The NetSupport software is required for our organization to be able to provide an effective Quality Control Monitoring Program. It will enable supervisors to provide comprehensive feedback to data collection clerks on core competencies in areas that cannot otherwise be addressed via auditory observation alone. This assessment illustrates that the risks involved with using NetSupport are far outweighed by the crucial function it provides. The application is essential for providing the necessary training, support and coaching data collection clerks need to meet our high standards for data quality control.
Objective
A privacy impact assessment was conducted to determine if there were any privacy, confidentiality and security issues associated with using NetSupport for the Quality Control Monitoring Program, and if so, to make recommendations for their resolution or mitigation.
Description
Statistics Canada has a legislative mandate under the Statistics Act to collect survey information from respondents on various topics. To fulfill this mandate, the agency is responsible for the objectives of maintaining high standards for quality control and conducting effective performance management of employees. The current Quality Control Monitoring Program was established in the regional offices in pursuit of achieving these objectives, however the program is rendered ineffective by the absence of visual observation for telephone interviews.
The NetSupport software is a third-party application that will address the need to have visual observation during monitoring sessions of telephone interviews. For our usage, the application will allow a set of users (i.e., Data Collection Supervisors) to conduct visual observation of other users' desktop screens (i.e., data collection clerks) for the sole purpose of performance management and quality control. The software will enable supervisors to evaluate in real-time the data collection clerk's skills, ensure data quality and identify areas for improvement in the interviewing process. As a result, the quality and level of detail supervisors can provide to data collection clerks for their performance feedback is greatly enhanced. At no point will the information viewed via NetSupport be recorded, collected or saved by the software.
For privacy impacts related to NetSupport, measures are in place to ensure that the impacted parties are informed. Data collection clerks are made aware of the possibility of being observed via their collective agreement, the training they receive and the interview script they read. Respondents of Statistics Canada surveys are made aware of monitoring at the beginning of the interview via the standard statement in our survey scripts that indicates a supervisor may listen to the call for quality control purposes.
Although NetSupport will not be saving/recording information, users of the software will have access to view the respondent's personal information while it is visible on the data collection clerks' screen. This may contain personally identifiable information such as names, addresses, ages, and other demographical information, as well as responses to our survey questions. Given the confidential nature of this information, the use of NetSupport will be restricted to supervisors and managers who have taken the Oath of Secrecy. These employees receive training on how to handle and protect confidential information that is subject to the Privacy Act and the Statistics Act.
Our organization is taking the necessary precautions to limit the number of risks involved with using NetSupport for respondents and employees. For example, the use of NetSupport will be limited to observing work-related performance only and for limited durations (e.g., 20 minutes). The user settings for NetSupport will also be restricted so that features that go beyond the purposes of monitoring performance will be disabled (e.g., recording of audio or video) to ensure it meets our security procedures. Furthermore, permissions for user accounts will be standardized and aligned with internal security procedures.
Risk Area Identification and Categorization
The PIA identifies the level of potential risk (level 1 is the lowest level of potential risk and level 4 is the highest) associated with the following risk areas:
|
a) Type of program or activity Risk scale |
|
|---|---|
| Administration of program or activity and services | 2 |
| b) Type of personal information involved and context | |
| Only personal information, with no contextual sensitivities, collected directly from the individual or provided with the consent of the individual for disclosure under an authorized program. | 1 |
| c) Program or activity partners and private sector involvement | |
| Within the institution (among one or more programs within the same institution) | 1 |
| d) Duration of the program or activity | |
| Long-term program or activity. | 3 |
| e) Program population | |
| The program's use of personal information for internal administrative purposes affects certain employees. | 1 |
| f) Personal information transmission | |
| The personal information is used in a system that has connections to at least one other system. | 2 |
| g) Technology and privacy | |
|
The NetSupport software will be used to support the existing quality control and performance management program of the regional offices. It will assist supervisors with fulfilling their responsibility of monitoring telephone interviews and provide performance feedback. It does not collect, create or handle personal information. Aside from the request for the NetSupport Manager application itself, no new electronic systems or applications are needed to support the program in terms of creation, collection or handling of personal information. It is important to note that the surveillance purposes of the program are restricted to improving internal quality control practices only. For example, the NetSupport application will be used to observe if the data collection clerk is following procedures, entering data correctly and using appropriate techniques such as probing. The responses provided in a questionnaire by the respondent are not particularly relevant to the user who is accessing the information. They are a by-product of the quality control work, and not the main focus. Irrespective of the relevance of the data, all confidential information that is observed via NetSupport will be protected under the Statistics Act Oath of Office that is taken by the NetSupport user and the guidelines of the Values and Ethics Code. This protection applies to the data collection clerk's activities as well as the respondent's participation. |
|
| h) Potential risk that in the event of a privacy breach, there will be an impact on the individual or employee. | |
|
The potential risk of a privacy breach involving our organization's use of NetSupport is very low. The impact of a privacy breach on the individual or employee will be very limited due to the measures in place. Statistics Canada has legislation and practices that reduce and mitigate the potential risks involved in handling confidential information. Data Collection Supervisors will be using the NetSupport software for visual observation while conducting a monitoring session of the data collection clerk's telephone interview. These supervisors are deemed employees who have sworn an Oath of Office to protect the confidential information they encounter during their work activities. For their jobs, they handle and encounter confidential information on a daily basis and must adhere to the guidelines and repercussions of the Statistics Act and the Privacy Act. Statistics Canada is taking precautionary measures to reduce the impacts for individuals and employees regarding the use of NetSupport. For example, we are disabling features within the application that would pose additional privacy risks, such as recording, so that it cannot save or retain information. Also, the application will solely be used for the purpose of monitoring work activities of data collection clerks and helping supervisors conduct performance management. These restrictions provide an accountability framework for limiting the possibility for confidential information to be disclosed improperly. |
|
| i) Potential risk that in the event of a privacy breach, there will be an impact on the institution. | |
|
The potential risk for a privacy breach involving NetSupport to impact the institution will be very limited due to the measures in place. The practices and safeguards for using NetSupport will offer reasonable layers of accountability in the event that confidential information viewed via NetSupport is improperly disclosed. This organizational infrastructure will allow for a breach to be dealt with efficiently in a manner that reduces the impact on the institution. For example, the regional offices will be responsible for managing users of the program and ensuring their work activities adhere to the requirements of the Statistics Act. The checks and balances that exist within the reporting structure of the regions will help to ensure that users are held accountable for their use of NetSupport. In the event of wrongful disclosure of confidential information, users of NetSupport will be subject to the same recourse as for activities undertaken for general statistical programs (see Generic Privacy Impact Assessment for Statistics Canada's Statistical Programs.) . Furthermore, since the application will not be used to retain or store data there is a reduced risk for mishandling of information. |
|
Conclusion
This assessment of NetSupport did not identify any privacy risks that cannot be managed using existing safeguards.