Administrative Burden Baseline: 2014 Baseline Count

In its Red Tape Reduction Action Plan, the Government committed to build on the efforts of the Paperwork Burden Reduction Initiative by requiring departments, through the Administrative Burden Baseline, to provide a count of the requirements in federal regulations that impose an administrative burden on business.

All federal regulations administered by Statistics Canada that have requirements that impose administrative burden on business are identified below. The total 2014 count is 157.

Administrative burden
Title of the regulation SOR number 2014 Count
Corporations Returns Regulations 2014-13 157
Total Count 157

Environment, Energy and Transportation Statistics Division

Reporting Guide

This guide is designed to assist you as you complete the 2016 Monthly Natural Gas Storage Survey. If you need more information, please call the Statistics Canada Help Line at the number below.

Help Line: 1-877-604-7828

Storage facilities include natural gas storage caverns such as: depleted oil and gas reservoirs, aquifer reservoirs, salt cover reservoirs. Liquefied Natural Gas (LNG) storage facilities are out of scope for this survey.

Units: Report Gigajoules (GJs) of natural gas stored during the month under review.

Confidentiality

Your answers are confidential.

Statistics Canada is prohibited by law from releasing any information it collects which could identify any person, business, or organization, unless consent has been given by the respondent or as permitted by the Statistics Act. Statistics Canada will use the information from this survey for statistical purposes.

Table of contents

Skip to text

General information : Purpose of survey, Data-sharing agreements and Data linkage
Reporting instructions
Reporting Instructions and natural gas definitions

Text begins

General information

Purpose of survey

The purpose of this survey is to obtain information on the supply of, and demand for, energy in Canada. This information serves as an important indicator of Canadian economic performance, and is used by all levels of government in establishing informed policies in the energy area. In the case of public utilities, it is used by governmental agencies to fulfill their regulatory responsibilities. The private sector also uses this information in the corporate decision-making process. Your information may also be used by Statistics Canada for other statistical and research purposes.

Data-sharing agreements

To reduce respondent burden, Statistics Canada has entered into data-sharing agreements with provincial and territorial statistical agencies and other government organizations, which have agreed to keep the data confidential and use them only for statistical purposes. Statistics Canada will only share data from this survey with those organizations that have demonstrated a requirement to use the data.

Section 11 of the Statistics Act provides for the sharing of information with provincial and territorial statistical agencies that meet certain conditions. These agencies must have the legislative authority to collect the same information, on a mandatory basis, and the legislation must provide substantially the same provisions for confidentiality and penalties for disclosure of confidential information as the Statistics Act. Because these agencies have the legal authority to compel businesses to provide the same information, consent is not requested and businesses may not object to the sharing of the data.

For this survey, there are Section 11 agreements with the provincial and territorial statistical agencies of Newfoundland and Labrador, Nova Scotia, New Brunswick, Quebec, Ontario, Manitoba, Saskatchewan, Alberta, British Columbia, and the Yukon.

The shared data will be limited to business establishments located within the jurisdiction of the respective province or territory.

Section 12 of the Statistics Act provides for the sharing of information with federal, provincial or territorial government organizations. Under Section 12, you may refuse to share your information with any of these organizations by writing a letter of objection to the Chief Statistician and returning it with the completed questionnaire. Please specify the organizations with which you do not want to share your data.

For this survey, there are Section 12 agreements with the statistical agencies of Prince Edward Island, Northwest Territories and Nunavut.

For agreements with provincial and territorial government organizations, the shared data will be limited to business establishments located within the jurisdiction of the respective province or territory.

Record linkages

To enhance the data from this survey and to minimize the reporting burden, Statistics Canada may combine it with information from other surveys or from administrative sources.

Reporting Instructions

Please report information for a specific reference month in 2016.

Please complete all sections as applicable.

If the information requested is unknown, please provide your best estimate.

This guide is designed to assist you as you complete the Monthly Natural Gas Storage Survey. If you need more information, please call 1-877-604-7828.

Reporting Instructions and Natural Gas Definitions

Question 1: OPENING INVENTORY

1a: Opening inventory of base or cushion gas

Report total amount of base or cushion gas held by the establishment on the first day of the month under review. This should equal the closing inventory of the previous month.

Definition:

  • Base gas, also referred to as cushion gas is the amount of gas that must be present in storage at all times to maintain a storage facility’s pressure.

1b: Opening inventory of working gas

Report total amount of working gas held by the establishment on the first day of the month under review.  This should equal the closing inventory of the previous month.

Definition:

  • Working gas is the amount of gas that can be withdrawn from storage while maintaining a storage facility’s minimum operating pressure.

Total opening inventory of natural gas

Report total amount of natural gas held by the establishment on the first day of the month under review.  This should equal the sum of the base/cushion gas and working gas.

Question 2: CLOSING INVENTORY

2a: Closing inventory of base or cushion gas

Report total amount of base or cushion gas held by the establishment on the last day of the month under review. 

Definition:

  • Base gas, also referred to as cushion gas is the amount of gas that must be present in storage at all times to maintain a storage facility’s pressure.

2b: Closing inventory of working gas

Report total amount of working gas held by the establishment on the last day of the month under review. 

Definition:

  • Working gas is the amount of gas that can be withdrawn from storage while maintaining a storage facility’s minimum operating pressure.

Total closing inventory of natural gas

Report total amount of natural gas held by the establishment on the last day of the month under review.  This should equal the sum of the base/cushion gas and working gas.

Question 3: HEATING VALUE OF STORED NATURAL GAS

3:  Average heating value of stored natural gas in gigajoules per thousand cubic metres

Report average heat content of your natural gas held in storage for the month under review.

Question 4: INJECTED, WITHDRAWN AND INVENTORY ADJUSTMENTS OF NATURAL GAS STORAGE

4a: Injected in to storage

Report total amount of natural gas received by the establishment for month under review.

4b: Withdrawn from storage

Report total amount of natural gas delivered by the establishment for month under review.

4c: Other adjustments

This calculated amount is the difference between (1) opening and closing inventories and (2) injections and withdrawals. This difference includes discrepancies due to meter inaccuracies and/or leakage or other losses. Inventory adjustments can be a positive or negative value.

  • Inventory adjustments = (closing – opening inventories) – (withdrawals – injections)

Net withdrawals of natural gas from inventories

This calculated amount is the difference between (1) withdrawals and (2) the sum of injections and inventory adjustments. Net withdrawals can be a positive or negative value.

  • Net withdrawals = withdrawals – (injections + inventory adjustments)

Question 5: NATURAL GAS HELD IN THE UNITED STATES

5: Natural gas in storage facilities in the United States

Report total amount of natural gas held by the establishment in storage facilities located in the United States for eventual use in Canada.

 

Thank you for your participation.

Audit of the Data-sharing Agreement with the New Brunswick Department of Health

November 27, 2015
Project Number: 80590-91

Executive summary

Data-sharing agreements (DSAs) are a key Statistics Canada business process. In recent years, data sharing has become a growing and an increasingly complex area to manage. Ensuring confidentiality of data is becoming more complicated as business processes and organizational structures are continually changing. Statistics Canada's Health Statistics Division (HSD) enters into DSAs with provincial health ministries under the authority of section 12 of the Statistics Act.

The new omnibus agreement signed March 10, 2014, between Statistics Canada and the New Brunswick Department of Health (NBDH) allows for the collection and sharing of information from several selected health surveys. Under this agreement, statistical health survey information obtained through the Canadian Community Health Survey (CCHS), the National Population Health Survey (NPHS) and the Survey on Living with Chronic Diseases in Canada (SLCDC) is shared with the NBDH.

To protect the confidentiality and sensitive nature of the information collected, the DSA contains terms and conditions (T&Cs) to ensure that confidentiality of information is not compromised.

The objective of this audit was to provide assurance to the Chief Statistician and Statistics Canada's Departmental Audit Committee that

  • the terms and conditions of the Data-sharing Agreement between Statistics Canada and New Brunswick Department of Health were met.

The audit was conducted by Internal Audit Division in accordance with the Government of Canada's Policy on Internal Audit.

Key Findings

Statistics Canada's policy framework and the omnibus DSA provide clear roles, responsibilities and practices for the management and implementation of the DSA.

At the NBDH, the employees managing the Statistics Canada data are long-term employees who understand their roles and responsibilities as they relate to the receiving, storing and sharing of Statistics Canada data, but practices for the administration and use of Statistics Canada confidential information need to be strengthened. The process for granting network access to approved users by the Data Custodian and the process of reviewing the aggregate data reports prepared by the analysts before distribution are informal practices and lack documented evidence of review and approval.

Processes and procedures have been established and are monitored to fulfill the requirements in the DSA, however, the Data Custodian is not fulfilling all of the responsibilities prescribed in the DSA for the management of Statistics Canada data. The NBDH confidentiality document has not been updated to reflect all of the T&Cs in Appendix C of the DSA and, as such, employees are not familiar with the requirements that apply to them in the DSA. At the time of the audit, the Data Custodian had not signed a confidentiality agreement.  The official Register of Data Files Received from Statistics Canada and the Register of Access to Data Files are not maintained as stipulated in Appendix C of the DSA.

Effective controls for physical access to the NBDH's premises and physical storage at its off‑site data centre are in place. Logical access controls and effective practices for identification and authentication safeguards are working as intended.

Assessment of electronic access privileges to Statistics Canada data files revealed that employee access privileges are only removed when employees leave the NBDH or move to new position.  The audit noted that one approved user had access to Statistics Canada data from their residence.

Management at the NBDH identifies and assesses the appropriateness of existing controls to effectively manage their risks, and responds to and monitors their risk exposure. A monitoring clause is included in the omnibus DSA and the NBDH DSA template for third-party sharing. Currently the NBDH does not have any third-party agreements in place.

Overall Conclusion

Statistics Canada entered into a statistical data-sharing agreement with the NBDH on March 10, 2014, to assist and support health planning and decision-making. The omnibus DSA includes T&Cs governing the use, confidentiality, access, monitoring and compliance of information, and physical and information technology (IT) security.

While the audit revealed that processes and procedures have been established to support the handling and management of the T&Cs of the omnibus DSA, the NBDH must strengthen them to provide consistent understanding and efficient application of the requirements in the DSA and to ensure the sound management of Statistics Canada confidential information. The process for granting network access to approved users by the Data Custodian and the process of reviewing the aggregate data reports prepared by the analysts before distribution should be formalized to provide documented evidence of approval. The confidentiality document should be updated to reflect the requirements in Appendix C of the DSA. The Register of Data Files received from Statistics Canada and the Register of Access Privileges to Statistics Canada data should be maintained.

Effective physical and logical access controls are in place to safeguard Statistics Canada data in compliance with the DSA. However, access to Statistics Canada data should be granted to employees as necessary and only from a secure location within the premises of the NBDH to prevent unwanted disclosure of Statistics Canada data. Audit observations did not reveal any evidence that Statistics Canada confidential information was compromised.

Conformance with professional standards

The audit was conducted in accordance with the Internal Auditing Standards for the Government of Canada, which includes the Institute of Internal Auditors (IIA) International Standards for the Professional Practice of Internal Auditing.

Sufficient and appropriate audit procedures have been conducted and evidence gathered to support the accuracy of the findings and conclusions in this report and to provide an audit level of assurance. The findings and conclusions are based on a comparison of the conditions as they existed at the time, against pre-established audit criteria. The findings and conclusions are applicable to the entity examined, and for the scope and time period covered by the audit.

Patrice Prud'homme
Chief Audit Executive

Introduction

Background

The Health Statistics Division (HSD) at Statistics Canada has the mandate to provide accurate, timely and relevant information about the health of Canadians. The HSD provides statistical information about the health of the population, the determinants of health, and the scope and utilization of Canada's health care resources. This information is used to assist and support health planners and decision-makers at all levels of government, to sustain demographic and epidemiological research, and to report to the Canadian public about their collective health and health care system. The HSD works in partnership with provincial and territorial vital statistics registrars and cancer registries as well as data providers and users at the federal level (Health Canada and the Public Health Agency of Canada), provincial level (provincial ministries of health), and the regional level (health regions).

To achieve its mandate, the HSD enters into statistical data-sharing agreements (DSAs) with other organizations under the authority of sections 11 and 12 of the Statistics Act. These agreements cover nearly all of the business surveys and a majority of household surveys, and include certain exceptions regarding the release of confidential respondent information either with or without the respondent's consent, provided the legal requirements for the provision of data-sharing information, consent rights and confidentiality protection are respected by all parties. In general, data-sharing for statistical purposes occurs when a statistical and information inquiry is initiated by joint survey partners, or where a common data resource is equally and jointly owned by two or more partners. Data-sharing is exercised when there are significant reductions in response burden and compliance costs for data-sharing partners, as well as improvements in statistical data accuracy, coverage, relevance and timeliness.

DSAs are a key business process and ensuring the confidentiality and protection of data can pose challenges. Currently, Statistics Canada has an omnibus data-sharing agreement with the New Brunswick Department of Health (NBDH) covering health surveys, under the authority of section 12 of the Statistics Act. Health surveys for the Canadian Community Health Survey (CCHS), National Population Health Survey (NPHS) and Survey on Living with Chronic Diseases in Canada (SLCDC) are included in the agreement.

Through its mandate, the CCHS program collects information related to health status, health care utilization and health determinants for the Canadian population. The first component of the CCHS program is an annual survey (CCHS – annual), which relies on a large sample of respondents and is designed to provide reliable estimates at the health-region level. The second component focuses on a specific health-related topic such as nutrition, mental health or healthy aging, and is conducted approximately every three years. The uniqueness of the annual survey arises from the regional nature of both content and survey implementation.

The NPHS is a longitudinal survey providing unique information about the health of Canadians. The final cycle of this survey covered the period from 2010 to 2011. This survey, which was performed every two years, consisted of the same individuals providing current and in‑depth information on their physical and mental health status, use of health care services, physical activities, life in the workplace and social environment. It collected information related to the health of the Canadian population and related socio-demographic information. The last release will provide researchers with access to nine cycles of Canadian longitudinal health data to examine the dynamics of population health from 1994 to 1995 and from 2010 to 2011.

The SLCDC is a cross-sectional survey sponsored by the Public Health Agency of Canada that collects information related to the experiences of Canadians with chronic health conditions. The SLCDC takes place every two to three years, with two chronic diseases covered in each survey cycle. The objectives of the survey are to assess the impact of chronic health conditions on quality of life; provide more information on how people manage their chronic health conditions; identify health behaviours that influence disease outcomes; and identify barriers to the self-management of chronic health conditions. The last survey was performed in 2014.

The data are used extensively by the research community and other health professionals. Federal and provincial departments of health and human resources, social service agencies, and other types of government agencies use the information collected from the respondents to plan, implement and evaluate programs to improve health and the efficiency of health services. Non-profit health organizations and academic researchers use the information for research on ways to improve health.

Audit objectives

The objective of the audit was to provide assurance to the Chief Statistician and Statistics Canada's Departmental Audit Committee that:

  • the terms and conditions of the Data Sharing Agreement between Statistics Canada and New Brunswick Department of Health were met.

Scope

The scope included an examination of compliance with the terms and conditions prescribed in the DSA to ensure that confidentiality of information and the sensitive nature of the information collected were protected. The audit focused on the confidentiality and security (physical access, IT storage and transmission, physical storage and information copying, and retention and record management) safeguards at the NBDH to ensure that data were protected and confidentiality was maintained.

Approach and methodology

The audit work consisted of an examination of documents, interviews with key senior management and personnel, and a review of compliance with relevant policies and guidelines (see Appendix A: Audit Criteria for details).

The field work included the following:

  • a review and assessment of the processes and procedures outlined in the T&Cs of the DSA with the NBDH, with emphasis on whether or not the security requirements were in place and complied with, and that confidentiality of data was maintained
  • testing of system application controls and authentication and access procedures
  • a review of the third-party data-sharing agreement template.

This audit was conducted in accordance with the Internal Auditing Standards for the Government of Canada, which includes the Institute of Internal Auditors (IIA) International Standards for the Professional Practice of Internal Auditing.

Authority

The audit was conducted under the authority of the approved Statistics Canada integrated Risk-Based Audit and Evaluation Plan 2015/2016 to 2019/2020.

Findings, recommendations and management response

Control Environment for the Management of the Data-sharing Agreement

Authorities are defined and the Statistics Canada policy framework sets out clear roles, responsibilities and practices for the management and implementation of the DSA.

Processes and procedures have been established and the DSA is managed by long-term employees who understand their roles and responsibilities. However, practices for the administration and use of Statistics Canada confidential information need to be strengthened. The process for granting network access to approved users by the Data Custodian and the process of reviewing the aggregate data reports prepared by the analysts before distribution are informal practices and lack documented evidence of review and approval.

A monitoring clause is included in the omnibus DSA and the NBDH DSA template for third-party sharing. Currently, the NBDH does not have any third-party agreements in place.

Authorities, responsibilities and accountabilities should be clearly defined and understood at all levels to support effective management of the T&Cs of the omnibus DSA. Monitoring of practices as outlined in the T&Cs of the omnibus DSA should be in place to prevent unwanted disclosure of Statistics Canada data.

Authorities are defined

Statistics Canada exercises its mandate to enter into statistical data-sharing agreements with other organizations under the authority of sections 11 and 12 of the Statistics Act. The Directive on Data Sharing under sections 11 and 12 sets out the roles and responsibilities for the development, implementation and monitoring requirements of DSAs. The directive notes that the Information Management Division (IMD), in consultation with Legal Services, is responsible for drafting DSAs when requested from directors of statistical programs. IMD is also required to support managers during the development of new or modified DSAs with receiving parties pursuant to section 12 of the Statistics Act. Subject‑matter divisions are responsible for communication with recipient organizations during the negotiations and drafting of the agreements.

Processes and procedures for the management of DSA have been established at the NBDH

Statistics Canada confidential information is managed by two branches within the NBDH: the Analytics Branch has responsibility for the life-cycle of the Statistics Canada data; and the Health Business and Technology Solutions Branch provides technical services related to the Statistics Canada data, such as IT access privileges, IT storage, maintenance and security, as well as the electronic file transmission (e-FT) process used for the receipt of Statistics Canada data. Both groups report to the Assistant Deputy Minister (ADM) of Corporate Services, who has ultimate responsibility for the Statistics Canada health survey information.

Statistics Canada data are managed by long-term employees who understand their roles and responsibilities as they relate to the receiving, storing and sharing of Statistics Canada data. The same person has been the Data Custodian for the past 11 years. However, he has recently been assigned to another project with another department, and will be transferring his data custodian-related responsibilities to the Director of Analytics Branch upon his departure. However, the processes and responsibilities of the Data Custodian to fulfil the requirements of the DSA have not been documented. Although this is not a prescribed requirement in the DSA, the NBDH agreed that, as a good business practice, they will document them.

Practices for the administration and use of Statistics Canada confidential information need to be strengthened at the NBDH

At the NBDH, six users have access to Statistics Canada data—two program analysts and four statistical analysts from the Analytics Branch with responsibility for analyzing the data and providing aggregate data to the programs within the NBDH and to external organizations.

For the past 11 years, the Data Custodian has performed the duties associated with data handling, storage, and approving access to Statistics Canada data. Requests from users are received either by email or phone by the Data Custodian and, in turn, he contacts the IT group by email or phone to allow access privileges for the approved user. This is an informal practice that lacks evidence of a documented approval process as required by the T&Cs of the DSA.

Section 5 of the DSA has strict guidelines regarding the "Use of the Information." At the NBDH, the statistical analysts normally have access to the data for purposes of analyzing and providing aggregate data internally for statistical research purposes or as part of the NBDH's mandate to perform Community Health Assessments. The Data Stewardship Committee has developed a protocol to review their data against a list of identifiers before releasing or distributing aggregate data. Interviews revealed that there may be informal reviews performed on the aggregate reports prior to distribution, but this is not supported by a documented review and approval process. This is not in compliance with the DSA.

A monitoring clause is included in the omnibus DSA and in the NBDH DSA template for third-party sharing

Clauses with respect to monitoring are prescribed by Statistics Canada in the omnibus DSA with the NBDH. The DSA prescribes that third-party agreements entered into by the NBDH "shall contain a clause stipulating the right of Statistics Canada or the Receiving Party to review compliance with the terms of this Agreement."

The NBDH requires external organizations with which Statistics Canada data will be shared to sign a DSA. A review of the NBDH DSA template revealed that it includes an audit clause that states the "Contractor shall provide NBDH or its representatives with reasonable access to the Contractor and its facilities for the purpose of reviewing security measures and other records or information in order to perform audits and security reviews deemed necessary by DH and to ensure the Contractor's compliance with the terms and conditions of this Agreement."

The Data Custodian approves all requests for third-party sharing. Currently, the NBDH is not sharing Statistics Canada health survey information with any regional health authority, researcher under contract, provincial/territorial or university research institute, or any other organization.

Recommendations

The Assistant Chief Statistician, Social, Health and Labour Statistics field, should communicate with the New Brunswick Department of Health to ensure that

  • the approval process for granting access to Statistics Canada data is formalized to provide evidence of approval
  • the NBDH implements an approval or vetting process in compliance with the T&Cs of the DSA.

Management response

Management agrees with the recommendation.

  • The Director Health Statistics Division will prepare a letter to the NBDH and request that the approval process for granting access to Statistics Canada data be formalized, and will remind the NBDH to implement an approval/vetting process that complies with the T&Cs of the DSA.

    Deliverables and Timeline: HSD will prepare and send a letter by December 11, 2015 and request confirmation in writing.

Data Stewardship

At the NBDH, processes are in place and monitored to fulfill the requirements of the DSA, however, the Data Custodian is not fulfilling all of the responsibilities prescribed in the DSA for the management of Statistics Canada data. The NBDH confidentiality document has not been updated to reflect all of the T&Cs in Appendix C of the DSA and, as such, employees are not familiar with the requirements that apply to them in the DSA. At the time of the audit, the Data Custodian had not signed a confidentiality agreement. The official Register of Data Files Received from Statistics Canada and the Register of Access to Data Files are not maintained.

Management at the NBDH identifies and assesses the appropriateness of existing controls to manage its risks, and responds to and monitors its risk exposure.

Internal protocols and controls for the sound management of data should be in place to ensure the protection and safeguarding of Statistics Canada health survey information over the full lifecycle of the information.

Processes are in place and monitored to fulfill the requirements stipulated in the DSA

Data files are sent by Statistics Canada via e-FT directly to the Data Custodian at the NBDH. The files are password-protected and encrypted during transfer. Once a data file is received from Statistics Canada, the Data Custodian is notified that a file is in the e-FT vault and requests a password from Statistics Canada to access and decrypt the file. Afterwards, the Data Custodian sends Statistics Canada an acknowledgement of file receipt.

The data file is downloaded by the Data Custodian onto his secure personal network drive and then saved in a restricted folder within a Microsoft SharePoint folder where all the Statistics Canada data are stored and maintained. Once the file is saved in SharePoint, the Data Custodian deletes the file from his personal network drive. Testing revealed that the 'share files' received from Statistics Canada are stored in a SharePoint folder that is accessible by the employees who have been granted access to the data, and the 'link files' are saved in a SharePoint private folder accessible only by the Data Custodian. The Data Custodian is the only one who can approve access to the SharePoint document folder.

The Data Custodian is not fulfilling all the responsibilities prescribed in the DSA

As per Appendix C of the DSA, the Data Custodian is responsible for the following three key requirements: 1) prepare a confidentiality document and ensure that all individuals who access the Statistics Canada data sign this document; 2) maintain the Register of Data Files received from Statistics Canada; and 3) maintain the Register of Access to Data Files of all individuals granted access to Statistics Canada data files.

Confidentiality Document

Appendix C stipulates that the Data Custodian will "prepare a document for the use of the Receiving Party's employees and contractors, outlining the T&Cs governing the use of the information, as well as the procedures to send, receive, handle and store the information (hereinafter the "Confidentiality Document")." Prior to granting access to Statistics Canada data, the Data Custodian must ensure that every employee and contractor who will have access to the data has agreed in writing to comply with the terms of the DSA by signing and acknowledging that they have read, understood and agree to comply with the T&Cs of the DSA as highlighted in the Confidentiality Document.

The audit revealed that the confidentiality document used at the NBDH is outdated and has not been updated to reflect all of the requirements in Appendix C of the omnibus agreement signed on March 10, 2014, specifically related to sections 4, 5, 6 and 10, and Appendix A and Appendix B of the DSA. As a result, employees are not familiar with the requirements of these sections. All approved users with the exception of the Data Custodian have signed the outdated confidentiality agreement.

Register of Data Files

The audit revealed that the Register of Data Files received from Statistics Canada has not been maintained, as required. The NBDH had incorrectly assumed that all information required to be maintained was recorded in the SharePoint document folder. However, a review of the SharePoint site revealed that it was missing some of the required information such as the name of employee who received the file from Statistics Canada, the name of individual at Statistics Canada who sent the file, and the name of the employee responsible for safekeeping of the file.

Register of Access to Data Files

The Register of Access to Data Files has not been maintained either, as required. The NBDH provided a listing of all employees who had access to the Statistics Canada data on SharePoint, but the listing did not include all the required information such as the file name and reference period, name of employee or contractor to whom access is given, justification for access, name of person who authorized access, date of authorization, and start and end dates of the period for which access is authorized.

The NBDH has established a risk-management process to identify and monitor risks

The audit revealed that risks to the New Brunswick Department of Health (NBDH) are managed through its core policy framework (Corporate Privacy Policy; Privacy and Security Guide; and Information Security Framework Policy), which are based on the Right to Information and Protection of Privacy Act (RTIPPA) and the Personal Health Information Privacy and Access Act (PHIPAA) legislation, as well as the New Brunswick Government Information Technology Systems Security Policy (GISSP) Standards and Directives.

The Chief Privacy Officer (CPO) oversees the NBDH's privacy management program, which is a corporate-wide oversight and management component of the NBDH's privacy risks and responsibilities. A data stewardship committee chaired by the CPO deals with changes to policy and large data requests, and a working group assesses corporate gaps and ensures that gap recommendations are being addressed.

Employees are required to complete the General PHIPAA Training within six weeks of employment and annually thereafter; they are also asked to acknowledge and sign that they have reviewed and understood privacy and access, conflict of interest and Internet policies as part of their annual performance evaluations.

Processes for reporting privacy breaches are in place and governed by the Corporate Privacy Policy administered by the CPO, who records and investigates all privacy incidents. Interviews and a review of the NBDH 2014 Incident Report did not reveal any privacy incidents involving Statistics Canada data.

Recommendation

The Assistant Chief Statistician, Social, Health and Labour Statistics field, should communicate with the New Brunswick Department of Health to ensure that

  • the NBDH's confidentiality document is updated to reflect the requirements prescribed in Appendix C, and signed by the Data Custodian and approved users
  • the NBDH maintains the official Register of Data Files received from Statistics Canada with all of the information required under Appendix C of the DSA
  • the NBDH maintains the Register of Access privileges provided for Statistics Canada data as prescribed in Appendix C of the DSA.

Management response

Management agrees with the recommendation.

  • The Director Health Statistics Division will prepare a letter to remind the NBDH to update the confidentiality document to reflect the requirements prescribed in Appendix C of the DSA and to have it signed by the Data Custodian and all approved users; and to maintain the Register of Data Files Received from Statistics Canada and the Register of Access privileges as prescribed in Appendix C of the DSA.

    Deliverables and Timeline: HSD will prepare and send a letter by December 11, 2015 and request confirmation in writing as well as copies of the completed registers.

Physical and Information Technology Security

Effective controls for physical access to the NBDH's premises and physical storage at its off-site data centre are in place. Logical access controls and effective practices for identification and authentication safeguards are working as intended.

Assessment of electronic access privileges to Statistics Canada data files revealed that employee access privileges are only removed when employees leave the NBDH or move to a new position. The audit noted that one approved user had access Statistics Canada data from their residence.

Control and protection of information, either physical or electronic, should be executed in a manner that protects against loss, theft, compromise or improper disclosure. Access to the data should only be granted to employees or contractors as necessary to produce a survey-related product or service for the sole benefit and mandate of the NBDH.

Physical access and storage is secure

The NBDH offices are located in downtown Fredericton, and its data centre (where the Statistics Canada data server resides) is located off-site at a New Brunswick Government-owned facility managed by the New Brunswick Information Services Agency (NBISA). Stringent physical access controls exist at both locations, including the use of locked doors and a physical access card system, which is used for both the elevator and the rest of the premises. No guest-pass-card access is permitted, and visitors must be escorted by an NBDH-authorized person at all times. Interviews revealed that access cards are regularly updated to reflect employee departures.

A visit to the data centre revealed that the entrances to the building are equipped with security cameras. Pre-authorization is required to visit the data centre and, upon sign-in at reception, visitors must also sign a non-disclosure document. An annual audit of the sign-in log is conducted and reconciled against the access tickets issued to visitors. All servers and equipment are locked in cabinets and security cameras are located along certain server rows. The server room is equipped with a fire suppression system, cooling systems, and a backup power generator. The physical area housing the servers is protected by concrete walls, ceilings and floors.

Clauses for termination and return or destruction of the shared data no longer needed are included in the DSA. Prior to the implementation of the e-FT data transmission process, the Statistics Canada files were sent to the NBDH via encrypted CD ROMs. While all of the Statistics Canada data received by either CD ROM or e-FT are still in use and saved on the NBDH network, the Data Custodian indicated that the CD ROMs have now been destroyed.

