.

   Direct collection from operators through additional screening questions: Despite potentially being more accurate, the addition of screening questions to validate that the survey respondent is also the business operator could be more burdensome on respondents, limiting the response rate and compromising the program’s ability to produce statistics about these minority groups that comply with Statistics Canada’s quality guidelines. 

   Linking the sociodemographic variables from other surveys or administrative files: Statistics Canada’s only linkable dataset that contains these types of variables is the Census of Population long-from to which only a portion of Canadians were asked to respond. As such, the linkage rate would be too low to meet Statistics Canada’s quality guidelines.

Mitigation factors:

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, such as with the following measures:

• Respondents will be informed at the start of the questionnaire that it is voluntary, and that they have the right to refuse to provide any information. 
• Respondents have the option to select the response “Prefer not to answer” or “Don’t know” for the questions pertaining to gender, First Nations, Métis, or Inuk (Inuit), landed immigrant to Canada in the last 10 years, and person with a disability. 
• Respondents can leave the questions blank and proceed with the rest of the survey. 
• Respondents are instructed at the beginning of the questionnaire that the owner or operator of the child care service is the best person to respond to the survey.
• Statistics Canada will not attempt to re-identify any individuals from the personal information collected. 
• Statistics Canada will not publish any information that could allow the identification of any individuals. Additional suppressions will be performed on outputs to ensure any risk of re-identification is mitigated.

Conclusion:

This assessment concludes that the overall risk of harm has been deemed manageable with the abovementioned mitigations and existing Statistics Canada safeguards described in Statistics Canada's Generic Privacy Impact Assessment.