Supplement to Statistics Canada's Generic Privacy Impact Assessment related to the Survey of Early Learning and Child Care Arrangements – Children with Long-term Conditions or Disabilities

Date: March 2023

Program manager: Director, Diversity and Sociocultural Statistics
Director General, Justice, Diversity and Population Statistics

Reference to Personal Information Bank (PIB)

Personal information collected through the Survey of Early Learning and Child Care Arrangements – Children with Long-term Conditions or Disabilities (SELCCA – CLCD) 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 016) 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 Survey of Early Learning and Child Care Arrangements – Children with Long-term Conditions or Disabilities (SELCCA – CLCD) under the authority of the Statistics Act1. on a cost-recovery basis for Employment and Social Development Canada (ESDC) to address the data gaps for children with long-term conditions and disabilities. This new cross-sectional survey aims to gather information from parents and guardians of children with one or more long-term condition or disability, aged 0 to 5, living in the provinces, as a next step to Statistics Canada's other recent collections on Early Learning and Child Care (the voluntary 2022 Survey of Early Learning and Child Care Arrangements (SELCCA) and 2023 Canadian Survey on Early Learning and Child Care (CSELCC) . The SELCCA – CLCD includes the same core content as each of these surveys to support indicators related to early learning and child care, as well as content that can provide information on the specific needs of these children and their families or barriers that they may experience. CSELCC, which replaces SELCCA for 2023, includes additional content on parents' and guardian's labour market participation to better understand the interaction between work and the use of early learning and child care arrangements. As there is no standardized measure of disability among children, neither of these surveys included measures to identify whether children have long-term conditions or disabilities.

The survey asks parents and guardians about their child care preferences, arrangements, associated costs and other relevant information such as difficulties they may have faced when looking for or accessing care (accessibility and availability).

In order to identify long-term conditions or disabilities in children, the survey also collects information on their activity limitations, physical and mental health conditions and health status. In addition, age, gender, Indigenous identity, visible minority status, and education will be collected.

Results from this survey will be used to help to support the Multilateral Early Learning and Child Care Framework, which seeks to improve Canada's Early Learning and Child Care (ELCC) system.

To reduce respondent burden and supplement/verify relevant information (described in more detail below), participants will be notified that their responses will be linked to their data from Statistics Canada's 2021 Census of Population2 and Longitudinal Immigration Database3, as well as their Canada Child Benefit, T1 Universe File (Personal Master)4 and the T1 Family File (T1FF) data from the Canada Revenue Agency (CRA)5 . Statistics Canada's microdata linkage and related statistical activities were assessed in Statistics Canada's Generic Privacy Impact Assessment.6 All data linkage activities are subject to established governance7 , and are assessed against the privacy principles of necessity and proportionality8 . All approved linkages are published on Statistics Canada's website9 .

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 collection and use of potentially sensitive information regarding disabilities and long-term conditions of children10 . 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.

Reason for supplement

While the Generic Privacy Impact Assessment (PIA) presents and addresses most of the privacy principles and security risks related to statistical activities conducted by Statistics Canada, this supplement addresses any privacy risks associated with this new data environment. 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 and use of personal information for SELCCA – CLCD can be justified against Statistics Canada's Necessity and Proportionality Framework:

1. Necessity

The collection and use of information on children with long-term conditions and disabilities is required by Employment and Social Development Canada (ESDC) to ensure that Canada's Early Learning and Child Care (ELCC) system meets the needs of all families, including those who may face barriers to child care as a result of long-term conditions or disabilities as per the Government of Canada's Multilateral Early Learning and Child Care Framework. Other surveys on early learning and child care do not collect information related to long-term conditions or disabilities in children nor the barriers they face. As a result, there is a data gap related to the children with long-term conditions and disabilities and child care, which results in the inability to assess whether ELCC in Canada adequately supports these children and their families. The information produced through this survey will be used to direct policies and programs aiming to improve the quality, accessibility, affordability, inclusivity and flexibility of ELCC programs and services.

The 2021 Census and the CRA's Canada Child Benefit file will be used by Statistics Canada methodologists to identify which households are in-scope for collection when creating the survey frame, based on statistical sampling parameters (geographic representativeness, socio-demographic representativeness, etc.) and the indicated presence of young children.

