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Appendix B – WD Privacy Protocol (April 22, 2011)

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Western Economic Diversification Canada’s (WD) Privacy Protocol is intended to ensure that the collection, use or disclosure of personal information for non-administrative purposes within the Department is carried out in compliance with the Privacy Act, the Privacy Regulations and related privacy policy requirements of the Treasury Board of Canada Secretariat (TBS).

TBS defines a non-administrative purpose as:

  • “The use of personal information for a purpose that is not related to any decision-making process that directly affects an individual.  This includes the use of personal information for research, statistical, audit and evaluation purposes.”

WD is committed not to use the personal information it collected for any other purpose than the proposed non-administrative purpose, except where:

  • the individual consents to another use of their information at the time of collection (e.g. to be contacted for audit purposes in the future);
  • it is for a consistent purpose (e.g. to contact survey participants to clarify their response); or
  • WD might be required to disclose the information in response to a subpoena or other Court order. 

Alternatives to the collection, use and disclosure of personal information

When considering the collection, use or disclosure of personal information for non administrative purposes, WD commits to:

  • consider alternatives to the collection, use and disclosure of personal information, such as the use of depersonalized or aggregate data; and
  • where the proposed non-administrative purpose cannot reasonably be fulfilled without the collection, use or disclosure of personal information, WD will weigh the benefits against the invasion of privacy before determining whether to proceed with the non-administrative program or activity.

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Collection, use and disclosure of personal information

When the ATIP Coordinator or Deputy ATIP Coordinator authorizes the collection, use or disclosure of personal information for a non-administrative purpose, WD will ensure that:

  • the personal information relates directly to an operating program or activity of the institution, for which it has legal authority;
  • the personal information or data elements being collected, used or disclosed will be limited to that which is essential to meet the objectives of the non-administrative program or activity;
  • individuals will be given adequate notice of the non-administrative purpose for which their personal information will be collected, used or disclosed;
  • access to personal information will be limited to those individuals who have a genuine need to know to perform functions or duties related to the non-administrative program or activity;
  • the personal information will not be used or disclosed for any other purpose beyond the original non-administrative purpose for which it was collected;
  • the results of the non-administrative program or activity will not be used to subsequently make any decisions that would directly affect the individuals to whom the information relates;
  • the results of the non-administrative program activity will not be published in a way that could potentially identify the individuals to whom the information relates;
  • adequate security safeguards will be used to protect the personal information;
  • an action plan will be in place to address potential privacy breaches; 
  • where possible, personal information collected, used and disclosed for a non-administrative purpose will be stripped of all personal identifiers (de-identified) once the non-administrative program or activity has been completed; 
  • alternatively, if WD determines that it must retain the personal information, it will establish and apply a retention and disposal schedule to the information, including any information generated by the non-administrative program or activity;
  • any institution that receives the personal information and is also subject to the Privacy Act will demonstrate that the personal information is directly related to one of its operating programs or activities, and commit to only use the information for the proposed non-administrative purpose (such a sharing of information should be done through a Memorandum of Understanding (MOU) or similar agreement);
  • WD will establish a contract or other information sharing agreement with any other recipients of the personal information and the agreement will include adequate privacy protection clauses to ensure that the recipients continue to respect the undertakings of this protocol, including a prohibition respecting any unauthorized use or disclosure of the personal information without the express written authorization of the institution; and
  • WD will reserve the right to audit or request audits of recipients’ uses of the personal information.

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Enquiries

All enquiries regarding this Privacy Protocol should be addressed to the ATIP Unit at (780) 495-4982.

Date of Application

This protocol was adopted the ATIP Coordinator on April 22, 2011, as part of its Privacy Protection Policy suite, and shall apply to all programs and services of the Department.

Document Change Control

Revision Number Date Issued Author Brief Description of Change
v1.0 April 22, 2011 ATIP  Officer New protocol is based on the requirements of the April 1, 2010, TBS Directive on Privacy Impact Assessment