Privacy Impact Assessment (PIA) Summary
Government Institution
Veteran Affairs Canada
Government Official Responsible for the Privacy Impact Assessment
Mary Nicholson
Director, Health Care, Rehabilitation and Income Support Programs
Head of the government institution / Delegate for section 10 of the Privacy Act
Crystal Garrett-Baird
Director, Privacy and Information Management
Name of Program or Activity of the Government Institution
Financial Benefits Program
Description of Program or Activity:
The Financial Benefits Program (FBP) was designed to recognize and compensate for the economic impact that a career-ending or service-related disability may have on a Veteran’s ability to earn an income following release from the Canadian Armed Forces. The FBP Privacy Impact Assessment (PIA) which was initially completed in 2007 was updated in November of 2014. The updated PIA examined Veterans Affairs Canada’s (VAC’s) delivery of the four specific programs delivered under the umbrella of the Financial Benefits Program: Earnings Loss Benefit (ELB), Canadian Forces Income Support (CFIS), Career Impact Allowance (CIA) and accompanying CIA Supplement (CIAS), and Supplementary Retirement Benefit (SRB). Addendums to the FBP PIA were completed in 2015 to assess the changes to the Earnings Loss Benefits (ELB) provided to part-time Reserve Force Veterans and to assess the Retirement Income Security Benefit (RISB), a new financial benefit which came into effect on July 1, 2015.
An additional addendum was completed in March 2017 following amendments to the program as a result of the Budget Implementation Act, 2016 (BIA 2016). These amendments included the following which came into effect October 1, 2016 and April 1, 2017 respectively:
- Changes to the Earnings Loss Benefit (ELB), including increasing the monthly Earnings Loss Benefit from 75% to 90% of the recipient’s gross pre-release military salary, setting the minimum pre-release salary to provide income support of at least $44,496.00 per year, and adjusting the calculation amount annually so that the Earnings Loss Benefit will keep pace with inflation.
- Changes to the CIA program, including renaming the benefit to “Career Impact Allowance (CIA)” to better reflect the intent of the program and the introduction of a new assessment to be completed in some cases to determine career impact.
Earnings Loss Benefit (ELB)
A monthly income replacement program that ensures the income of eligible participants does not fall below 90% of their gross pre-release military salary (as determined by VAC), or 90% of the salary of a senior Private, whichever is higher. This benefit is taxable and is payable while an individual is taking part in the rehabilitation or vocational assistance program, or to the age of 65 if the recipient is unable to engage in suitable, gainful employment. This benefit is also available to eligible survivors and dependent children of deceased Veterans.
Canadian Forces Income Support (CFIS)
A tax-free benefit payable to eligible participants that have completed the Rehabilitation Program and are able to work but have not been able to find a job or have a low-paying job. Applicants may qualify for CFIS if they are a CAF Veteran who no longer qualifies for Earnings Loss Benefits; need financial help because the household income is not enough to meet basic needs; are looking for a suitable job but have not been able to find one; and live in Canada. This benefit is also available to eligible survivors and dependent children of deceased Veterans.
Career Impact Allowance and Supplement
A monthly taxable allowance payable to eligible applicants whose future economic earning potential has been negatively impacted due to a permanent and severe impairment.
Individuals may qualify for a Career Impact Allowance if they are a CAF Veteran who has a physical and/or mental impairment that is severe and permanent; have a rehabilitation plan that has been approved by VAC for this impairment; and received a disability award or a disability pension related to this impairment.
An additional monthly taxable benefit (indexed annually) is payable if an applicant is in receipt of a Career Impact Allowance and is not capable of suitable, gainful employment due to their permanent physical or mental health problem.
Supplementary Retirement Benefit (SRB)
A payment designed to compensate for the lower pension contributions made because applicants are unable to work as a result of being totally and permanently incapacitated. This is a one-time, taxable cash award. Applicants may qualify for a Supplementary Retirement Benefit if they are a CAF Veteran who is totally and permanently incapacitated and no longer qualify for Earnings Loss Benefits. This benefit is also available to eligible survivors of deceased Veterans.
