Supplement to Statistics Canada's Generic Privacy Impact Assessment (SPIA) related to the Pulse Survey on COVID-19 and its Impacts on Public Service Employees (PSCIPSE)

Date: May 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 the workplace across the federal public service of Canada, Statistics Canada is conducting the Pulse Survey on COVID-19 and its Impacts on Public Service Employees (PSCIPSE), a series of short thematic questionnaires directed at employees on different topics, such as mental health and wellness, the current work environment, leadership and support, and the future of work. The series will include core questions remaining the same in each questionnaire and rotating theme content. Employing a crowdsourcing methodology, respondents will access the questionnaires through the anonymous portal on the Statistics Canada webpage. The survey will pilot with Statistics Canada employees and may also be extended to employees across the public service.

The voluntary PSCIPSE questionnaires do not collect any direct personal identifiers such as name or age. Instead, these questionnaires collect personal information such as age group, gender, aboriginal status, visible minority status, and disability. They also collect the following work-related information about the employee, such as department or agency of work, organizational unit, current employee status, occupational group, and province or territory of work. While direct personal identifiers are not being collected, participants will provide personal information and work information. This information will be processed according to standard privacy protocols. Individuals' participation and answers will remain anonymous; individuals will not purposely be identified.

The PSCIPSE asks questions on mental health and wellness and a minimal number of open-ended questions, which could potentially result in sensitive information being revealed. The sensitivity of the open-ended questions will vary by survey theme but responding to these questions is voluntary. Finally, the PSCIPSE collects email addresses from participants, on a voluntary basis, for future invitation to participate in related research projects. Aggregated results will be presented by demographic information, for example age, region, organizational unit, and occupational group.

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 (see below, Mitigation Factors) being implemented for collection and access to the information due to potentially sensitive information being provided by the participant. This supplement also presents an analysis of the necessity and proportionality of this new survey series.

Necessity and proportionality

The collection and use of personal information for the PSCIPSE can be assessed against the four-part test proposed by the Office of the Privacy Commissioner of Canada:

  1. Necessity: The COVID-19 pandemic is having a significant impact on Statistics Canada and the federal public service at large, the services being delivered, and the way in which employees work. The personal information collected in the PSCIPSE is necessary for Statistics Canada to gather more reliable information on the impact that COVID-19 is having on federal government employees. The results will help participating government departments and agencies identify the key challenges faced by federal public servants in various circumstances both at work and home, understand their most important needs, and develop tools and measures to support employees during and after the pandemic. Further, the results from the PSCIPSE will provide insight as to whether the federal government is meeting its objectives during the COVID-19 pandemic; most notably, the objectives to provide an agile, inclusive and equipped workplace and maintain a healthy work environment in regards to mental health and workplace (including telework situations) wellness.

    Collecting sensitive information through questions about mental health and other open-ended questions is also necessary to achieve the goal of the PSCIPSE. Good mental health is crucial to achieving overall good health and well-being, and the work environment can have an impact on a person's mental health. During these difficult times, the Government of Canada must continue to take all reasonable actions in creating and maintaining healthy and safe workplaces (including telework situations). Given the unprecedented nature of the COVID-19 pandemic, the possible impacts on mental health and other aspects of life are unknown. Open-ended questions are required to appropriately capture these impacts as well as capture suggestions on how the current work environment could be improved.

  2. Effectiveness: Due to the urgency of the information need, a crowdsourcing methodology will be used to administer the PSCIPSE in order to minimize the impact on the internal government infrastructure and maximize employee participation. As such, the questionnaires will be placed on Statistics Canada's website for federal employees to complete. Several Statistics Canada projects related to COVID-19 have successfully adopted this methodology, including Impacts of COVID-19 on Canadians: Data Collection Series, the Canadian Survey on Business Conditions and Impacts of the COVID-19 Pandemic on Postsecondary Students.

  3. Proportionality: The PSCIPSE is being collected through the anonymous portal, giving participants anonymity and limiting privacy concerns.

    Experts at Statistics Canada and TBS have been consulted on the scope and methodology of the PSCIPSE. A number of questions from the Public Service Employee Survey (PSES) have been included in the PSCIPSE. This is beneficial because these questions have previously undergone qualitative testing and the results of this data collection series could potentially be compared to the PSES, allowing for improved interpretation of the results.

    The data collected will contain only the variables required to achieve the statistical goals of the PSCIPSE. 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 never be shared with government departments or agencies. In the event of a public service-wide launch, a limited number of employees from the Treasury Board of Canada Secretariat (TBS) will have access to the data for statistical and research purposes and will be required to adhere to the same security and confidentiality requirements as other surveys conducted by Statistics Canada and as outlined in the Statistics Act. Respondents will be advised of this in the survey introduction.

    The benefits of the findings, which are expected to inform support services aimed at improving workplace environments, and support leadership across departments and agencies, are believed to be proportional to the potential risks to privacy.

  4. Alternatives: Currently, there are no other sources that gather information on the impact of the COVID-19 pandemic on federal public service employees.

Mitigation factors

Some questions contained in the PSCIPSE are considered sensitive as they relate to an individual's mental health and wellness or are open-ended questions in which sensitive information could inadvertently be included, but the overall risk of harm to survey participants was deemed manageable through the mitigating actions outlined here.

Consultation

A streamlined consultation process will be followed prior to each questionnaire's launch. It may include engagement activities with TBS policy centers, the Privy Council Office and other stakeholder groups such as bargaining agent representatives.

Consent

All participants will be informed of the voluntary nature of the PSCIPSE and the topic of each questionnaire in the series before participating. Participants will also be informed that their participation is voluntary, in the invite, before being asked any questions. Finally, participants will be informed that, in the event of a public service-wide launch, a small number of Treasury Board of Canada Secretariat employees will have access to the data for statistical and research purposes and will be required to adhere to the same security and confidentiality requirements as other surveys conducted by Statistics Canada, and as required by the Statistics Act.

Benchmarking

While the crowdsourcing questionnaires target public service employees at Statistics Canada and, in the event of a public service-wide launch, other participating departments, challenges in reaching employees during the COVID-19 pandemic are anticipated. As crowdsourcing does not allow for a controlled group of respondents, it is expected that there will be population coverage issues which may have an impact on the quality of the results. Benchmarking, or adjusting results, against known public service population totals may allow for better interpretation of results by mitigating some of the known differences between participants and non-participants. However, even if benchmarking is performed, inference cannot be made to the general population of interest.

Support Services

To support participants, Statistics Canada we will list the following reputable, government-wide resources on COVID-19 in the questionnaires:

Statistics Canada will also provide other resources when relevant to a particular topic being covered in the series.

Conclusion

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

Eric Rancourt
Director General,
Modern Statistical Methods and Data Science

Linda Howatson-Leo
Chief Privacy Officer

Lynn Barr-Telford
Assistant Chief Statistician,
Social, Health and Labour Statistics

Anil Arora
Chief Statistician of Canada

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