Ice Assistance Emergency Program 

Title of the PIA

Privacy Impact Assessment of Ice Assistance Emergency Program 

Government institutions

Fisheries and Oceans Canada (DFO)
Employment and Social Development Canada (ESDC)

Head of DFO or delegate for section 10 of the Privacy Act

DFO
Director, ATIP

Senior official or executive for the new or substantially modified program or activity

DFO
Senior Assistant Deputy Minister, Strategic Policy

ESDC
Assistant Deputy Minister, Citizen Service Branch
Assistant Deputy Minister, Benefits Delivery Services

Name and description of the program or activity of the government institution

The sub-program 1.1.1 Commercial Fisheries is described in the 2016-17 Report on Plans and Priorities as the following:

The Commercial Fisheries Program is managed in partnership with its stakeholders. It relies on scientific assessments and is dependent on consultative processes to develop and review policies, procedures and regulations and to ensure that the fisheries governance regime is accountable, predictable and transparent. In collaboration with its stakeholders, the program develops and uses management tools such as licences, quotas, trap limits, escapements and bycatch.

Legal authority

DFO
Personal information is collected under the authority of section 4 of the Department of Fisheries and Oceans Act and section 5 of the Atlantic Fisheries Restructuring Act.

ESDC
Personal information is collected under the authority of section 5 of the Department of Employment and Social Development Act (DESDA). Section 28.2 of the DESDA allows ESDC to use the Social Insurance Number (SIN) to identify individuals for the purpose of this program, section 28.3 authorizes the Canada Employment Insurance Commission to delegate powers to ESDC, and section 34 allows ESDC to share this information with DFO.

Personal Information Bank (PIB)

A new PIB will be published online in DFO's Info Source publication upon registration of the PIB with the Treasury Board of Canada Secretariat. The proposed title of the PIB is Ice Assistance Emergency Program.

Short description of the project, initiative or change

The 2017 Ice Assistance Emergency Program (IAEP) is a new temporary activity designed to reduce the economic hardship faced by fishers on the East Coast of Newfoundland and Labrador and Quebec, who have exhausted their eligibility for Employment Insurance benefits, and who are unable to commence fishing due to unseasonably severe ice conditions. The IAEP provides up to $5 million in grant payments to fishers in the eight affected areas beginning the second week of May 2017, when commercial fishing would typically start, to mid-June 2017, when ice conditions are expected to improve sufficiently for fishing to commence.

DFO made applications for benefits available on June 23, 2017. Electronic versions of the application could be printed from the DFO website or hard copies could be picked up at a DFO or Service Canada Office in an affected area. Completed applications could be mailed to the Ice Assistance Emergency Program Processing Centre or delivered in person at a Service Canada location in Newfoundland or an affected area of Quebec. Applications were not accepted electronically. Fishers could apply as of June 26, 2017. Applications were not to be accepted after August 4, 2017.

Completed application forms were processed by Service Canada (ESDC) who entered all application information in the Common System for Grants and Contributions (CSGC). Service Canada used the applicant's first and last name, SIN, and date of birth to validate their identity in CSGC. They then verified that the applicant received EI benefits in accordance with IAEP requirements using the Full Text Screens system (FTS). 

After completing this step, Service Canada officials made a recommendation to DFO on the applicant's eligibility for IAEP. Recommendations were to be recorded in writing on page three of the application form. For the duration of IAEP, DFO officials were co-located at the Service Canada Ice Assistance Emergency Program Processing Centre. As a result, applications remained at the Service Canada office at this stage of processing. DFO officials were then to ensure that the applicant met the affected area criteria by checking their application information against information registered in the Regional Catch and Effort Database, specifically: fisher name, home port, and vessel registration number. DFO officials then recorded their decision on eligibility and payment amount on the application form. Forms were then to be returned to Service Canada officials so that they could enter these details into CSGC, disperse the benefit if appropriate, and retain the paper application form until program close.

Applicants whose grant applications were denied could request a review by an Eligibility Review Committee composed of DFO and ESDC officials. To request a review, the applicant had to call the Service Canada call centre responsible for IAEP information within 15 days of receiving their denial letter and describe to the official the reason they are requesting a review. A paper record of their request and the Eligibility Review Committee's decision was to be kept with their paper application form.

At program close, all paper records will be returned to DFO for storage at National Headquarters according to the Retention and Disposition Authority (RDA). Service Canada will maintain electronic information entered into CSGC according to the applicable RDA.

The Ice Assistance Emergency Program aligns with the DFO's core responsibility to manage Canada's fisheries, Indigenous fisheries programs, aquaculture activities and support commercial fishing harbours while applying relevant legislation, and its mission to support strong economic growth in the marine and fisheries sectors. In particular, it responds to the government-wide commitment to help those working hard to join the middle class, and to provide more help to those who need it that are outlined in the Minister of Fisheries and Oceans' mandate letter. 

Risk area identification and categorization

The following section contains risks identified in the PIA for the new or modified program. The numbered risk scale is presented in an 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.

Type of program or activity

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: Low

Type of personal information involved and context

Sensitive personal information, including Social Insurance Number and financial information, and other biographical information.

Level of risk to privacy: Medium

Program or activity partners and private sector involvement

The program involves other federal government institutions.

Level of risk to privacy: Low

Duration of the program or activity

Ice Assistance Emergency Program is planned to be a temporary program.

Level of risk to privacy: Low

Program population

The use of personal information is for external administrative purposes, and affects only certain individuals.

Level of risk to privacy: Medium

Technology & privacy

Does the new or substantially modified program or activity involve implementation of a new electronic system or the use of a new application or software, including collaborative software (or groupware), to support the program or activity in terms of the creation, collection or handling of personal information?

     No

Does the new or substantially modified program or activity require any modifications to information technology (IT) legacy systems?

     No

Does the new or substantially modified program or activity involve implementation of new technologies or one or more of the following activities enhanced identification methods, surveillance, or automated personal information analysis, personal information matching and knowledge discovery techniques?

     No

Overall risk to privacy based on technology: Low

Personal information transmission

Personal information is transferred to a portable device (e.g. laptop computer), transferred to a different medium or is printed.

Level of risk to privacy: Medium

Risk impact to the individual or employee in the event of a privacy breach

The privacy impact in the event of a breach could include financial harm - lawsuits, additional moneys required reallocation of financial resources.

Level of risk to privacy: Medium