Caregiver Recognition Benefit

Privacy Impact Assessment (PIA) summary

Government Institution

Veteran Affairs Canada

Government Official Responsible for the Privacy Impact Assessment

Mary Nicholson
Director, Health Care and Rehabilitation Programs

Head of the government institution / Delegate for section 10 of the Privacy Act

Crystal Garret-Baird
Director, Privacy and Information Management

Name of Program or Activity of the Government Institution

Caregiver Recognition Benefit

Description of Program or Activity

The following description of the program is based on the 2018-2019 Departmental Results Framework and the Veterans Affairs Canada Program Inventory.

Core Responsibility: 1 – Benefits, Services and Supports

Support the care and well-being of Veterans and their dependents or survivors through a range of benefits, services, research, partnerships, and advocacy.

Program Description: P10 – Caregiver Recognition Benefit

The Caregiver Recognition Benefit formally recognizes the contribution caregivers make to the health and well-being of seriously injured Veterans who require continuous care and supervision, due to their service-related physical and/or mental health condition(s). This benefit is paid directly to Veterans’ caregivers.

Description of the class of record and the Personal Information Bank

• Caregiver Recognition Benefit – Class of Record VAC MVA 892
• Caregiver Recognition Benefit – Personal Information Bank VAC PPU 702
• Classes of Records and Personal Information Banks can be reviewed at: VAC's Info Source Chapter

Legal Authority for Program or Activity

Personal information is collected pursuant to section 65.1 of the Veterans Well-being Act, as well as the associated Veterans Well-being Regulations.

The legal authority requires that the individual be in receipt of a VAC Disability Award and, as a result of the disability, requires ongoing care. In addition, the legal authority will require that the informal caregiver be at least 18 years of age and not be otherwise remunerated for his/her service.

Risk Area Identification & Categorization

The following section contains risks identified in the PIA for the new or modified program. A risk scale has been included. The numbered risk scale is presented in ascending order: the first level represents the lowest level of potential risk for the risk area; the fourth level (4) represents the highest level of potential risk for the given risk area. Please refer to “Appendix C” of the TBS Directive on PIAs to learn more about the risk scale.

1. Type of Program or Activity
   • Administration of Programs / Activity and Services
   • Level of risk to privacy – 2
2. 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

3. Program or Activity Partners and Private Sector Involvement
   • Within the institution (amongst one or more programs within the same institution)

     Level of risk to privacy – 1

4. Duration of the Program or Activity
   • Long-term program.

     Level of risk to privacy – 3

5. Program Population
   • The program affects certain individuals for external administrative purposes.

     Level of risk to privacy – 3

6. Technology & Privacy
   1. Does the new or modified program or activity involve the implementation of a new electronic system, software or application program including collaborative software (or groupware) that is implemented to support the program or activity in terms of the creation, collection or handling of personal information?

      Risk to privacy - No

   2. Does the new or modified program or activity require any modifications to IT legacy systems and / or services?

      Risk to privacy - Yes

   3. Enhanced identification methods - This includes biometric technology (i.e. facial recognition, gait analysis, iris scan, fingerprint analysis, voice print, radio frequency identification (RFID), etc.) as well as easy pass technology, new identification cards including magnetic stripe cards, “smart cards” (i.e. identification cards that are embedded with either an antenna or a contact pad that is connected to a microprocessor and a memory chip or only a memory chip with non-programmable logic).

      Risk to privacy – No

   4. Use of Surveillance - This includes surveillance technologies such as audio/video recording devices, thermal imaging, recognition devices, RFID, surreptitious surveillance / interception, computer aided monitoring including audit trails, satellite surveillance etc.

      Risk to privacy – Yes

   5. Use of automated personal information analysis, personal information matching and knowledge discovery techniques - For the purposes of the Directive on PIA, government institution are to identify those activities that involve the use of automated technology to analyze, create, compare, cull, identify or extract personal information elements. Such activities would include personal information matching, record linkage, personal information mining, personal information comparison, knowledge discovery, information filtering or analysis. Such activities involve some form of artificial intelligence and/or machine learning to uncover knowledge (intelligence), trends/patterns or to predict behavior.

      Risk to privacy – No

7. Personal Information Transmission
   • The personal information is used in a system that has connections to at least one other system.
     The personal information is transferred to a portable device or is printed.
     The personal information is transmitted using wireless technologies.

     Level of risk to privacy – 2, 3, 4

8. Risk Impact to the Individual or Employee
   • Inconvenience
   • Reputational harm, embarrassment
   • Financial harm
   • Level of risk to privacy – 1, 2 and 3
9. Risk Impact to the Institution
   • Managerial harm
   • Organizational harm
   • Financial harm
   • Reputational harm, embarrassment, loss of credibility.
   • Level of risk to privacy – 1, 2, 3 and 4