2.A Refugees: From Eligibility to Arrival
A.2 What resources and partnerships are required to process privately sponsored refugees?
(vii) What policies govern data-sharing between actors?
How Canada Does It
Canada enters into agreements, arrangements, or contracts with other processing actors. These agreements govern all aspects of the activities carried out by those actors, including their roles and responsibilities with respect to the collection, use, disclosure, and sharing of personal information with third parties.
It is paramount that all actors ensure the personal information of refugees is protected and is not used or disclosed in a manner that would place them or their family members at risk of harm.
Canada’s policy on the use of personal information requires government departments to conduct a Privacy Impact Assessment before establishing any new or substantially modified program or activity involving personal information. The Privacy Impact Assessment will identify any risks that may impact a person’s privacy and measures to mitigate those risks.
PERSONAL INFORMATION: Personal information includes information that can be combined with other information to identify a specific individual, even through association or inference. Such information could potentially place a refugee at risk of harm if it is used incorrectly or disclosed to a third party. For example, if information such as ethnic origin were linked to health information and only one person in a small town was of that ethnic origin, this could potentially make that individual identifiable and reveal sensitive health information about that person.
PRIVACY POLICIES: Privacy protection should be a core consideration in the initial framing and subsequent administration of programs and activities involving personal information. Individuals are increasingly sensitive to the complexity of modern information systems, how information travels through those systems, and want to be assured that their personal information is protected. Failure to guard against privacy breaches and improper disclosure of information could result in potentially grave consequences for affected individuals and undermine the integrity of programs.
INFORMATION-SHARING AGREEMENTS: Entering into signed agreements, arrangements or contracts with partners also ensures there is shared understanding of the importance of protecting personal information and affords an opportunity to address those principles in writing and how they will be implemented.