Supplement to Statistics Canada's Generic Privacy Impact Assessment related to the Survey on Mental Health and Stressful Events (SMHSE)

Date: February 2021

Program manager: Director, Centre for Social Data Integration and Development
Director General, Census Subject Matter, Social Insights, Integration and Innovation

Reference to Personal Information Bank (PIB)

Personal information collected through the Survey on Mental Health and Stressful Events 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 do not form part of the regular survey taking activity 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 on Mental Health and Stressful Events, under the authority of the Statistics Act (Sections 7 and 8), on behalf of the Public Health Agency of Canada. The purpose of the survey is to collect information to better understand how stressful events can impact the mental health of Canadians. The survey will also cover mental health status and well-being, post-traumatic stress disorder (PTSD), social support and healthy behaviours, and access to and use of mental health services and supports. The survey results will be used to estimate the prevalence of post-traumatic stress disorder (PTSD) in the population. The results may be used by policy makers to analyse the overall impact of specific stressful events on Canadians, including on their mental health, and will help guide decision making on the development and funding of targeted programs. In addition, the survey will identify the extent to which there is an unmet need for mental health care and will guide decisions about funding programs to decrease barriers to mental health care.

This voluntary household survey collects information from individuals aged 18 years and older living in the provinces. This survey includes topics on behaviours and symptoms associated with depression, anxiety and PTSD, suicide risk, substance use, social impacts of PTSD, as well as general mental health.

Three questions on the COVID-19 pandemic have been included in order to assess the impact the pandemic has had on highly stressful or traumatic events experienced by respondents. For example, the pandemic could have been related to a stressful event (e.g. a COVID-19 hospitalization or death of a family member); resulted in cancelled, rescheduled or delayed appointments (e.g. with a healthcare professional); or been the reason for an absence from work or a layoff. The COVID-19 related information will also provide context for data analysis, considering that mental health issues and stressful events may have been exacerbated by this ongoing public health crisis.

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. A sample of 35,000 respondents will be selected from Statistics Canada's Dwelling Universe File, which is a frame of household addresses rather than individuals. When the household receives a survey invitation, they will be asked to follow Age Order Selection instructions to choose the respondent when there is more than one person living in the household. Reponses will be aggregated to ensure that no individual can be identified. No direct identifiers such as name or address (except for postal code to derive the province of the respondent) will be collected for this 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 describes additional measures being implemented due to the sensitivity of the information being collected. 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 Survey on Mental Health and Stressful Events will collect information on mental health and well-being, 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's Framework for the Governance of Canada to Assess Privacy-Impactful Initiatives in Response to COVID-19.

Necessity and Proportionality

The collection and use of personal information for the Survey on Mental Health and Stressful Events can be justified against Statistics Canada's Necessity and Proportionality Framework:

Only individuals 18 years of age and older, living in the provinces, are eligible to participate in the Survey on Mental Health and Stressful Events. As such, respondents will first be asked to provide their age in order to establish whether they can take part in the survey.

The demographic data collected will be used for analysis of subgroups of the population. Treatment of PTSD tends to be highly individualized and many factors need to be taken into consideration for treatments to be effective. Understanding which groups are at higher risk for PTSD will help guide decisions about where awareness and treatment programs are most needed.

The survey data file, without direct identifiers other than postal code, will be made available to researchers in the Research Data Centres (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 aggregate results, which are fully anonymized and non-confidential, 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.