Respondents will be informed that their survey responses will be linked to 2021 Census of Population data, immigration data (from Statistics Canada's Longitudinal Immigration Database), and select CRA data to provide additional contextual information, and to help reduce respondent burden. Specifically:

  • The linkage with the 2021 Census of Population will be used to evaluate the relationship between the Activities of Daily Living questions on the Census with the reporting of long-term conditions and disabilities in children on the SELCCA – CLCD to determine how accurate it is at identifying children with long-term conditions and disabilities. This analysis will support the future development of a social model disability screening tool for children, similar to the Disability Screening Questions. A standardized disability screening tool for children would facilitate the collection of data for this population, resulting in data which reflects the lived experiences of these children and their parents. Additionally, a standardized disability screening tool would support Canada in meeting obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD).
  • A linkage with the CRA's Canada Child Benefit will provide accurate geographic information, such as place of residence.
  • Data from CRA, such as the T1 Universe File (Personal Master) file, and T1FF, will provide data related to personal and household income to reduce the number of questions respondents need to answer.
  • Finally, a linkage to the Longitudinal Immigration Database provides data related to immigration status for the child and their family to reduce the number of questions respondents need to answer.

2. Effectiveness - Working assumptions:

SELCCA – CLCD is designed to provide accurate estimates of the experiences and needs of children with long-term conditions and disabilities and their families at the national level, excluding territories11 . To effectively collect this data, Statistics Canada will:

3. Proportionality

SELCCA – CLCD was developed to address data gaps related to child care for children with disabilities or long-term conditions, specifically barriers related to the use of child care. Questions related to long-term conditions and disability, particularly in children, can be viewed as sensitive, however this information is required to ensure that the early learning and child care arrangement needs of all children are being met.

In order to ensure the survey was reflective of the needs of children with long-term conditions and disabilities, content for SELCCA – CLCD was developed in consultation with experts in early learning and child care for children with disabilities, as well as ESDC, to ensure that the content aligned with the needs of researchers and ESDC to make informed policy decisions that ultimately benefit the Canadian society and economy. Only content needed to support ELCC policies and programs are included within the survey.

A sample size of 20,000 children aged 0-5 has been assessed as necessary by methodologists to produce statistics of sufficient quality to produce insightful information at the national level. The Census of Population and the Canada Child Benefit are used to create a representative sample frame of children for the survey, with a person knowledgeable about the child, such as a parent or legal guardian, responding to the survey.

In order to limit collection to only children aged 0-5 with a long-term condition or disability, a screening at the beginning of the survey ensures that respondent children without a long-term condition or disability are screened out and not required to provide any additional information as they are considered out of scope.

Ultimately, this collection of data and information is considered proportional to the potential benefits to policymakers, who will be able to use it to help address the child care needs of children with a long-term condition or disability.

4. Alternatives

Statistics Canada conducts several other surveys related to early learning and child care13 ; however, these surveys do not collect data on long-term conditions or disabilities. Specifically, these surveys do not contain:

  • measures to identify long-term conditions or disabilities in children, or
  • content regarding the specific needs of these children and their families, including information on barriers related to child care.

Adding content on long-term conditions and disabilities in children to existing surveys was considered, but was projected to increase response burden for participants selected for these other surveys to statistically and operationally unacceptable levels. Although the data from these other surveys supports Canada's ELCC system, they do not provide sufficient insights related to the long-term conditions or disabilities of the associated children.

Mitigation factors

Some questions contained in SELCCA – CLCD are considered sensitive as they relate to health conditions or disabilities of young children, however, 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 measure:

  • Qualitative testing of survey content was conducted with parents and guardians of children with long-term conditions and disabilities to ensure that the content would be well understood and to evaluate whether the questions being asked were overly intrusive or insensitive. As a result of feedback related to the sensitivity of the content received during qualitative testing, several changes were made to the final survey content, including the removal of content that was deemed highly sensitive.
  • As with all Statistic Canada surveys, prior to the survey, respondents will be informed of the survey purpose, allowing them to decide if they want to participate. This information will be provided through invitation and reminder letters and reiterated at the beginning of the online questionnaire. Respondents will also be informed that their participation is voluntary before being asked any questions. Information about the survey, a brochure, and the survey questionnaire will be made available on Statistics Canada's website on the day collection starts.
  • 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. Careful analysis of the data and consideration will be given prior to the release of aggregate data to ensure that vulnerable individuals are not disproportionally impacted.

Conclusion

This assessment concludes that, with the existing Statistics Canada safeguards including those listed above, any remaining risks are such that Statistics Canada is prepared to accept and manage the risk.

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