Consulting with the Office of the Privacy Commissioner’s Government Advisory Directorate
April 14, 2021
Privacy Act Bulletins are intended to offer lessons learned, best practices and other important privacy news, trends and information related to privacy protection in the federal public sector.
Did you know that the Office of the Privacy Commissioner of Canada (OPC) offers consultation services to federal institutions that develop programs and activities with privacy implications?
Through consultation, the OPC’s Government Advisory Directorate can provide informal, proactive advice and guidance on programs and activities that may impact privacy. We can help to identify compliance issues or risks to privacy, as well as potential mitigation strategies. