Privacy Impact Assessment Elections Canada's National Register of Electors Immigration, Refugees and Citizenship Canada Data Transfers (New Citizens and Loss of Citizenship Data)
A privacy impact assessment (PIA) was conducted to identify and mitigate any privacy risks associated with the transfers of new citizens and loss of citizenship data from Immigration, Refugees and Citizenship Canada (IRCC) to Elections Canada's (EC) National Register of Electors (NROE).
Section 1 Overview and PIA Initiation
- Elections Canada (lead government institution for the purpose of the PIA)
- Immigration, Refugees and Citizenship Canada
Government Officials Responsible for the PIA:
- Director, NROE, EC
- Director, Citizenship Program Delivery, Citizenship and Passport Program Guidance, IRCC
Delegates for Section 10 of the Privacy Act:
- Assistant Director, Access to Information and Privacy, EC
- Director, Access to Information and Privacy, IRCC
Description of the Program or Activity:
The EC NROE is the permanent, continually updated database of Canadians who are eligible to vote in federal elections and referendums. It contains the family name, given name, gender, date of birth, Canadian residential address and Canadian mailing address for some 26 million electors along with a unique identifier to help track changes to the elector's record. EC uses the information in the NROE to create preliminary lists of electors at the beginning of federal elections and referendums. The preliminary elector list data is used to mail voter information cards to electors telling them where and when to vote and is given to candidates and political parties. In addition, the Canada Elections Act (CEA) requires EC to provide lists of electors to members of Parliament and registered political parties by the 15th of November each year, if there has not been a federal election in the last six months. The CEA also allows EC to enter into agreements with provincial and territorial electoral bodies to provide data from the NROE for use at their elections.
Personal Information Banks (PIB):
- Voter Registration and Identification Elections PPU 037
- Application and Assessment for Canadian Citizenship IRCC PPU 050
EC Legislative Authority:
Subsections 44(1), (2) and (3); 46(1), (1.1) and (2); 52(1), (1.1) and (2); and sections 53 and 54 of the Canada Elections Act
IRCC Legislative Authority:
Section 26.3 and subsections 26.4(1) and (2) of the Citizenship Regulations
Project / Activity Summary:
The activity focuses on two personal information-sharing transfers between IRCC and EC. IRCC discloses to EC new citizenship information and loss of citizenship information in order for EC to add or remove eligible electors in the NROE and to ensure that the NROE is as complete, accurate and up-to-date as possible. EC does not share any personal information with IRCC as part of these data transfers.
Transfers of new citizen data have occurred from IRCC to EC NROE since 1997, when the NROE was created. Canadian citizenship applicants aged 18 and over can consent on IRCC's Application for Canadian Citizenship to transfer to EC personal information associated with citizenship status upon citizenship conferral to be added to the NROE and subsequently to lists of electors. In May 2017, EC and IRCC updated their Memorandum of Understanding (MOU) pertaining to the initiative to allow EC to also obtain a unique client identifier (UCI) number and the date of citizenship conferral for new citizens.
In addition, changes made to IRCC's Citizenship Regulations in 2014 allow IRCC to disclose information on citizenship revocations, recalls and renunciations (collectively called "loss citizenships") to government departments and agencies, including EC. The new ECIRCC MOU now also covers this transfer, and EC will now receive personal information for these individuals: name, sex, date of birth, address, UCI and date of citizenship loss.
Section 2 - Risk Area Identification and Categorization
A. Type of Program or Activity:
Administration of Programs / Activity and Services
Personal information is used to make decisions that directly affect the individual (i.e. determining eligibility for programs including authentication for accessing programs/services, administering program payments, overpayments, or support to clients, issuing or denial of permits/licenses, processing appeals, etc.) (Level of Risk to Privacy: 2)
B. Type of Personal Information Involved and Context:
Social Insurance Number, medical, financial or other sensitive personal information and/or the context surrounding the personal information is sensitive. Personal information of minors or incompetent individuals or involving a representative acting on behalf of the individual (Level of Risk to Privacy: 3)
C. Program or Activity Partners and Private Sector Involvement:
With other federal institutions (Level of Risk to Privacy: 2)
D. Duration of the Program or Activity:
Long-term program (Level of Risk to Privacy: 3)
E. Program Population:
The program affects certain individuals for external administrative purposes. (Level of Risk to Privacy: 3)
F. Technology and Privacy:
Does the new or modified program involve the implementation of a new electronic system, software or application program including collaborative software (or groupware) that is implemented to support the program in terms of the creation, collection or handling of personal information? No.
Does the new or modified program require any modifications to IT Legacy Systems and/or services? No.
Does the new or modified program or activity involve the implementation of one or more of the following technologies?
- Enhanced identification methods? No.
- Use of Surveillance? No.
- Use of automated personal information analysis, personal information matching and knowledge discovery techniques? Yes.
G. Personal Information Transmission:
The personal information is transferred to a portable device or is printed. (Level of Risk to Privacy: 3)
H. Potential risk that in the event of a privacy breach, there will be an impact on the individual or employee:
Inconvenience, embarrassment, financial harm and physical harm