Effective security measures are in place for identification and authentication safeguards, IT storage and data transmission

Testing of logical access controls with the Data Custodian and other employees of the Analytics group revealed that only employees who had been granted access to the Statistics Canada data could access the related SharePoint folder where the Statistics Canada data are maintained; and that only the Data Custodian had access to his personal folder on SharePoint where the Statistics Canada link files are maintained. A password was required to access the NBDH network, which automatically provides access to the SharePoint document folder. Access to the Statistics Canada data on SharePoint is restricted to employees approved by the Data Custodian. Only the Data Custodian and the Director of Analytics have read/write access to the data on SharePoint. The other six users have been granted read‑only access. Analysts download a copy of the file onto their secure private drive to work with the data as needed for their research/statistical purposes and they indicated that, once their analysis has been completed, they delete the file from their private drive.

Network access to Statistics Canada data files is not compliant with the T&Cs of the DSA

The T&Cs of the DSA stipulate that access to Statistics Canada confidential information at the NBDH is to be granted to employees as necessary to produce a survey-related product or service for the sole benefit and mandate of the NBDH. The audit tested this requirement by reviewing who has access privileges to the directory where the Statistics Canada data files are stored, along with the purpose and frequency of such access. The audit revealed that once employees have been granted access to the data, their access privileges are only removed when they move to a new position or leave the NBDH. Access privileges are not periodically reviewed.

Section 1 in Appendix A of the DSA states that "information must be accessed within a secure location that allows unescorted access, only to Authorized Persons." Interviews revealed that one approved user of Statistics Canada data can access data remotely from his home. The Data Custodian informed the audit team that the user has been verbally directed not to access Statistics Canada information remotely. The employee stated that he has not worked on or accessed Statistics Canada data in the last three to four years, but that he is still able to access the data from his residence. This is not compliant with the requirements of the DSA and could result in unauthorized access and use of the data, and confidential information being compromised.

Sound security measures exist for information copying, retention and records management

Information stored on the database servers is backed-up daily on encrypted tapes, which are stored off‑site in a secure building. A review of the NBDH's Security Policy Framework revealed that their security policies prohibit the transmission of data through fax or emails and data cannot be stored on transportable media devices (i.e., CD-ROMs, USB sticks, hard drives or laptops). Data are not to be removed from the premises or reproduced. Employees are required to ensure that confidential information is placed in locked shredding bins, the contents of which are to be removed by a private shredding company.

Recommendation

The Assistant Chief Statistician, Social, Health and Labour Statistics field, should communicate with the New Brunswick Department of Health to ensure that

  • access privileges to Statistics Canada data are periodically reviewed and access is only granted to employees in compliance with the  T&Cs of the DSA
  • employees only access Statistics Canada data from a secure location at NBDH premises in compliance with the  T&Cs of the DSA.

Management Response

Management agrees with the recommendation.

  • The Chief Statistician has requested the NBDH implement measures eliminating access to Statistics Canada data from outside a secure location.

    Deliverables and Timeline: The letter was forwarded on November 2nd, 2015 and a written confirmation was requested.
  • The Director Health Statistics Division will prepare a letter to remind the NBDH of the T&Cs related to granting access to Statistics Canada and of the physical access requirements stipulated in the DSA.

    Deliverables and Timeline: HSD will prepare and send a letter by December 11, 2015.

Appendices

Appendix A: Audit Criteria

Appendix A: Audit criteria
Control Objective / Core Controls / Criteria Sub-criteria Policy instrument
The T&Cs of the Data Sharing Agreement between Statistics Canada and New Brunswick Department of Health are met.
1.1 Authorities, responsibilities and accountabilities are defined and communicated, and the segregation of duties is appropriately established. 1.1.1 Responsibilities are formally defined and clearly communicated.

1.1.2 Authority is formally delegated and delegated authority is aligned with individuals' responsibilities. Where applicable, incompatible functions are not combined.
The Statistics Act

The Companion guide to the Statistics Act

Statistics Canada - Directive on Data Sharing under sections 11 and 12

Statistics Canada - Policy on Official Release

Statistics Canada - Security Practices Manual

Statistics Canada - Policy on the Security of Sensitive Statistical Information

Statistics Canada - Policy on Privacy Impact Assessments (PIA)

Statistics Canada - Policy on Informing Survey Respondents (ISR)

Statistics Canada - Policy on Micro-Data Release

Statistics Canada - Policy on Discretionary Disclosure and associated guidelines

TBS - Government Policy on Security

TBS - Standard on Physical Security

TBS - Directive on Departmental Security Management

TBS – Core Management Controls

Omnibus Data-sharing Agreement between Statistics Canada and NBDH
1.2 NBDH has established an appropriate framework to manage the requirements set out in the DSA. 1.2.1 Processes are in place to fulfill the requirements set out in the DSAs.

1.2.2 Processes are understood and are complied with.

1.2.3 Compliance with processes is monitored.
2.1 Management at NBDH identifies and assesses the appropriateness of existing controls to effectively manage its risks, and responds to the risks that may preclude the achievement of its objectives. 2.1.1 Risks are identified.

2.1.2 Formal processes and guidelines exist to assess the effectiveness of controls in place to manage identified risks.

2.1.3 Management formally responds to and monitors its risk exposure.
3.1 Assets are protected at NBDH. 3.1.1 Access to data is limited to authorized individuals and is appropriately secured in compliance with the DSA.

3.1.2 Physical access is restricted.

3.1.3 Procedures exist to safeguard the shared data upon termination of an agreement.

3.1.4 Procedures exist to protect the use of data from abuse or fraud.
3.2 Appropriate system application controls exist at the NBDH. 3.2.1 Logical access controls exist to ensure access to systems and data, is restricted to authorized users- (e.g., systems require users to logon using a unique user name and password).

3.2.2 Authentication and access procedures and mechanisms exist and are applied in order to keep authentication and access mechanisms effective.
4.1 Management monitors actual performance against planned results, and adjusts course as needed, to better address the requirements/ needs of the program. 4.1.1 Responsibility for monitoring is clear and communicated, and results are reported to required authority levels.

4.1.2 Active monitoring is demonstrated.

Appendix B: Acronyms and initialisms

Appendix B: Acronyms and initialisms
Acronym Description
ADM Assistant Deputy Minister
CCHS Canadian Community Health Survey
DSA Data-sharing Agreement
e-FT Electronic file transmission
NBDH New Brunswick Department of Health
HSD Health Statistics Division
IIA Institute of Internal Auditors
IMD Information Management Division
IT Information Technology
NPHS National Population Health Survey
TBS Treasury Board Secretariat
T&Cs Terms and conditions
SLCDC Survey on Living with Chronic Diseases in Canada

Section 9: Supplementary Documents


Appendix 1 – Statistics Canada Personal Information Banks related to Statistical Operations

Information about Programs and Information Holdings (formerly Info Source : Sources of Federal Government and Employee Information) provides information about the functions, programs, activities and related information holdings of government institutions subject to the Access to Information Act and the Privacy Act. It provides individuals and employees of the government (current and former) with relevant information to access personal information about themselves held by government institutions subject to the Privacy Act and to exercise their rights under the Privacy Act.

This appendix contains the main categories of personal information that Statistics Canada collects from respondents or obtains from other organizations. The full list and descriptions of Statistics Canada's Classes of Records and Personal Information Banks (PIBs) are available in Statistics Canada's Information about Programs and Information Holdings chapter, which is updated and published annually.

Categories of personal information

Surveys and censuses:

  • Aboriginal peoples
  • Age, sex and gender
  • Children and youth
  • Culture and leisure
  • Education, training and learning
  • Ethnicity
  • Energy use and expenses
  • Families and households
  • Health
  • Income and pensions
  • Languages
  • Labour and employment
  • Military/Armed Forces
  • Seniors
  • Spending and wealth
  • Travel and tourism
  • Victimization

Survey information is also collected on unincorporated businesses which may be considered personal information.

The complete list of Statistics Canada surveys is available on the Statistics Canada website under Definitions, data sources and methods.

Administrative data:

  • Cannabis
  • Credit and financial records
  • Education
  • Employment and employment insurance
  • Health records
  • Energy use and expenses
  • Housing
  • Immigration, citizenship, refugees
  • Income tax and benefits
  • Income support
  • Indian register
  • Licences and permits
  • Justice statistics
  • Pension plans
  • Personal insurance
  • Population and demography
  • Government personnel and payroll
  • Salary information
  • Social assistance
  • Social insurance register
  • Telephone use and expenses
  • Travel and tourism
  • Vehicle registrations

Administrative data is also obtained on incorporated businesses which may be considered personal information.


Appendix 2 – Minimum content to be included in a Supplement to the Generic Privacy Impact Assessment

Date:

Title:

Program manager:

Reference to Personal Information Bank:

New institutional PIB – Title, PRN, PSU (or "Under development")
Revised institutional PIB – Title, PRN, PSU
Revised standard PIB – Title, PRN, PSU

Description of statistical activity or procedures and systems:

Reason for supplement:

Mitigation factors:


Appendix 3 – Data Collection at Statistics Canada

The purpose of this appendix is to provide an overview of the different methods that Statistics Canada uses to collect information for its statistical programs. Each of these is addressed within the Threat and Risk Assessment in Section 6.

Traditionally, Statistics Canada has collected the majority of its information directly from the individual persons, businesses, institutions and organizations, who report for themselves.Footnote 1 This continues to be a significant approach to collecting information. The various modes of direct data collection are described briefly below.

An alternative approach to collecting personal information directly is to use administrative records produced by another organization for their own uses. This approach is usually a lower cost alternative to direct collection, represents no additional response burden, and is used whenever possible if the data quality of the administrative records is sufficiently high for Statistics Canada's use in its statistical programs. Even when quality may not be as high as desired, administrative data may be used. The decision on when to use administrative information requires a comparison of the data quality, respondent burden and costs of direct collection and the use of administrative information. Traditionally, Statistics Canada has collected administrative records from governments. However, the Agency now collects administrative records from businesses, such as pricing information on products and services.

Another option is used rarely, but may gain importance in the future. In certain cases, the information is available already on the organization's web site and Statistics Canada may obtain it directly. It is highly unlikely that such sources would contain personal information.

Overview of the direct survey collection process

The choice of the data collection methodology for social surveys considers a number of factors, such as survey budget, the number of persons/respondents included in the survey, the target population, the complexity of the survey subject matter, the number of survey questions and length of interview, telephone number and/or email address coverage in the geographic areas to be included, and, the timeframe within which the survey must be completed. For business surveys the data collection processes are influenced, among other factors, by the periodicity of the survey, the complexity of the business enterprise and the type of data collected. Some surveys may employ more than one data collection methodology.

For direct data collection of survey information, all of the collection methodologies follow a three-step process that includes:

  1. Preparation of the survey sample file and delivery of a questionnaire to the respondent: The sample file contains information about the persons or businesses to be included in the particular survey, such as contact information. In many cases, this contact information will not include respondent names; rather, it will be a set of civic addresses and may include telephone numbers or email addresses, if available. The information in this file is considered confidential (i.e, Protected B) under the Statistics Act. For many household surveys, the first step is collect a roster of all individuals living in a selected household along with some basic demographic information. From this, one household is randomly selected to receive the questionnaire. The information is used to deliver a survey questionnaire to the respondent through various means (telephone or face-to-face interview, mail-out of a paper questionnaire, or electronic delivery via the Internet).
  2. Data collection: Survey questionnaires are completed by the respondent (self-completed) or by a Statistics Canada Interviewer. In both cases, data are collected either electronically, through computer-assisted interviewing/e-questionnaire, or on paper depending on the collection methodology selected for the survey.
  3. Transmission of completed information: Completed questionnaires in paper or electronic format are transmitted to Statistics Canada for further processing.

Regardless of the collection methodology employed, once data are collected they are transferred to, or captured on, Statistics Canada's closed, private computer network, which is logically isolated from publicly-accessible means of communications, thus ensuring the protection of data collected under the authority of the Statistics Act. Processing of Statistics Act data outside of this network is prohibited.

For any statistical program, direct collection will include one or more of the following:

  • Mail-out / Mail-back (self-enumeration)
  • Paper and Pencil Interviewing (PAPI)
  • Computer-Assisted Personal Interviewing (CAPI)
  • Computer-Assisted Telephone Interviewing (CATI) - Decentralized
  • Computer-Assisted Telephone Interviewing (CATI) - Centralized
  • e-Questionnaire Service (web-based)
  • Collection of Human Biometrics and Biological Specimens
  • Collection of Information through the use of Monitoring Devices
  • Obtain records for a specific business (eg., financial statements) in addition to or in place of information provided on a questionnaire
  • Use of the E-file transfer service by a business to transmit its information in addition to or in place of information provided on a questionnaire

Wave collection: Statistics Canada recognizes that different respondents may have different preferences with respect to replying to requests for information. The wave approach to collection offers multiple opportunities and multiple modes for respondents. For example, a survey may first send a letter with a Secure Access Code (SAC) that a respondent may use to respond electronically using the e-Questionnaire service. Those that do not respond may then be called for a CATI interview, sent a paper questionnaire or be visited for a personal interview.

Mail-out / Mail-back (self-enumeration): Statistics Canada mails a questionnaire to each respondent in the survey. The questionnaire may:

  • be completely blank, and the respondent is asked to enter certain identifying information;
  • contain basic information, such as name or address;
  • contain detailed information about the respondent, such as information collected at a previous collection;

The respondent is asked to complete the questionnaire. Once completed, the respondent is asked to mail it back to Statistics Canada using the pre-addressed envelope included with the questionnaire.

Paper and Pencil Interviewing (PAPI): A Statistics Canada interviewer makes an appointment to visit the respondent's home. At that time, the interviewer asks the questions on the survey questionnaire and records the respondent's responses. PAPI interviewing may also be conducted by telephone, and the responses recorded on a paper questionnaire.

Computer-Assisted Personal Interviewing (CAPI): This method of collection is identical to PAPI, except that the questionnaire is electronic rather than on paper. The interviewer uses a computer that is owned by Statistics Canada and dedicated to data collection. The responses are entered into the computer.

Computer-Assisted Telephone Interviewing (CATI) - Decentralized: This method of collection is identical to CAPI, except that the collection takes place by telephone rather than in person. The interviewer calls the respondent from his/her home.

Computer-Assisted Telephone Interviewing (CATI) - Centralized: This method of collection is identical to decentralized CATI, except that the interviewer calls from a Statistics Canada office, rather than from home.

e-Questionnaire Service: Statistics Canada either mails a letter or sends an email to each respondent to inform them that they have been selected to take part in a Statistics Canada survey. The letter / email includes a Secure Access Code (SAC). The respondent uses the SAC to access the electronic questionnaire on Statistics Canada's web site. The respondent records the information directly. When completed, the information is stored in Statistics Canada's secure IT network.