  1. Necessity: The extent of mental health symptoms, in particular for PTSD, and other aspects related to the access and use of mental health resources are generally unknown. There are no existing sources for this information, so a survey is necessary to fill this data gap. A quick and timely assessment of the mental health and well‐being of Canadians will help inform government decision‐making in order to support vulnerable Canadians and their families dealing with mental health issues. In addition, the Public Health Agency of Canada (PHAC), the survey sponsor, has a reporting requirement under The Post-Traumatic Stress Disorder Act, and will use the information to assess the prevalence and impacts (such as sleep or relationship problems) of PTSD and other mental health conditions, as well as to inform and develop policies and programs to support the planning of mental health resources. The information from the survey will also be available to policy makers to help them analyze the overall impact of specific stressful events on Canadians, including on their mental health, and guide decision making about the development and funding of targeted programs. 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.
    Only individuals 18 years of age and older, living in the provinces, are eligible to participate in the Survey on Mental Health and Stressful Events. As such, respondents will first be asked to provide their age in order to establish whether they can take part in the survey.
    The demographic data collected will be used for analysis of subgroups of the population. Treatment of PTSD tends to be highly individualized and many factors need to be taken into consideration for treatments to be effective. Understanding which groups are at higher risk for PTSD will help guide decisions about where awareness and treatment programs are most needed.
    The survey data file, without direct identifiers other than postal code, will be made available to researchers in the Research Data CentresFootnote 1 (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 aggregate results, which are fully anonymized and non-confidential, 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: A questionnaire was developed by following Statistics Canada's processes and methodology to produce results that are representative of the population. The survey will be administered using a self-reported electronic questionnaire. A random sample of households from Statistics Canada's household survey frame will receive an invitation letter and secure access code to complete the survey on Statistics Canada's secure website. After four weeks, interviewers will follow up with households that have not yet responded, to reissue the invitation and follow a protocol to randomly select someone in the household (using the age order selection method) aged 18 or older to respond to the survey. This will provide respondents with the opportunity to complete the survey over the telephone with a trained Statistics Canada interviewer. The collection period will be approximately twelve weeks. All Statistics Canada directives and policies for the development, collection, and dissemination of the survey will be followed, and survey responses will not be attached to respondents' addresses or phone numbers. The data will be representative of the general population and may be disaggregated by province, ethnicity, gender, age groupings, and other variables; in order to ensure anonymity.
    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 to ensure they accurately capture the data in question to help inform and develop policies and programs related to mental health (including PTSD) and its impacts.
    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 small groups (as established by minimum prevalence levels for each variable among these small groups) will not be published or shared with government departments or agencies. This approach will also reduce any potential impact 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 PHAC, Health Canada and provincial and territorial ministries of health, 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 findings will support decision-making at all levels of government and improve knowledge and understanding of the mental health and well‐being of Canadians, and will help inform government decision‐making in order to support vulnerable Canadians and their families dealing with mental health issues. The privacy measures taken are proportional to the potential risks to an individual's privacy.
    Proportionality has also been considered based on ethics:
    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 in writing on the questionnaire, or verbally by the interviewer before any questions are asked. They will also be asked if their data can be shared with PHAC, 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 accessed in the electronic questionnaire and during interviews.
  3. Proportionality: Data on mental health and its impacts, in particular PTSD, and data on other aspects related to the access and use of mental-health resources are highly sensitive. Moreover, mental-health issues may be exacerbated due to COVID‐19 isolation protocols. For these reasons, experts at Statistics Canada and PHAC have been consulted on the scope and methodology of the survey. Wherever possible, questions about mental health and well‐being from existing surveys have been used. Some of these questions were taken from the Survey of COVID-19 and Mental Health (SCMH) and have previously undergone qualitative testing; the results of these two surveys may be compared, allowing for improved interpretation of the results (see SPIA for the SCMH).
  4. Alternatives: Research was conducted on existing administrative data and other surveys on mental health. It was determined that these types of data sources were not able to identify people with PTSD (whether diagnosed or not) to determine its prevalence and the associated mental-health impacts. As a result, it was determined that a survey to collect this information was required. The possibility of using crowdsourcing or web‐panel survey methodologies was explored. However, based on discussions between health and methodology experts within Statistics Canada and the Public Health Agency of Canada, it was determined that a survey with at least 35,000 units was necessary to produce reliable and accurate results by province. Releasing data at these aggregated levels would reduce the potential to identify impacts on vulnerable populations, subsets of populations, and groups.

Mitigation factors

Some questions contained in the Survey on Mental Health and Stressful Events 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, and will be provided to respondents at the beginning of the survey and as a help button within the electronic questionnaire. In addition, in the case of telephone follow-up for non-response, 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 they can make an informed decision about whether they want to participate. This notification to all potential participants will be done in writing on the questionnaire, or verbally by the interviewer before any questions are asked. The topics listed as part of the survey will include: behaviours and symptoms associated with depression, anxiety and post-traumatic stress disorder (PTSD); suicide risk; substance use; social impacts of PTSD; general mental health; and access to and use of mental health care services and supports. This information will be provided through invitation and reminder letters, and will be repeated at the beginning of the questionnaire. Information about the survey, as well as the survey questionnaire, will also be available on Statistics Canada's website.

Confidentiality

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. Following careful analysis of the data, consideration will be given prior to the release of aggregate data to ensure that marginalized and vulnerable communities are not disproportionally impacted. As permitted by the Statistics Act, and only with the consent of the respondent, survey responses may be shared with PHAC, Health Canada and provincial and territorial ministries of health, strictly for statistical and research purposes, and in accordance Statistics Canada's security and confidentiality requirements. The postal code will be used to derive the province of the respondent; it will not be used to identify respondents given that only aggregated data will be released. Respondents will be 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 it 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

Eric Rancourt
Director General
Modern Statistical Methods and Data Science

Lynn Barr-Telford
Assistant Chief Statistician
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.

Anil Arora
Chief Statistician of Canada