Privacy Impact Assessment (PIA) Summary
Government Institution
Veteran Affairs Canada (VAC)
Government Official Responsible for the Privacy Impact Assessment
Sandra Williamson
Director, Long-Term Care and Disability Benefits Program
Head of the government institution / Delegate for section 10 of the Privacy Act
Crystal Garrett-Baird
A/Director, Access to Information and Privacy
Name of Program or Activity of the Government Institution
Critical Injury Benefit
Description of Program or Activity
The Critical Injury Benefit (CIB) is a new benefit, effective July 1, 2015, which recognizes and compensates eligible Canadian Armed Forces members and Veterans who on or after April 1, 2006 experienced a sudden, single incident that caused a severe and traumatic injury or an acute disease immediately resulting in a severe impairment and interference in quality of life. This compensation recognizes and compensates for the time between the initial injury or incident and when the CAF member is medically stabilized.
The requirement for an application may be waived based on sufficient information currently within VAC’s data holdings. Individuals will be notified and will be requested to provide their acceptance of the CIB prior to the Department providing the benefit. Individuals may also complete an application form. Compensation is provided in the form of a lump sum payment.
Description of the class of record and the Personal Information Bank
- The Class of Record: Critical Injury Benefit (VAC MVA 890)
- Personal Information Bank: Critical Injury Benefit (VAC PPU 700)
Class of Record and Personal Information Bank can be viewed at: VAC’s Info Source Chapter
Legal Authority for Program or Activity
Sections 44.1, 44.2, 44.3 of the Canadian Forces Members and Veterans Re-establishment and Compensation Act (CFMVRCA) and the associated sections under the Canadian Forces Members and Veterans Re-establishment and Compensation Regulations as amended. Section 80 of the CFMVRCA provides disclosure authority upon which government institutions and agencies can rely.
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 (1) 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.
- Type of Program or Activity
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Administration of Programs / Activity and Services
Level of risk to privacy – 2
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- Type of Personal Information Involved and Context
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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
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- Program or Activity Partners and Private Sector Involvement
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With other federal institutions.
Level of risk to privacy – 2
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- Duration of the Program or Activity
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Long-term program.
Level of risk to privacy – 3
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- Program Population
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The program affects certain individuals for external administrative purposes.
Level of risk to privacy – 3
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- Technology & Privacy
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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
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Does the new or modified program or activity require any modifications to IT legacy systems and / or services?
Risk to privacy – Yes
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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
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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 – No
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Use of automated personal information analysis, personal information matching and knowledge discovery techniques - For the purposes of the Directive on PIA, government institutions 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
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- Personal Information Transmission
- The personal information is used in a system that has connections to at least one other system.
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The personal information is transferred to a portable device or is printed.
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Level of risk to privacy – 2 & 3
- Risk Impact to the Institution
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Financial harm and reputational harm, embarrassment, loss of credibility.
Level of risk to privacy – 3 & 4
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- Risk Impact to the Individual or Employee
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Inconvenience, reputational harm and financial harm.
Level of risk to privacy – 1, 2 & 3
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