Collection of Human Biometrics and Biological Specimens: For a small number of select surveys, Statistics Canada collects biometrics, such as height, weight and waist measurement, or biological specimens, such as blood and urine. The biological specimens must be sent to special laboratories for analysis so that the information may be used for statistical analysis. In most cases, Statistics Canada sends a report back to the respondent to inform on the results.

Collection of Information through the use of Monitoring Devices: As part of some surveys, respondents are asked to use monitoring devices that record specific information. Examples of monitoring devices that have been used are:

  • a monitor that a respondent wears to record level of activity;
  • a monitor to place in the home to record air quality;
  • sample of water quality (although not strictly speaking a monitoring device);
  • a monitor to place in the automobile to record driving information.

The monitor contains only an identification number that Statistics Canada can use to link to the individual and the information recorded by the device. No other personal information is recorded.

After the completion of the monitoring activity period, the device is sent to a designated facility to extract the information from the device and to delete the recorded information from the device. The designated facility forwards the information recorded on the device along with the device identification number to Statistics Canada.

Obtain records for a specific business (eg., financial statements) from that business in addition to or in place of information provided on a questionnaire: Rather than complete a questionnaire, Statistics Canada may ask respondents to send documents that they have already prepared. This is a means to reduce response burden. Statistics Canada would extract the information it needs from these documents.

Use of the E-file transfer service by a business to transmit its information in addition to or in place of information provided on a questionnaire: The E-file transfer service is primarily designed for the secure transmission of large files. In some cases, businesses may use it to transmit their electronic information.

E-file Transfer Service

This service was developed to permit secure electronic transmission of administrative files from other organizations to Statistics Canada. In addition to the uses described above, it provides for the secure transmission of large files from Statistics Canada to another organization, for such purposes as data sharing and data disclosure, when legally permitted.

Collection and Use of Phone Numbers and Email Addresses

Statistics Canada may contact respondents for collection by phone or email. It collects phone numbers and email addresses from respondents directly, from publicly-available sources as well as from a variety of administrative sources to which it has access. It is necessary to use all email addresses and phone numbers, including unlisted landline and cell phone numbers, to ensure that its surveys are representative of the population.

Statistics Canada treats all such phone and email contact information as confidential, and does not share it with any other organization, even within the Government of Canada. The confidentiality of Canadians’ phone and email contact information is assured by the Statistics Act. Statistics Canada destroys its information on phone numbers and email addresses when they are no longer useful, so it does not retain information for phone numbers or email addresses that no longer exist, or that are no longer linked to a specific individual or to a specific residential address.

As it is not a telemarketing agency, Statistics Canada is not subject to the requirements of the Do Not Call list.


Appendix 4 – Corporations Returns Act

There is one statistical program administered by Statistics Canada that falls outside the scope of the Statistics Act. The Corporations Returns Act program is mandated by this separate Act.

Program Description

The purpose of the Corporations Returns Act (CRA) is to collect financial and ownership information on corporations conducting business in Canada and to use this information to evaluate the extent and effect of non-resident control of the Canadian corporate economy. The Corporations Returns Act requires that an annual report be submitted to Parliament summarizing the extent to which foreign control is prevalent in Canada.

According to the Act, corporations or a group of corporations under common control conducting business in Canada whose assets for the reporting period exceed 600 million dollars or whose gross revenue, from business conducted in Canada, exceeds 200 million dollars are required to provide financial and ownership information to Statistics Canada. Corporations, under these limits, but having long-term debt or equity owing directly or indirectly to non-residents in excess of a book value of 1 million dollars must report ownership information only. The Act stipulates anyone who fails to complete and file a return is guilty of an offence and may be subject to legal proceedings.

The CRA data is a primary source of information about the foreign control of enterprises and mergers and acquisitions. This information can be found in The Corporations Returns Act – Foreign Control in Canada, Statistics Canada catalogue no. 61-220, report to Parliament. In addition, the CRA data provides the ownership information required for the Inter-Corporate Ownership (ICO) (quarterly) Statistics Canada catalogue no. 61-517, a product providing detailed information on corporate structures at the micro data level.

This program requires the name and address of the principal shareholders of the corporations and the number of shares held by each of them.

The ownership information provided by businesses (on Schedule I) is not confidential. According to the Corporations Returns Act, C-43, Article 16, "that information shall be made available by the Minister of Industry for inspection by any person, on application at any reasonable time and on payment of such fee, not exceeding one dollar in respect of any one corporation, as may be prescribed".

However, any other financial information to which the Corporations Returns Act ownership information is linked is confidential in unaggregated form. For this reason, the financial data contained in the Corporations Returns Act - Foreign Control in Canada, Report to Parliament, is tabulated in aggregate form to protect the confidentiality of businesses.

Personal Information held by the Program

Due to the nature of the information collected, the Program has limited personal information. The program has the following personal information for each director, officer and/or shareholder of every reporting corporation:

  • Surname
  • First name
  • City
  • Province/Territory
  • Country
  • Title or position held
  • Citizenship

This personal information is included in Schedule I – Ownership return and in accordance with the Corporations Returns Act, C-43, Article 16, "that information shall be made available by the Minister of Industry for inspection by any person, on application at any reasonable time and on payment of such fee, not exceeding one dollar in respect of any one corporation, as may be prescribed".


Appendix 5 – Generic Statistical Business Process Model (GSBPM version 5.0, December 2013)

Levels 1 and 2 of the Generic Statistical Business Process Model

Footnotes:

Footnote 1

In some surveys, proxy reporting is accepted whereby the proxy provides information for another individual. The proxy must be knowledgeable enough to report accurate information and must have the consent (often implicit) of the individual to whom the information belongs.

Return to footnote 1 referrer

Section 8: Information and Privacy Breach Protocol

Statistics Canada's statistical programs must meet agency standards for both IT and physical security. Physical security includes access controls to work places where personal information is stored, maintained or used, Identification cards for authorized individuals and monitoring cameras in public spaces. IT Security includes controlled physical access to the server for authorized personnel only, password protection for access to the server and to the database/tool, configuration and use of a firewall. For this reason, the threat and risk assessment (TRA) grid rates unauthorized access by either Statistics Canada employees or individuals outside Statistics Canada as low probability.

Upon discovery of an actual or suspected breach of security (however unlikely), the following steps would be taken:

  • Immediate notification of the Departmental Security Officer (Assistant Chief Statistician of Census, Operations and Communications Field) and the departmental Privacy Coordinator (Director, Information Management Division). Response could include suspending operation of the program(s).
  • In collaboration with Departmental Security and IT Security, there would be an internal investigation that would include recommendations to prevent any recurrence. Any investigation would document in detail the circumstances that gave rise to the privacy breach, and determine what information may have been breached, the impact of the breach, and what measures have been introduced to eliminate the risk of any subsequent breach.
  • In the case of a "material privacy breach", in accordance with the TBS Directive on Privacy Practices, Statistics Canada would notify the Office of the Privacy Commissioner (OPC) and the Treasury Board Secretariat (TBS). "Material breaches" are those involving sensitive personal information and that could reasonably be expected to cause serious injury or harm to the individual.
  • Impacted individuals would be provided with an explanation of the situation and the steps being taken to remove the information from the possession of those not authorized to have it. Individuals would also be informed that they have the right to file a complaint with the Office of the Privacy Commissioner (OPC). The OPC and TBS will be informed of the individual(s) whose information was disclosed, the investigation and what actions have been taken to prevent a re-occurrence.

The Protocol is reviewed on a regular basis to ensure continued relevance. Incident reports are reviewed regularly and lessons learned from incidents are incorporated into relevant policies, directives and survey practices.

Section 7: Summary of Analysis and Recommendations

A generic privacy impact assessment for Statistics Canada Statistical Programs  was conducted to determine if there were any associated privacy, confidentiality and security issues, and if so, to make recommendations for their resolution or mitigation.

This document summarizes Statistics Canada's assessment of the privacy implications of its Statistical Programs. It includes a review of the ten privacy principles as they apply to these programs. Also included is an assessment of the risks to the privacy, confidentiality and security of respondents'/participants' information.

While a number of potential privacy concerns have been identified, as expected, this assessment concludes that, with the existing Statistics Canada safeguards and additional safeguards that have been put in place, any remaining risks are either negligible or are such that Statistics Canada is prepared to accept and manage the risk.

There may be situations where a statistical program identifies privacy risks not covered in this generic PIA. In this event, either the newly identified risk(s) for a statistical activity will be assessed in a supplement to the generic PIA or a specific PIA may be conducted with respect to these additional risks.

Section 6: Threat and Risk Assessment

The purpose of this section is to assess potential threats and risks that could compromise privacy. It outlines existing Statistics Canada safeguards, the probability of occurrence of the threat, and the severity of the impact as it relates to the privacy and protection of personal information.

Statistics Canada currently employs numerous safeguards to reduce threat probabilities; these safeguards are described in agency policies, practices, tools and/or techniques.

Ratings for threat probability, impact and residual risk are defined and presented as follows:

Threat: An undesirable event with the potential to compromise privacy or breach data confidentiality.

Threat probability: The likelihood that the threat will occur, given the existing Statistics Canada safeguards. The threat probability is rated numerically.

  • Level 1: The threat can only come about through the use of very specialized knowledge and/or costly specialized facilities and/or a sustained effort. The threat is unlikely to occur.
  • Level 2: The threat requires some specialized knowledge and/or facilities and/or a special endeavor to create or take advantage of the threat opportunity. The threat is somewhat likely to occur.
  • Level 3: The threat opportunity is widely available and can occur either intentionally or accidentally with little or no specialized knowledge and/or facilities. The threat is very likely to occur.

Impact: The effect on the privacy of an individual in the event that a threat is realized and his or her information is compromised. The level or degree of impact is expressed in terms of outcome severity as it relates to individual privacy.

  • Level 1: Minor injury with no or minimal harm or embarrassment to the individual.
  • Level 2: Moderate injury causing some harm or embarrassment to the individual, but with no direct negative effects.
  • Level 3: Severe injury such as lasting harm or embarrassment that will have direct negative effects on an individual's career, reputation, financial position, safety, health or well-being.

Residual risk: A numeric rating is arrived at through an assessment and comparison of the threat probability and the impact to individual privacy.

Threat and Risk Assessment Grid: Statistics Canada Statistical Programs

  • TRA Grid A. Statistical Operations in Statistics Canada Head Office and its Regional Offices
  • TRA Grid B. Mail-out / Mail-back collection (MOMB)
  • TRA Grid C. Paper and Pencil Interview (PAPI)
  • TRA Grid D. Computer-Assisted Personal Interviewing (CAPI)
  • TRA Grid E. Computer-Assisted Telephone Interviewing – Decentralized
  • TRA Grid F. Computer-Assisted Telephone Interviewing- Centralized
  • TRA Grid G. E-Questionnaire Service
  • TRA Grid H. Collection Management Portal (CMP)
  • TRA Grid I. Contracting for services where personal information is transmitted, stored or accessed at the contractor's place of business
  • TRA Grid J. Collection of Information through the use of Monitoring Devices
  • TRA Grid K. Obtain records for a specific business (eg., financial statements) from that business in addition to or in place of information provided on a questionnaire
  • TRA Grid L. Use of the E-file transfer service by a business to transmit its information in addition to or in place of information provided on a questionnaire
  • TRA Grid M. Threats and Risks Applicable to all Modes of Direct Data Collection
  • TRA Grid N. E-File Transfer service
  • TRA Grid O. Transmission of Administrative Records to Statistics Canada (when E-File Transfer Service is not used)
  • TRA Grid P. Data Collection from Children
  • TRA Grid Q. Longitudinal Survey Data Collection
  • TRA Grid R. Collection and Analysis of Human Biometrics and Biological Specimens
  • TRA Grid S. Collection of Individual Information Directly from a Public Web Site
  • TRA Grid T. Record Linkage and Data Integration
  • TRA Grid U. Statistics Canada Research Data Centres (RDCs)
  • TRA Grid V. Statistics Canada Canadian Centre for Data Development and Economic Research (CDER)
  • TRA Grid W. Real Time Remote Access (RTRA)
  • TRA Grid X. Production and Dissemination of Public-Use Microdata Files (PUMFs)
  • TRA Grid Y. Production and Dissemination of Pre-release Microdata Files, Microdata Share Files, Work-in-progress datasets and Microdata Discretionary Disclosure Files (using E-File Transfer Service)
  • TRA Grid Z. Statistics Canada Official Release Process (excluding Pre-release) and Dissemination of Statistical Information
  • TRA Grid AA. Personal Information Collected from Clients of Statistical Information

Note: Individual Threat and Risk Assessment grids for Statistics Canada's statistical programs may be provided upon request by the Departmental Privacy Officer.

Section 5: Privacy Compliance Analysis

Principle 1: Accountability

Statistics Canada is responsible for all personal confidential information collected and used under authority of the Statistics Act. The Agency is responsible for all personal information under its control and has designated individuals who are accountable for the Agency's compliance with the obligations of federal departments to respect privacy rights as described in sections 4 to 8 of the Privacy Act.

Statistics Canada's mandate for its statistical programs is described in Section 3 of the Statistics Act. Its authority to obtain information to meet its mandate is described in Sections 7, 8, 13, 22 and 24 to 29 of the Act.

Managers of statistical programs, as directed by their line management (Divisional Director, Branch Director General and the Field Assistant Chief Statistician), are responsible for applying all relevant central Agency and Statistics Canada policies related to privacy and confidentiality protection of personal information.

Often, statistical programs seek guidance and direction from committees and groups outside the project team. Such groups include:

  • steering groups comprised of senior managers, possibly including individuals from outside Statistics Canada;
  • Provincial and Territorial statistical agencies, and provincial and territorial government departments;
  • Research Ethics Boards, to ensure that ethical research standards are maintained within the statistical program;
  • user groups comprised of key users of the information produced by the program, with significant participation from outside Statistics Canada;
  • international statistical groups, whose responsibility is to develop and maintain international standards for a particular statistical domain.

5.1.1 Overall accountability

Under the Statistics Act, the Chief Statistician, under the direction of the Minister Responsible for Statistics Canada, is accountable for the operations and staff of Statistics Canada. The Statistics Act provides Statistics Canada with the mandate to collect, compile, analyse, abstract and publish statistical information relating to the commercial, industrial, financial, social, economic and general activities and condition of the people. Data collected by Statistics Canada are used for statistical, research and analytical purposes, but not for administrative purposesFootnote 1. The Statistics Act provides the legal basis for maintaining the confidentiality of the statistical information (personal, business and institutional) that Statistics Canada collects. Divisional directors are delegated to act on behalf of the Chief Statistician with respect to specific responsibilities for the control of and access to confidential information which includes both personal and business information.