Retirement Income Security Benefit (RISB)
The RISB is a monthly, taxable benefit that works with VAC’s existing services and benefits to establish a continuum of support that spans an eligible Veteran’s or survivor’s entire life. Beginning at age 65, RISB provides eligible Veterans with an income support level equivalent to at least 70% of their pre-age 65 income level from VAC Financial Benefits. Eligible survivors are provided with income support that assures their income does not fall below 50% of the income threshold for which the deceased Veteran was approved.
Description of the class of record and the Personal Information Bank
Class of Record: Financial Benefits (VAC MVA 845)
Personal Information Banks:
Earnings Loss (VAC PPU 607)
Canadian Forces Income Support (VAC PPU 608)
Career Impact Allowance and Supplement (VAC PPU 610)
Supplementary Retirement Benefit (VAC PPU 609)
Retirement Income Security Benefit (VAC PPU 701)
This information can be reviewed at: VAC’s Info Source Chapter
Legal Authority for Program or Activity
The Canadian Forces Members and Veterans Re-establishment and Compensation Act (CFMVRCA) and related Regulations are the program’s authority to collect and use personal information to administer the program. The Budget Implementation Act (BIA) is the authority for the one-time compensation payment for Disability Pension offset for ELB and CFIS.
| Financial Benefit Program | Section(s) of CFMVRC Act Establishing Authority for Program | Section(s) of CFMVRC Act and Regulations Related to the Collection of Personal Information | Section(s) of CFMVRC Act and Regulations Related to the Use of Personal Information | Section(s) of CFMVRC Act Related to Disclosure of Personal Information |
|---|---|---|---|---|
| Earnings Loss | Sections 18-24 of the Act 18(1) Veteran 22(1) Survivor/Orphan |
Sections 76(1), 80 and 82 of the Act and section 17 of the Regulations | Sections 18-24 of the Act and sections 17-27 of the Regulations | Sections 81 and 82 of the Act |
| Supplementary Retirement Benefit | Sections 25-26 of the Act | Sections 76(1) and 80 of the Act and section 28 of the Regulations | Sections 25-26 of the Act and sections 28-29 of the Regulations | Sections 81 and 82 of the Act |
| Canadian Forces Income Support Supplement | Sections 27-37 of the Act | Sections 76(1), 80 and 82 of the Act and section 30 of the Regulations | Sections 27-37 of the Act and sections 30-39 of the Regulations | Sections 81 and 82 of the Act |
| Permanent Impairment Allowance/Supplement | Sections 38-40 of the Act 38(3) Supplement | Sections 76(1) and 80 of the Act and section 40 of the Regulations | Sections 38-40 of the Act and sections 40-46 of the Regulations | Sections 81 and 82 of the Act |
| Retirement Income Security Benefit | Sections 40.1-40.5 of the Act. | Sections 40.5, 76, 80 and 82(a) of the Act | Sections 40.1-40.6 and 76(2) of the Act | Sections 81 and 82(b) of the Act. |
| One-Time Compensation Payment | Section(s) of Budget Implementation Act Establishing Authority for Program |
|---|---|
| Earnings Loss Benefit | Section 6 of the Act |
| Canadian Forces Income Support | Section 6 of the Act |
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
- Administration of Programs / Activity and Services.
- Level of risk to privacy – 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
- Program or Activity Partners and Private Sector Involvement
- Within the institution (amongst one or more programs within the same institution)
- With other federal institutions
- Level of risk to privacy – 1 and 2
- Duration of the Program or Activity
- Long-term program
- Level of risk to privacy – 3
- Program Population
- The program affects certain individuals for external administrative purposes.
- Level of risk to privacy – 3
- Technology & Privacy
-
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 – Yes
-
Does the new or modified program or activity require any modifications to IT legacy systems and/or services?
Risk to privacy – Yes
-
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
-
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
-
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 – Yes
-
- Personal Information Transmission
- The personal information is used within a closed system.
- 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.
- Level of risk to privacy – 1, 2 and 3
- Risk Impact to the Institution
- Managerial harm; financial harm; and reputational harm, embarrassment, loss of credibility.
- Level of risk to privacy – 1, 3 and 4
- Risk Impact to the Individual or Employee
- Inconvenience; reputational harm, embarrassment; and financial harm.
- Level of risk to privacy – 1, 2 and 3