5.1.2 Organizational accountability

The Director, Information Management Division, is responsible for the development of Statistics Canada's policies related to information, including all aspects of information classification, control, and access and for providing advice, guidance, and assistance in the implementation of information security measures. The director is Statistics Canada's Privacy Coordinator and is accountable for the department's compliance with the principles contained in this document.

5.1.3 Divisional custodial accountability

Divisional directors are responsible for controlling and protecting all confidential information obtained by their division in the pursuit of its program objectives, as defined in the Statistics Canada Directive on the Security of Sensitive Statistical Information.

5.1.4 Performance and compliance reviews

The Internal Audit Division provides a systematic and independent review function to advise management on the adequacy of the Agency's control framework for its operational, financial and administrative activities, in terms of compliance, efficiency, and economy.

5.1.5 Data sharing agreements

The Statistics Act provides Statistics Canada with the legal authority to enter into an agreement with provincial and territorial statistical agencies for the sharing of information collected from a respondent by Statistics Canada where those agencies administer legislation containing protection for information provided by respondents, equivalent to federal law (section 11). The Act also allows for agreements with any federal or provincial/territorial government department, municipal government or other incorporated body such as an association or university (section 12).Footnote 2 This is done to reduce respondent burden and additional costs to Canadians where information is needed by another government department. The receiving organization (i.e., provincial/territorial statistical agency, department or municipal or other corporation) is accountable under the terms of the agreement with respect to the use and protection of any information it receives.

Statistics Canada has standard templates that it uses to formalize data-sharing agreements. Such agreements were developed, and reviewed regularly, in coordination with legal advisors in the Department of Justice to ensure that they meet all legal and policy requirements, including the TBS Guidance on Preparing Information Sharing Agreements Involving Personal Information.

5.1.6 Statistics Canada's Policy Suite

Statistics Canada has in place a framework of policies and related instruments to protect confidential personal, business and institutional information, to receive and respond to complaints and enquiries, to train and inform staff about these policies and procedures, and to explain the policies and procedures. As applicable, these are described in the sections that follow. As well, Appendix 5 provides a graphical link between the policy suite and the GSBPM.

Principle 2: Purpose

Statistics Canada will collect information only as required to fulfill its mandate, as defined by the Statistics Act.

When collecting data directly from respondents, Statistics Canada's Directive on Informing Survey Respondents requires that the principal purpose(s) of the survey (including the expected uses and users of the statistics to be produced from the survey) must be communicated to survey participants. Respondents are informed that their information may also be used by Statistics Canada for other statistical and research purposes, including record linkage.

When administrative data is collected from other organizations, Statistics Canada explains that the information will be used for statistical purposes.

Principle 3: Consent

The Agency's Directive on Informing Survey Respondents and its Directive on Record Linkage as well as the legal requirements of sections 11, 12 and 17(2) of the Statistics Act all incorporate principles related to consent. Section 8 of the Act provides the authority to the Chief Statistician to designate certain data collection activities as voluntary.

At the same time, it is recognized that there may be circumstances where information obtained by one institution for its own purposes (administrative) is used by another institution for a secondary purpose (statistical), without the knowledge of the individuals to whom the information related. The Statistics Act contains a provision, set out generally in section 13 (and for certain specific types of information in sections 24 through 29), for accessing records held by other organizations, both public and private, where those records are needed by Statistics Canada in the conduct of its statistical programs. Specifically, section 13 specifies the statutory authority for Statistics Canada to obtain access to records in any department (federal and provincial) or in any municipal office, corporation, business or organization where those records are required for purposes of the Statistics Act.

Statistics Canada's use of records obtained under section 13, as well as Sections 24 to 29, is limited to statistical purposes only. It reduces the burden of statistical enquiries on respondents and provides an alternative to the more costly traditional survey-taking activities.

5.3.1 Statistics Canada Directive on Informing Survey Respondents

Statistics Canada provides all respondents, prior to or at the time of collection, with information about the purpose of the survey (including the expected uses and users of the statistics to be produced from the survey), the authority under which the survey is taken, the mandatory or voluntary nature of the survey, confidentiality protection, the known record linkage plans and the identity of the parties to any agreements to share the information provided by those respondents, where applicable.

5.3.2 Mandatory or voluntary nature of the survey

The Agency's Directive on Informing Survey Respondents requires that respondents be advised explicitly whether taking part in the survey is mandatory or voluntary. Messages about the voluntary nature must be presented or available to respondents before they make a decision whether or not to participate in the survey. The information as to the mandatory/voluntary nature of the survey may be provided in various modes, such as on the questionnaire, in the introduction letter, orally by an interviewer, along with a clear description of the survey purpose. As well, the Information for survey participants module on the Statistics Canada web site is organized according to the survey title/program name, and includes this same information, as well as more detailed information that cannot be effectively and efficiently communicated in other ways.

In the case of voluntary household or business/institutional surveys, respondents are to be informed explicitly that their response is voluntary. Other information about the survey may be communicated first, but the voluntary nature of the survey must be communicated prior to any survey questions being asked. Should enquiries about the nature of the survey be made at any time, a direct response is to be provided immediately.

Even after having agreed to participate in a voluntary survey, respondents may choose not to answer specific questions they find sensitive or where they feel uncomfortable providing a response. As well, they may decide to stop participating part way through the collection.

In the case of mandatory household surveys, respondents are advised in a factual and non-threatening manner that their response is required by law. Traditionally, the Census of Population and the Labour Force Survey are the only household surveys Statistics Canada undertakes on a mandatory basis.

In the case of mandatory business/institutional surveys, respondents are informed that their response is required by law. In the case of surveys which include small businesses, the administration of the mandatory nature of the survey is carried out with due regard to the reporting burden of the business. Statistics Canada has an Ombudsman for Businesses, whose job is to liaise with businesses regarding their reporting to Statistics Canada, and with managers of business surveys regarding their data requests, to reach a balance between the two.

5.3.3 Record linkage plans

Statistics Canada's Directive on Record Linkage requires that respondents must be notified of planned and/or potential linkage of their survey responses to data from other surveys or administrative files. Notification may be specific or general, as explained in the directive. Planned linkages are those that are an integral part of the survey and are envisaged as the methodology is being developed.

Statistics Canada does not seek consent from respondents to conduct a record linkage, unless required by legislation or policy. The linked dataset will be used only for statistical purposes, and not for regulatory or administrative purposes. There is legal authority in the Statistics Act to "collect, compile, analyze, abstract and publish statistical information." The same Act obliges Statistics Canada to protect the confidentiality of "any information obtained under the Act in such a manner that it is possible to relate the particulars obtained from any individual return to any identifiable person, business or organization." In addition, Statistics Canada advises all its survey respondents that the collected information may be used for other statistical purposes.

If a respondent objects to having his/her information used for record linkage, the objection is recorded and no future record linkage will use this information.

For certain studies involving record linkage (for example, in the case of long-term health studies), Statistics Canada may determine that it is necessary to consult with appropriate representative groups before the linkage is approved. If the linkage involves a particular group and relates to a potentially sensitive issue, Statistics Canada may consult with representatives of the group involved, and with the Office of the Privacy Commissioner (OPC). As well, major new linkage projects are discussed with the OPC and, while the OPC does not formally approve record linkage projects, feedback from this consultation process in the past has proven to be very useful. In certain cases, a separate assessment may be undertaken to supplement the generic PIA.

5.3.4 Data Sharing Pursuant to Section 12 of the Statistics Act

Section 12 of the Statistics Act provides for the sharing of information, collected for statistical purposes by Statistics Canada, with any federal or provincial/territorial government department, municipal government or other incorporated body such as an association or university. Sharing of data is conditional on giving respondents prior notification of the proposed sharing, and giving them the right to refuse to allow their information to be shared.Footnote 3 Indeed not even the names of objecting respondents are provided to the other party in a share agreement. These agreements have terms and conditions that limit the use of information and provide for security requirements that are equivalent to those employed by Statistics Canada.

In many cases, such an agreement means that the other agency will not have to collect similar information through its own survey. The shared information is used for statistical purposes, except where the other party is authorized by law to require the respondent to provide this information. In such cases, the data are normally used for administrative or regulatory purposes by the other party, who are responsible for the access, use, storage, retention and disposition of the information.

Statistics Canada has standard templates that it uses to formalize data-sharing agreements. Such agreements were developed, and reviewed regularly, in coordination with legal advisors in the Department of Justice to ensure that they meet all legal and policy requirements, including the TBS Guidance on Preparing Information Sharing Agreements Involving Personal Information.

5.3.5 Information on the Statistics Canada website related to consent

The Statistics Canada website provides information related to privacy and consent:

  • privacy notice to survey respondents, clients, third party social media and visitors to the web site, along with contact information for the departmental privacy officer;
  • privacy-related policies and practices at Statistics Canada;
  • what record linkage is and how it is used at Statistics Canada;
  • approved record linkages at Statistics Canada, with their purpose, description and output.

The website provides information about Privacy impact assessments, providing a link to this generic PIA as well as summary descriptions of all approved specific PIAs.

As well, the web site provides "Information for survey participants":

  • the various surveys that Statistics Canada undertakes are listed, and information is provided for each one;
  • what Statistics Canada tells respondents when undertaking a survey;
  • what Statistics Canada asks for in responses to a survey;
  • the assurances that Statistics Canada makes in undertaking a survey.

5.3.6 Children: Obtaining information and seeking consent

Occasionally, Statistics Canada determines that it can best meet the objectives of a specific program by collecting information directly from children. Although circumstances may lead to a different approach in certain situations, the following general approach is used:

  • Children are defined as persons under a survey-specific age;
  • Consent is obtained from a parent or guardian to collect the information from the child;
  • Assent is obtained from the child, and furthermore, the child is told that he/she may choose to not answer any particular question.

Each survey determines its own definition of the age under which a person is considered a child. Factors considered in determining this age are definitions used by other programs, the nature of questions and the nature of the concepts. Overall, the decision aims to divide the survey respondents into those who can best provide the information; in some cases, it will be the person and in other cases it will be that person's parent or guardian.

With respect to seeking consent for data sharing or other statistical operations, Statistics Canada may decide to seek consent from the child or from the parent/guardian, regardless of who will be asked to respond to the survey questions.

Principle 4: Limiting Collection

The authority to collect information for Statistics Canada's statistical programs falls under the Statistics Act. Collection of the information is included in standard Personal Information Banks, listed in Appendix 1 below. Only personal information required for the purpose of the statistical program is collected.

The purposes for which confidential personal and business information is collected are communicated by Statistics Canada at or before the time the information is collected directly from respondents. The collection of confidential information is limited to that which is necessary to meet Statistics Canada's statistical purposes. All surveys undertaken by Statistics Canada are carried out under the authority of the Statistics Act.

An alternative approach to collecting directly from individuals is to use administrative records produced by another organization for their own uses. This alternative is usually a lower cost approach to direct collection, represents no additional response burden, and is used whenever possible if the data quality of the administrative records is sufficiently high for Statistics Canada's use in its statistical programs. Even when quality may not be as high as desired, administrative data may be used. The decision on when to use administrative information may require a decision related to data quality, respondent burden and relative costs.

In most cases, it is necessary for the other organization to transmit the information to Statistics Canada; however, in certain cases, the information is available already on the organization's web site and Statistics Canada may obtain it directly itself.

5.4.1 Statistics Canada Directive on Informing Survey Respondents

It is the policy of Statistics Canada to provide all respondents, prior to or at the time of collection, with information about the purpose of the survey (including the expected uses and users of the statistics to be produced from the survey), the authority under which the survey is taken, the mandatory or voluntary nature of the survey, confidentiality protection, the record linkage plans and the identity of the parties to any agreements to share the information provided by those respondents, where applicable.

5.4.2 Information on the Statistics Canada website related to the collection of confidential personal and business information

The Statistics Canada website contains the following information:

  • how Statistics Canada ensures relevance through consultation with and advice from various groups and individuals;
  • the various stakeholders in Statistics Canada data;
  • how statistical information is used;
  • protection of confidentiality and privacy;
  • what Statistics Canada does and its authority to do so.

The Statistics Canada website contains information for survey respondents:

  • the various surveys that Statistics Canada undertakes are listed, and information is provided for each one;
  • what Statistics Canada tells respondents when undertaking a survey;
  • what Statistics Canada asks for in responses to a survey;
  • the assurances that Statistics Canada makes in undertaking a survey.

Principle 5: Limiting Use, Disclosure and Retention

Statistics Canada will not disclose confidential personal information from its statistical programs without the consent of the respondent or unless as permitted by both the Statistics Act and the Privacy Act. Access to any information obtained under the authority of the Statistics Act is restricted to employees who must swear an oath of confidentialityFootnote 4 under the Act and who also have a need-to-know as part of their job duties.

Statistics Canada uses confidential personal and business information it collects or obtains under the Statistics Act only for statistical, research and analytical purposes, not for administrative purposes.

5.5.1 Statistics Canada Directive on Record Linkage

Statistics Canada recognizes the significant benefits of record linkage in meeting its mandate, while also recognizing the inherent privacy-invasive nature of the activity. Record linkage is a recognized important statistical tool. It results in the generation of a new dataset and new information, of which an individual is usually unawareFootnote 5. The benefits of a specific record linkage may include cost savings, higher data quality as compared to other options to obtain the information, and reduced burden on individuals who otherwise would be asked to supply the information themselves. When used for statistical analysis, record linkage cannot directly impact an individual as by nature, statistical analysis combines information from many individuals.

To achieve an appropriate balance between the statistical benefits and privacy invasiveness, Statistics Canada sets the following conditions for record linkage activities:

  • the purpose of the record linkage activity is statistical (as opposed to administrative) and is consistent with the mandate of Statistics Canada as described in the Statistics Act; and
  • the benefits to be derived from such a linkage are clearly in the broad public interest; and
  • in the case of research projects, the proposed analysis is methodologically sound and the linked dataset and analytical techniques are appropriate for the intended objectives; and
  • the products of the record linkage activity will be released only in accordance with the confidentiality provisions of the Statistics Act and with any applicable requirements of the Privacy Act; and
  • the record linkage activity has demonstrable cost or respondent burden savings over other alternatives, or is the only feasible option; and
  • the record linkage activity is judged not to jeopardize the future conduct of Statistics Canada's programs; and
  • the linkage satisfies a prescribed review and approval process; this includes formal approval by the Chief Statistician and, in cases where the linkage presents additional privacy concerns, review by Statistics Canada's Executive Management Board (its most senior management committee).

The directive recognizes that there are certain record linkage activities that are essential elements of programs and are regularly conducted. These omnibus approvals are not subject to the usual review and approval notice, having been pre-approved by Statistics Canada's Executive Management Board.

The first omnibus approval relates to the economic statistics program. All record linkage activities for this program are covered, except:

  • Linkages that would have significant privacy implications since they involve a high proportion of small and/or unincorporated businesses;
  • All linkage activities of the Agriculture Division;
  • Linkages that involve client-supplied lists of businesses;
  • Linkages that present a significant risk of residual disclosure.

The overriding considerations behind this authority are:

  • No linkage should damage our relationship with the business respondents.
  • No privacy-invasive linkages shall be carried out without a demonstrated public good. Privacy concerns are present when information from unincorporated businesses is linked.
  • If the linkage involves an externally-specified group of businesses, no files are to be linked if the results might harm the interests of that group.

Any linkages not meeting these criteria are not approved.

The second omnibus approval relates to the population and household statistics programs, and to privacy-sensitive economic statistics programs. There are two Parts to this second omnibus approval.

PART A: Linkages whose primary purpose is not to contribute directly to statistical outputs that are disseminated outside Statistics Canada

The purpose of linkages covered in this part is to do one of the following:

  • Obtain information that benefits a survey, such as for stratification in survey design, but that does not directly contribute to estimates;
  • Study and assess survey data quality, for example, by comparing survey data to data from other sources; and
  • Aid in data collection, such as to provide addresses to mail introductory letters or to provide telephone numbers to reduce collection costs by permitting data collection through a telephone interview.

PART B: Linkages whose primary purpose is to contribute directly to statistical outputs that are disseminated outside Statistics Canada

The following types of linkages are approved:

  • Linkage of supplementary surveys to the main survey: This is a situation where a second household survey is designed to use all or part of the sample of another household survey, and to reduce response burden by using content collected in the original survey. This second survey may be collected at the same time as the initial survey or at a later time, but the planned linkage for the second survey must be clearly planned prior to data collection begins for the main survey. Examples of surveys with supplements are the Labour Force Survey (LFS) and the Canadian Community Health Survey (CCHS). Another example is the linkage of the Census of Population data to that for a postcensal survey.
  • Longitudinal surveys: The linkage of survey information for the same individual but collected at different times. This applies to surveys that are designed to be longitudinal, and specified in the prescription order.
  • Linkage of administrative data to survey data when the linkage is clearly defined as part of the survey: This applies to situations where essential survey content is not collected as part of the direct data collection, but is planned to be taken from administrative files. An example is household surveys which do not ask questions on sources and amounts of personal income, but plan to link to income tax files to obtain the required income information.
  • Longitudinal linkage of personal administrative information: This applies to the longitudinal linkage of the same administrative file over time. An example is the Longitudinal Administrative Database (LAD), which links personal income tax files over time. Linkages of different administrative files, either longitudinally or cross-sectionally, are not included.

All linkages not covered by the omnibus linkage authority must follow the prescribed process to obtain approval.

Linkage projects that have been carried out which involve personal information are listed in the annual report to Parliament on the implementation of the Privacy Act. In addition, Statistics Canada also makes summaries of all approved record linkages (not just those involving personal information) available on its website (Statistics Canada)Footnote 6.

5.5.2 Informing respondents of record linkage plans

As part of the communications to persons whose information is requested, Statistics Canada informs respondents that record linkage is a standard tool used in the production of statistical information, and that Statistics Canada undertakes record linkages to meet its program objectives for reasons of greater efficiency and higher data quality. On its web site, Statistics Canada posts summaries of approved record-linkage projects, with the exception of most of the record linkage activities related to the omnibus linkage authorities.

5.5.3 Use of administrative records

The Statistics Act contains a broad provision, set out in section 13, for accessing records held by other organizations, both public and private, where those records are required for purposes of the legislation. Specifically, section 13 details the statutory authority for Statistics Canada to obtain access to records in any department (federal or provincial) or in any municipal office, corporation, business or organization where those records are required for purposes of the Statistics Act.

Statistics Canada's use of records obtained under section 13 is limited to statistical purposes only. It reduces the burden of statistical enquiries on respondents and provides an alternative to the more costly traditional survey-taking activities. At the same time, a major issue that inevitably arises from the use of administrative records for statistical purposes is the issue of privacy. This is because information obtained by one institution for its own purposes (administrative) is used by another institution for a secondary purpose (statisticalFootnote 7), without the knowledge of the individuals to whom the information relates. The privacy concern is mitigated by the fact that the statistical uses of the information do not result in a direct impact on any specific individual.

As well, section 24 of the Statistics Act gives Statistics Canada a specific right of access to federal income tax and excise tax records and section 25, the right of access to import and export records. The manner and times of the Agency's access to these records require the approval of the Governor in Council and are set out in MOUs between Statistics Canada and the Canada Revenue Agency and the Canadian Border Services Agency, respectively. Statistics Canada also has access to corporate tax records by way of the Corporations Returns Act which Statistics Canada administers.

There are also a number of specific provisions in the legislation giving Statistics Canada access to records relating to crime and justice statistics. Section 26 requires officials of criminal justice courts or tribunals to provide information. Similarly, section 27 requires sheriffs and penitentiary and reformatory wardens to provide Statistics Canada with information on prisoners, in the manner directed. Section 28 requires that court officials, sheriffs and wardens who are requested by Statistics Canada to provide information, ensure that they keep records that will enable them to provide that information. Finally, section 29 requires that the Solicitor General of Canada ensure that statistical information on pardons be provided to Statistics Canada.

5.5.4 Information on the Statistics Canada website related to the use of confidential personal and business information

The Statistics Canada website contains information about:

  • the relevance and use of the data;
  • what record linkage is and how it is used at Statistics Canada;
  • approved record linkages at Statistics Canada, with their purpose, description and output.Footnote 8

Under "Information for survey participants" on the Statistics Canada website, there is information about:

  • the various surveys that Statistics Canada undertakes are listed, and information is provided for each one;
  • what Statistics Canada tells respondents when undertaking a survey;
  • what Statistics Canada asks for in a survey;
  • the assurances that Statistics Canada makes in undertaking a survey.

5.5.5 Mandate of Statistics Canada

Statistics Canada collects only information which it uses to meet its mandate.

The Statistics Act provides Statistics Canada with the mandate to collect, compile, analyze, abstract and publish statistical information relating to the commercial, industrial, financial, social, economic and general activities and condition of the people. Data collected are used for statistical, research and analytical purposes, but not for administrative purposes.

5.5.6 Obligation to protect confidentiality

The Statistics Act provides the legal basis for maintaining the confidentiality of personal and business information that Statistics Canada collects. Section 17(1) of the Act requires that:

  1. No unauthorized personFootnote 9 may examine any identifiable information collected under the Act; and
  2. no authorized person may "disclose or knowingly cause to be disclosed any information collected under the Act in such a manner that it is possible to relate the particulars to any identifiable individual person, business or organization".

The Access to Information Act, in section 24, also provides for this confidentiality, recognizing that information collected under the Statistics Act and protected by section 17 of that act cannot be made available to anyone attempting to obtain it using the Access to Information Act.

The Privacy Act also generally protects collected personal information from disclosure. The provisions under subsection 8(2), which permit the disclosure of personal information, without the consent of the individual, cannot be applied in the case of personal information collected under the Statistics Act. Subsection 8(2) of the Privacy Act is subject to other Acts of Parliament, in this case the Statistics Act, and therefore does not take precedence over the specific statutory confidentiality protection found in the Statistics Act.

Statistics Canada will not disclose confidential personal information other than with the consent of the respondent or the original data provider, and as permitted by the Statistics ActFootnote 10. Identifiable personal information is retained only as necessary for the fulfillment of Statistics Canada's mandate and, in the case of Census of Population records, as required by the Library and Archives of Canada Act.

5.5.7 The oath of office

As legally required by Section 6 of the Statistics Act, before taking up duties under the Statistics Act, all employees must take an oath or solemn affirmation that they will conform to the requirements of the Act and will not, without due authority, disclose or make known any confidential information.

5.5.8 Penalties for violations

Employees who contravene the confidentiality provisions of the Statistics Act are subject to prosecution and are liable on summary conviction to a fine and/or imprisonment, as described in sections 30 and 34 of the Statistics Act.

5.5.9 Confidentiality measures at Statistics Canada

The following measures are in place at Statistics Canada to maintain confidentiality in the statistical information the Agency produces and to keep the principle of confidentiality in the forefront of all its employees' consciousness:

  • the Oath of Office, in addition to being a requirement of the Statistics Act, is also designed to impress upon each employee the need for preserving the confidentiality of information;
  • courses for new employees that emphasize confidentiality and mandatory refresher courses of ongoing employees;
  • dissemination of information containing quantity and frequency distributions are subjected to confidentiality edit procedures;
  • all public-use microdata filesFootnote 11 are reviewed by the Microdata Release Committee before their release to ascertain that the files do not contain any information that could lead to the identification of any respondent;
  • the Microdata Release Committee systematically reviews the various disclosure control strategies practiced by program areas in terms of their adequacy and consistency and promotes sound principles and best practices relating to confidentiality and inferential disclosure;
  • Statistics Canada's Disclosure Control Resource Centre provides advice and assistance to Statistics Canada programs on methods of disclosure risk assessment and control; develops disclosure control methods; maintains an inventory of methods for assessing and controlling the risks of disclosure for data products disseminated by Statistics Canada; supports the work of the Microdata Release Committee, particularly with respect to disclosure review procedures; fosters a better appreciation among respondents, data users and the general public of Statistics Canada's disclosure control practices;
  • training is provided to specialists, interviewers and survey managers in the areas of disclosure control, data quality, confidentiality and security;
  • documents on confidentiality are readily available to all employees on Statistics Canada's Internal Communications Network and the Confidentiality Awareness Program website including Statistics Canada's Security Practices Manual and Statistics Canada's Policy Suite;
  • detailed training and relevant documentation is provided to deemed employees working on research projects in an RDC or in CDER;
  • The Statistics Act, the Privacy Act, the Corporations Returns Act, the Access to Information Act and other relevant legislations are available to employees;
  • breaches of confidentiality, should they occur, are reported formally to the Departmental Security Officer as specified in the departmental Information and Privacy Breach Protocol (see section 8 below).

5.5.10 Retention of personal identifiers

It is Statistics Canada's practice to remove personal identifiers from statistical master files when they are no longer required for data processing. If retained for future use, the personal identifiers are to be stored separately from the statistical master file.

In the case of linked files, the requirement to maintain personal identifiers (e.g., name or unique identification number such as health number) is based on need. Linked files will be retained until no longer needed.

5.5.11 Disclosure of confidential personal and business information

The disclosure of confidential personal and business information collected under the Statistics Act is limited to the following circumstances:

Data sharing agreements

Section 11 of the Statistics Act recognizes the special status of provincial and territorial statistical offices that administer their own statistical legislation. It provides the authority for the Minister, with the approval of the Governor in Council, to enter into agreements to share data collected jointly with the statistical agencies of provinces and territories for statistical purposes. Thus, information can be shared with these agencies if (i) respondents were notified at the time of collection, (ii) the agencies has the statutory authority to collect the information on their own on a mandatory basis, (iii) the agencies' confidentiality protection requirements are substantially the same as those of Statistics Canada, and (iv) the Chief Statistician approves the data sharing. Agreements must be in place at the time the information is being collected. In other words, information cannot be shared retroactively.

Section 12 of the Statistics Act provides for the sharing of information, collected for statistical purposes by Statistics Canada, with any federal or provincial/territorial government department, municipal government or other incorporated body such as an association or university. Sharing of data is conditional on giving respondents prior notification of the proposed sharing, and giving them the right to refuse to allow their information to be shared.Footnote 12 Indeed not even the names of objecting respondents are provided to the other party in a share agreement. A respondent's right of refusal to the sharing of information does not apply if the department is authorized by law to require the respondent to provide that information. As is the case for agreements with provincial and territorial statistical agencies, agreements must be in place prior to data sharing. These agreements have terms and conditions that limit the use of information and provide for security requirements.

In many cases, such an agreement means that the other agency will not have to collect similar information through its own survey. The shared information is used for statistical purposes, except where the other party is authorized by law to require the respondent to provide this information. In such cases, the data are normally used for administrative or regulatory purposes by the other party. After Statistics Canada provides the information to the other party, the information is subject to the applicable legislation.

Statistics Canada has standard templates that it uses to formalize data-sharing agreements. Such agreements were developed, and reviewed regularly, in coordination with legal advisors in the Department of Justice to ensure that they meet all legal and policy requirements, including the TBS Guidance on Preparing Information Sharing Agreements Involving Personal Information.

Discretionary disclosure

The Statistics Act (subsection 17(2)) gives discretion to the Chief Statistician to release certain types of identifiable information. This discretion is limited and specific and includes the following types of information:

  • information collected by persons, organizations or government departments for their own purposes and communicated to Statistics Canada as long as the secrecy requirements to which this information was subjected when first collected are adhered to, and an agreement for disclosure is made between the Chief Statistician and the collector;
  • information relating to a person, organization or business if the person, organization or owner of the business consents to the disclosure in writing.

In exercising this discretion, the Chief Statistician is guided by the Directive on Discretionary Disclosure which sets out a review and approval process for all requests for disclosure of information under sub-section 17(2) of the Statistics Act.

According to the Directive on Discretionary Disclosure, the Chief Statistician may authorize disclosure when:

  • the information is needed for statistical or analytical purposes; and
  • the information released does not disadvantage Statistics Canada's respondents and does not harm the relationship between the Agency and its respondents.

Ultimately, it is only the Chief Statistician who can authorize disclosure and then, only within the limits set out in sub-section 17(2) of the Statistics Act. By law, the Chief Statistician must sign an Order to authorize the disclosure.

Work-in-progress and Advanced Release

Work-in-progress datasets, analytical products and information products may be provided in advance of official release by Statistics Canada to designated individuals of external organizations for the purposes of data validation. These are cases where it can be shown that the receiving individual or organization is qualified to provide the required validation, and where significant benefits to data quality are anticipated or have been previously demonstrated.

Work-in-progress datasets may contain personal informationFootnote 13, whereas analytical products and information products do not.

When providing work-in-progress data to external organizations for data validation, divisions are required to provide only the information that requires validation for a pre-established review period that is as brief as possible. The method of providing advance release information to external organizations must meet Statistics Canada's security requirements for transmission of sensitive statistical information.

Organizations receiving protected release information from Statistics Canada must:

  • safeguard the confidentiality of the protected release information provided to them;
  • limit access to the protected information to those designated officials within their organizations for work-related purposes ('need-to-know' basis);
  • undertake not to further disseminate the protected release information;
  • destroy the protected information once the review is completed, prior to official release.

Advance release of the text of an official release may occur under certain specific and restrictive situations. Texts of official release do not contain personal information, so there are no privacy risks associated with advanced release.

5.5.12 Access to confidential information by researchers as deemed employees of Statistics Canada

The Statistics Act permits Statistics Canada to use the services of persons outside Statistics Canada to carry out any function or perform work pursuant to the Statistics Act. Such persons are considered to be "deemed employees" of Statistics Canada. One area where Statistics Canada employs deemed employees is in conducting statistical research that requires access to confidential microdata. Such access is subject to Statistics Canada's Directive on the Use of Deemed Employees.

Located in most Canadian universities, Research Data Centres (RDCs) provide researchers with access, in secure premises, to microdata from population and household surveys, as well as to certain administrative datasets. The centres are staffed by Statistics Canada employees. They are operated under the provisions of the Statistics Act in accordance with all the confidentiality rules and are accessible only to researchers with approved projects who have been sworn an oath under the Statistics Act as deemed employees.

Similar to a RDC, the Statistics Canada Canadian Centre for Data Development and Economic Research (CDER) provides access to business microdata. The centre is located within Statistics Canada's Head Office. Deemed employees are not permitted to examine individual microdata, and work closely with a Statistics Canada employee to meet the objectives of the research project. The business microdata, particularly those for large firms, are considered to require this additional protection.

5.5.13 Real Time Remote Access (RTRA)

Another approach to provide researchers with access to detailed microdata is the Real Time Remote Access (RTRA) Application, already used by a number of other statistical agencies throughout the world. This application is essentially an on-line remote access facility allowing users to run, in real time, data analyses on microdata or lightly masked microdata sets, defined as confidential under the Statistics Act, that are kept in a central and secure location under the control and care of Statistics Canada, with the output vetted for confidentiality.

A limited number of researchers in other federal government departments are issued a username and password so they can remotely submit SASFootnote 14 programs to a secure Statistics Canada server. The submitted job requests use a modified version of SAS that will place limits on their requests and the subsequent outputs. Before being sent back to these researchers, results will be vetted to prevent disclosure of confidential information.

5.5.14 Retention of statistical information

As part of its Information Management program, Statistics Canada has a directive and a guideline that address the retention of statistical information:

  • Directive on the Management of Statistical Microdata Files
  • Guideline on the Management of Statistical Microdata Files and Aggregate Statistics

Generally, target retention periods are assigned to different types of statistical information. On an exception basis, a different retention period may be assigned when the information is created. Statistical information is disposed of once it has served its purpose or its retention period has expired.

The general philosophy is that information is retained only as long as is operationally required. With only a few exceptions, all files types have very short retention periods (a few years). Specifically two types of files have longer retention periods:

  • Internal master (analytical) files with direct personal identifiers removed: Indeterminate. With very few exceptions, these files never lose their statistical value. Their use is governed by the Statistics Act and supported by Statistics Canada's policies and procedures to protect the information.
  • Identifier files (Files containing direct identifiers that have been separated from statistical information): Retain as long as operational requirements remain. In many cases, this information is used only to support contacting individuals to collect information. In the case where future studies are planned that require the use of direct identifiers, very specific security procedures apply. The files containing direct identifiers are stored in Statistics Canada Head Office, and access to these files is limited to only a few people for work-related purposes.

Principle 6: Accuracy

To the extent possible, managers of statistical programs follow standard procedures that adhere to Statistics Canada's policy suite related to the accuracy of personal information.

The accuracy of information collected under the Statistics Act is dependent on our survey respondents and data providers. It is important to remember, however, that unlike other government departments that may use confidential personal or business information to make decisions, for example on eligibility for benefits, Statistics Canada uses information to produce statistical aggregates that are then disseminated for statistical, analytical and research purposes.

Statistical programs have edit and corrections processes to collected data to ensure accuracy for statistical purposes.

In cases where respondents request corrections to information they have provided to Statistics Canada, the Agency will consider these on a case-by-case basis. It is important to remember, however, that once individual survey responses are received and processed, it would not be possible to locate specific records of individuals after names or other identifiers have been removed from the survey file. As well, there may be other situations where the copy of the original records exists in a format that does not permit changes to be made (for example, microfilm, in the case of historical census records).

Starting with the 2006 Census, Canadians were given the opportunity to decide whether they will allow their personal census records to be made public 92 years after the census. Census records will be made public only when consent has been given. In cases where someone later decides to change their response, Statistics Canada will accept any such request. There is no time limit on when such a request will be accepted, up to the point at which the information is released.

5.6.1 Statistics Canada's commitment to quality

Given the widespread use of its data by the Canadian public and media, various levels of government, businesses and labour unions, the academic sector, foreign and international bodies, Statistics Canada strives to build quality into all its programs and products. Its quality assurance framework identifies six primary elements of quality: accuracy, relevance, timeliness, accessibility, interpretability and coherence.

To help ensure the accuracy of the confidential personal and business information that it collects from respondents, Statistics Canada has in place the following policies, guidelines and practices:

  • requirements for the testing of new and revised questionnaires in both official languages before implementation and for the periodic evaluation of questionnaires used in ongoing surveys (Policy on the Review and Testing of Questionnaires);
  • consultation with interviewers to identify problem areas where questionnaires can be improved (Policy on the Review and Testing of Questionnaires);
  • the adoption of standard concepts and definitions for the collection of data and consistent collection and processing methods for the production of statistical data across surveys (Policy on Standards);
  • quality guidelines for all its statistical projects, including activities related to the specification of objectives and uses in consultation with users, questionnaire design, data collection operations, editing of data records that are potentially in error and data quality evaluation (Quality Guidelines).

Principle 7: Safeguarding Personal Information

Statistics Canada takes seriously its legal obligation to safeguard the personal information of all Canadians. Therefore, for many years, the Agency has had in place a framework of policies, directives, procedures and practices to protect confidential information, including personal information, against loss, theft, unauthorized access or disclosure; they are supported by physical, organizational and technological measures that protect all the personal information that Statistics Canada holds.

Statistics Canada's Security Practices Manual details required specific administrative, physical and technical safeguards against loss or theft, unauthorized access or use of personal information. The Directive on the transmission of protected information describes security procedures that are necessary when transmitting confidential information into and out of Statistics Canada's Head Office.

5.7.1 Technology and privacy issues

Program managers must:

  • identify any changes to the business requirements that have an impact on the system, software of program application and, consequently, may affect the current access controls and privacy practices related to the creation, collection, retention, use, disclosure and disposition of personal information, and implement changes as deemed necessary.
  • Determine whether the current IT legacy systems and services that will be retained or those that will be substantially modified are compliant with privacy requirements, and implement changes as deemed necessary.
  • Develop and implement, for program staff, awareness activities related to the protection of privacy requirements in the new electronic environment.

5.7.2 Legal obligation to protect confidentiality

The Statistics Act provides the legal basis for maintaining the confidentiality of personal and business information that Statistics Canada collects. Section 17(1) of the Act requires that:

  1. No unauthorized personFootnote 15 may examine any identifiable information collected under the Act; and
  2. no authorized person may "disclose or knowingly cause to be disclosed any information collected under the Act in such a manner that it is possible to relate the particulars to any identifiable individual person, business or organization".

5.7.3 The oath of the office

Before taking up duties under the Statistics Act, all employees must take an oath or solemn affirmation that they will conform to the requirements of the Act and will not, without due authority, disclose or make known any confidential information.

5.7.4 Penalties for violations

Any actions that contravene the security policies of the Government of Canada or Statistics Canada could lead to administrative, disciplinary or statutory penalties when misconduct or negligence is involved. The nature of the penalties will depend on the nature of the offence. Employees who contravene the confidentiality provisions of the Statistics Act are subject to prosecution and are liable on summary conviction to a fine and/or imprisonment.

5.7.5 Security measures at Statistics Canada

The following describes some of the security measures in place at Statistics Canada to maintain a secure environment and to keep the principle of security in the forefront of all its employees' and deemed employees' consciousness:

  • access to Statistics Canada buildings is controlled by a combination of physical measures and access procedures;
  • all external visitors are escorted to the work area, accompanied while in the work area, and escorted back to the building entrance at the end of the visit;
  • employees' and visitors' identification cards must be visible at all times;
  • all staff undergo a reliability check;
  • only those Statistics Canada employees with a "need to know" have access to confidential information and then only to that information required for them to do their job;
  • within Statistics Canada, inter-divisional access to confidential information must be approved by the director of the division holding the information;
  • disposal of confidential information is carried out under secure conditions according to government-approved procedures;
  • non-computerized confidential data are stored in security-approved containers;
  • Statistics Canada's IT Security Policy outlines the safeguards the Agency has put in place to ensure that its information systems are kept secure, including:
    • data processing and communications networks are configured to prevent physical and electronic access to confidential information from outside Statistics Canada's facilities;
    • access to files is protected through access controls, passwords and servers located in access-controlled areas;
    • communications between Statistics Canada locations are facilitated through the use of secure data transmission lines and services specifically approved for that purpose;
    • computing devices with external wireless connections may not be connected to any Statistics Canada network;
    • electronic transmission of confidential information under specific special circumstances must adhere to approved security procedures;
    • transmission of microdata files containing confidential information to Statistics Canada Regional Offices, Research Data Centres or to data-sharing partners must follow approved security procedures; such information must be encrypted;
    • storage of confidential information on any removable storage media must follow approved security procedures; such information must be encrypted;
  • confidential information may not be taken out of Statistics Canada's secure premises;
  • after they are no longer required for data processing, direct personal identifiers are removed from statistical master files;
  • breaches of security are reported formally to the Departmental Security Officer, who will implement the departmental Information and Privacy Breach Protocol.

Information on security is readily available to all employees on Statistics Canada's Internal Communications Network.

Principle 8: Openness

Statistics Canada makes readily available specific information about its policies and practices relating to the management and protection of personal information. Information regarding the use of personal information in the form of a Privacy notice can be found on the agency's website at Statistics Canada.

Summaries of approved Privacy Impact Assessments are also available from the website.

5.8.1 Statistics Canada Directive on Informing Survey Respondents

It is the policy of Statistics Canada to provide all respondents with information about: the purpose of the survey (including the expected uses and users of the statistics to be produced from the survey), the authority under which the survey is taken, the mandatory or voluntary nature of the survey, confidentiality protection, the record linkage plans and the identity of the parties to any agreements to share the information provided by those respondents, where applicable. This information is communicated to respondents in different modes, depending on the survey. All information is available on the Statistics Canada web site.

5.8.2 Information on the Statistics Canada website related to policies and procedures

On the Statistics Canada website, there is information about:

  • protecting confidential information and privacy at Statistics Canada;
  • privacy-related policies and practices at Statistics Canada;
  • what record linkage is and how it is used at Statistics Canada;
  • Statistics Canada's Record Linkage Directive;
  • approved record linkagesFootnote 16 at Statistics Canada, with their purpose, description and output.

Under Information for survey participants on the Statistics Canada website, there is information about:

  • the various surveys that Statistics Canada undertakes, and information is provided for each one;
  • what Statistics Canada tells respondents when undertaking a survey;
  • what Statistics Canada asks for in a survey;
  • the assurances that Statistics Canada makes in undertaking a survey.

5.8.3 Info Source: Sources of Federal Government information

As required by the Privacy Act, all Statistics Canada surveys that collect and retain personal information in identifiable form are registered as personal information banks and are included in Info Source: Sources of Federal Government Information. Info Source contains the identification and description of the personal information bank, its registration number, a description of the group of individuals to whom personal information contained in the bank relates, the name of the government institution that has control of the bank, the purposes and consistent uses of the information bank, the retention and disposal standards applied to information in the bank and the contact person to whom requests relating to personal information should be sent. See Appendix 1 for specific details on Statistics Canada's specific personal information banks related to its statistical operations. Requests about personal information held by Statistics Canada should be directed to Statistics Canada's Access to Information and Privacy Coordinator as noted in Principle 9.

5.8.4 Record linkage activities

Linkage projects that have been carried out which involve personal information are listed in the annual report to Parliament on the implementation of the Privacy Act. In addition, a list of all approved record linkages at Statistics CanadaFootnote 17, with their purpose, description and output, is available on the Statistics Canada website.

5.8.5 Partnerships

Consultation with stakeholders, users, experts and advisory groups is an integral part of the planning and development of Statistics Canada surveys. The National Statistics Council advises the Chief Statistician of Canada on the full range of Statistics Canada's activities, particularly on overall program priorities. A network of Professional Advisory Committees in major subject areas ensures the continuous review of the Agency's statistical outputs and helps set priorities and foster program relevance. Statistics Canada also maintains, on a continuing basis, a close bilateral relationship with key federal departments and agencies to foster an awareness of each department's needs and their information priorities. The Federal-Provincial-Territorial Consultative Council on Statistical Policy, and its subcommittees, comprises a network of 13 provincial/territorial official representatives who collaborate with Statistics Canada to determine data requirements, consult on current statistical activities and coordinate the dissemination of Statistics Canada products to provincial and territorial governments.

Principle 9: Individual Access

The Privacy Act provides the right of every individual to be given access to any personal information about that individual contained in a personal information bank, and any other personal information about that individual under the control of a government institution. Where the personal information is used for administrative purposes, the individual is entitled to request correction of the error or omission. However, as the personal information collected from survey respondents is not used for administrative purposes at Statistics Canada and can never be used to make a decision about the individuals to whom the information relates without their consent, it is rare that individuals will request corrections to the personal information that they provided to Statistics Canada. Where possible, Statistics Canada accommodates requests to change personal information.

The collection of personal information through one of Statistics Canada's statistical programs falls under one of the specific personal information banks. The Personal Information Banks and a description for each one are published in Statistics Canada's Info Source chapter. After the need for direct personal identifiers is no longer present, direct personal identifiers are deleted. This means that usually the information for a specific individual is not retrievable, and the information is no longer covered under a PIB.

Upon request, Statistics Canada will provide individuals or businesses with access to their confidential personal or business information, where that information is held in identifiable form.

Requests for access are to be made in writing to Statistics Canada with the specific personal information bank identified or with sufficiently specific information provided on the location of the information. To locate a statistical record, Statistics Canada requires, in most cases, not only an identifier, but also additional information such as the time period in which the individual responded to a survey, the title of the survey or his/her street address.

Requests may be made in either official language and access is to be given in that language, if the personal information already exists in that language. Where the personal information does not exist in that language, it is translated or interpreted if necessary for the individual to be able to understand the information. Where required, access is to be given in an alternative format.

To access one's own personal information under the Privacy Act, a formal request may be made to:

Pierre Desrochers
Access to Information and Privacy Coordinator
R.H. Coats Building, 2nd Floor
100 Tunney's Pasture Driveway
Ottawa, Ontario K1A 0T6
Telephone: 613-894-4086
statcan.atip-aiprp.statcan@statcan.gc.ca

Principle 10: Challenging Compliance

An individual is able to address a challenge concerning compliance by Statistics Canada with the above principles.

Complaints may be addressed to:

Pierre Desrochers
Access to Information and Privacy Coordinator
R.H. Coats Building, 2nd Floor
100 Tunney's Pasture Driveway
Ottawa, Ontario K1A 0T6
Telephone: 613-894-4086
statcan.atip-aiprp.statcan@statcan.gc.ca

In addition, under the Privacy Act, individuals may make a complaint to the Office of the Privacy Commissioner of Canada, who may undertake an investigation.

Footnotes:

Footnote 1

As defined in the TBS Policy on Privacy Protection, the term "administrative purposes" is defined as the use of personal information about an individual "in a decision making process that directly affects that individual" (section 3). This includes all uses of personal information for confirming identity (i.e. authentication and verification purposes) and for determining eligibility of individuals for government programs. Non-administrative purposes are the use of personal information for a purpose that is not related to any decision-making process that directly affects the individual. This includes the use of personal information for research, statistical, audit and evaluation purposes.

Return to footnote 1 referrer

Footnote 2

In essence, the provincial and territorial statistical agencies are permitted to obtain confidential information pursuant to Section 11 to use for their own statistical purposes. All other organizations, including private organizations are legally permitted to obtain confidential information pursuant to Section 12. The key difference is that consent is required to receive information pursuant to Section 12, but not for Section 11.

Return to footnote 2 referrer

Footnote 3

In practice, Statistics Canada seeks consent for data sharing of personal information from its respondents, rather than give them the right to refuse.

Return to footnote 3 referrer

Footnote 4

This oath of confidentiality lasts for the person's lifetime, not just as long as he or she is an employee of Statistics Canada.

Return to footnote 4 referrer

Footnote 5

Summaries of approved record linkage projects are posted on the Statistics Canada web site.

Return to footnote 5 referrer

Footnote 6

Linkages falling under the omnibus authorities for the economic statistics program and Part A of the household statistics program are not provided on the Statistics Canada web site, since the privacy risk is low.

Return to footnote 6 referrer

Footnote 7

This includes record linkage activities.

Return to footnote 7 referrer

Footnote 8

Record linkages conducted under the omnibus provisions of the Record Linkage Directive are not posted on the web site.

Return to footnote 8 referrer

Footnote 9

The Statistics Act describes the conditions that must be met to obtain authorization to access the information. Within the federal government, confidential information is designated as Protected B, meaning that individuals must respect the requirements for this level of information, including undergoing a personal security review. Finally, Statistics Canada procedures require that persons may only access information for which they have a work-related "need to know".

Return to footnote 9 referrer

Footnote 10

Such situations are described in Section 5.5.11 of this document.

Return to footnote 10 referrer

Footnote 11

Public-use microdata files are data files of individuals that are available for public use. Prior to their release, these files must meet the confidentiality requirements of the Statistics Act. This requires the removal of all direct identifying information, such as name, address and Social Insurance Number. As well, certain combinations of information may not be released if they could lead to the identification of an individual whose information is on the file.

Return to footnote 11 referrer

Footnote 12

In practice, Statistics Canada seeks consent for data sharing of personal information from its respondents, rather than give them the right to refuse.

Return to footnote 12 referrer

Footnote 13

In such cases, information is released only as permitted by the Statistics Act (i.e., data-sharing agreement, discretionary disclosure).

Return to footnote 13 referrer

Footnote 14

SAS is a statistical analysis software.

Return to footnote 14 referrer

Footnote 15

The Statistics Act describes the conditions that must be met to obtain authorization to access the information. Within the federal government, confidential information is designated as Protected B, meaning that individuals must respect the requirements for this level of information, including undergoing a personal security review. Finally, Statistics Canada procedures require that persons may only access information for which they have a work-related "need to know".

Return to footnote 15 referrer

Footnote 16

Record linkages conducted under the omnibus provisions of the Record Linkage Directive are not posted on the web site.

Return to footnote 16 referrer

Footnote 17

Record linkages conducted under the omnibus provisions of the Record Linkage Directive are not posted on the web site.

Return to footnote 17 referrer

Reporting Guide

Manufacturing and Wholesale Trade Division

Do not mail this form. The other side is for your record of monthly reports.

Survey Definitions and Instructions

Reporting Unit: Activities reported should be comparable to those reported to the Annual Survey of Manufactures (ASM). If establishments for which individual reports are prepared for the ASM must be combined for this report, list the establishments included or report them to the interviewer. Report any changes in establishment coverage if they occur.

Frequency: Please submit data at the end of each accounting period either by telephone or mail. For report due date, please refer to the front page of the questionnaire.

Source of Data: Sales and inventory data should be available from monthly statements. Unfilled orders may be maintained separately. When values are not available by the due date, estimates are acceptable. If previously reported values have been revised, kindly note them in the “remarks” section on the monthly report, submit them on a separate sheet of paper or explain the change to the interviewer.

Note: Report all values in Canadian dollars. Do not include sales tax (provincial, federal or GST), excise duties, excise tax or discounts.

1. Sales

Report only sales for the accounting period. Do not report cumulative or year-to-date values.

  1. Sales of Goods Manufactured: Sales of goods out of the manufacturing establishment, except to warehouses that are part of the same accounting entity and goods on consignment. In addition to normal sales, include transfers to other establishments in the same company, sales from warehouses that are part of the same establishment, sales of goods shipped earlier on consignment, all sales for which an export permit is prepared, revenue for custom and repair work done, charges for installation where they are part of sales. Also include capitalized value of any goods manufactured by this establishment that have been built for subsequent rental
  2. Sales of goods purchased for resale, as is: Value of sales of goods purchased and resold in the same condition. This category also includes the value of goods purchased in bulk which remain unchanged when resold except for cutting and packaging.
  3. Total: Sum of 1(a) and 1(b).

2. Inventories

This section is for reports of the book value of inventory normally held by the establishment. Include: inventory used for long term contracts involving progress billings or payments without adjustment, goods in transit in Canada, goods held in warehouses that are part of the establishment, goods shipped on consignment in Canada until they are sold. Exclude: inventory owned and held abroad, e.g. purchases that have not cleared customs, finished products in foreign warehouses, or on consignment in foreign countries.

  1. Inventories of Raw materials, fuel, supplies, components: Include all items bought for processing and assembling that have not been charged out to processing. The value of logs and rough lumber may be reported either here or in goods in process but consistent with reports to the Annual Survey of Manufactures for the establishment.
  2. Inventories of Goods/Work in process: Report the gross book value before reduction for partial billings or progress payments.
  3. Inventories of Finished goods manufactured: Include goods manufactured or processed by the establishment ready for sale.
  4. Inventories of Goods purchased for resale, as is: May include items of non-manufacturing inventory in addition to any goods purchased for resale in the same condition except for cutting and packaging.
  5. Total inventory: Sum of 2(a), 2(b), 2(c), and 2(d).

3. Orders

For the purpose of this survey, unfilled orders are for goods to be manufactured by the establishment that have not been transferred to sales or treated as a sale. Exclude orders for goods purchased for resale, as is.

  1. Unfilled orders at month end: Report the total value of the unfilled orders less those portions which have been treated as a sale.

4. The last day of your reporting period

5. Production Capacity

This section measures the potential production (production capacity) and the actual production (capacity utilization) of your operations.

  1. Estimate the market value of production of the plant as if it had been operating at full production capability for the whole month.

Assume:

  • only machinery and equipment in place and ready to operate
  • normal downtime
  • labour, materials, utilities, etc. are fully available
  • the number of shifts, hours of operation and overtime pay that can be sustained under normal conditions and a realistic work schedule in the long run
  • the same product mix as the actual production

OPTION 1 – Value (in dollars)

If you report for more than one plant, please determine the production capacity for each plant and provide the sum of these values.

OPTION 2 – Volume and Average Price

Volume

If you report for more than one plant, please determine the production capacity for each plant and provide the sum of these figures.

Average Price

  1. Divide your actual production estimate by your full production estimate in (a). Multiply this ratio by 100 to get a percentage.

If your plant(s) produce(s) different products, please use a product mix at capacity which is most similar to the composition of your output for this reference period.

Inquiries

The telephone number for the Statistics Canada Regional Office in your area appears on the enclosed letter or the monthly survey form.

Mailed inquiries may be sent to that Regional Office in the postage-paid envelope that accompanies the survey form or to:

Statistics Canada Manufacturing and Wholesale Trade Division Monthly Survey of Manufacturing Section Ottawa, Ontario, K1A 0T6

Integrated Business Statistics Program (IBSP)

Reporting Guide

This guide is designed to assist you as you complete the 2015 Annual Electricity Supply and Disposition Survey. If you need more information, please call the Statistics Canada Help Line at the number below.

Your answers are confidential.

Statistics Canada is prohibited by law from releasing any information it collects which could identify any person, business, or organization, unless consent has been given by the respondent or as permitted by the Statistics Act.

Statistics Canada will use information from this survey for statistical and research purposes.

Help Line: 1-877-604-7828

Table of contents

Skip to text

Reporting Instructions
Electricity Generation Method
Combustible Fuel
Receipts of Electricity from the U.S.A.
Receipts of Electricity from Within Canada
Total Supply
Deliveries of Electricity to the U.S.A.
Deliveries of Electricity Within Province
Transmission, Distribution and Other Losses
General Information: Purpose of survey, Data-sharing agreements and Data linkage

Text begins

Reporting Instructions

Please report information for the period of January to December, 2015.

Please complete all sections as applicable.

If the information requested is unknown, please provide your best estimate.

This guide is designed to assist you as you complete the 2015 Annual Electricity Supply and Disposition Survey. If you need more information, please call 1-877-604-7828.

Electricity Generation Method

Nuclear: Electricity generated at an electric power plant whose turbines are driven by steam generated in a reactor by heat from the fission of nuclear fuel.

Hydro: Electric power generated from a plant in which the turbine generators are driven by flowing water.

Tidal: Electric power generated from a plant in which turbine generators are driven from tidal movements.

Wind: A power plant in which the prime mover is a wind turbine. Electric power is generated by the conversion of wind power into mechanical energy.

Solar: Electricity created using Photovoltaic (PV) technology which converts sunlight into electricity.

Wave: Electricity generated from mechanical energy derived from wave motion.

Geothermal: Electricity generated from heat emitted from within the earth’s crust, usually in the form of hot water or steam.

Combustible fuel

Coal: A readily combustible, black or brownish-black rock-like substance, whose composition, including inherent moisture, consists of more than 50% by weight and 70% by volume of carbonaceous material. It is formed from plant remains that have been compacted, hardened, chemically altered and metamorphosed by heat and pressure over geologic time without access to air.

Natural gas: A mixture of hydrocarbons (principally methane) and small quantities of various hydrocarbons existing in the gaseous phase or in solution with crude oil in underground reservoirs.

Wood (Report for “Dry” method): Wood and wood energy used as fuel, including round wood (cord wood), lignin, wood scraps from furniture and window frame manufacturing, wood chips, bark, sawdust, forest residues, charcoal and pulp waste.

Spent pulping liquor: A by-product in the paper making process, containing carbohydrate and lignin decomposition products.

Landfill gas: A biogas composed principally of methane and carbon dioxide produced by anaerobic digestion of landfill waste.

Municipal and other waste: Wastes (liquids or solids) produced by households, industry, hospitals and others (examples: paper, cardboard, rubber, leather, natural textiles, wood, brush, grass clippings, kitchen waste and sewage sludge).

Other biomass (food processing): Can include residues produced during the processing of a product, such as cheese whey, canning factory residues, fruit pits, apple pomace and coffee grounds.

Other biomass (type unknown): Any other type of biomass not otherwise identified on the questionnaire. Specify in the spaces provided.

Receipts of electricity from the U.S.A.

If applicable, please report the total amount of electricity (MWh) and Canadian dollar value (thousands of dollars) this business imported/purchased from the United States.

Receipts of electricity from within Canada

If applicable, please report the total quantities of electricity (MWh) and total dollar value (thousands of dollars) purchased or received from within and/or other provinces (e.g., other utilities/producers, transmitters, distributors).

Total Supply

This is the sum of Total Generation, Total Receipts from United States, Total Receipts from Other Provinces and Total Receipts from Within Province. The Total Supply number must equal the Total Disposal number.

Deliveries of electricity to the U.S.A.

If applicable, please report the amount of electricity (MWh) and Canadian dollar value (thousands of dollars) this business sold/exported to the United States.

Deliveries of electricity within Canada

If applicable, please report the amount of electricity (MWh) and total dollar value (thousands of dollars) your company sold to other domestic companies, by province or territory.

Transmission, distribution and other losses

Include :

  • transmission losses
  • adjustments
  • “unaccounted for” amounts which are subject to variation because of cyclical billing

Exclude :

  • generating station use output as measured at the generating station gate.

General information

Purpose of survey

The purpose of this survey is to obtain information on the supply of, and demand for, energy in Canada. This information serves as an important indicator of Canadian economic performance, and is used by all levels of government in establishing informed policies in the energy area. In the case of public utilities, it is used by governmental agencies to fulfill their regulatory responsibilities. The private sector also uses this information in the corporate decision-making process. Your information may also be used by Statistics Canada for other statistical and research purposes.

Data-sharing agreements

To reduce respondent burden, Statistics Canada has entered into data-sharing agreements with provincial and territorial statistical agencies and other government organizations, which have agreed to keep the data confidential and use them only for statistical purposes. Statistics Canada will only share data from this survey with those organizations that have demonstrated a requirement to use the data.

Section 11 of the Statistics Act provides for the sharing of information with provincial and territorial statistical agencies that meet certain conditions. These agencies must have the legislative authority to collect the same information, on a mandatory basis, and the legislation must provide substantially the same provisions for confidentiality and penalties for disclosure of confidential information as the Statistics Act. Because these agencies have the legal authority to compel businesses to provide the same information, consent is not requested and businesses may not object to the sharing of the data.

For this survey, there are Section 11 agreements with the provincial and territorial statistical agencies of Newfoundland and Labrador, Nova Scotia, New Brunswick, Quebec, Ontario, Manitoba, Saskatchewan, Alberta, British Columbia, and the Yukon.

The shared data will be limited to information pertaining to business establishments located within the jurisdiction of the respective province or territory.

Section 12 of the Statistics Act provides for the sharing of information with federal, provincial or territorial government organizations. Under Section 12, you may refuse to share your information with any of these organizations by writing a letter of objection to the Chief Statistician and returning it with the completed questionnaire. Please specify the organizations with which you do not want to share your data.

For this survey, there are Section 12 agreements with the statistical agencies of Prince Edward Island, the Northwest Territories and Nunavut as well as with the Newfoundland and Labrador Department of Natural Resources, the Ministère de l’énergie et des ressources naturelles du Québec, the Manitoba Department of Mineral Resources, Alberta Energy, the British Columbia Ministry of Energy and Mines, the British Columbia Ministry of Natural Gas Development, National Energy Board, Natural Resources Canada and Environment and Climate Change Canada.

For agreements with provincial and territorial government organizations, the shared data will be limited to information pertaining to business establishments located within the jurisdiction of the respective province or territory.

Record linkages

To enhance the data from this survey and to minimize the reporting burden, Statistics Canada may combine it with information from other surveys or from administrative sources.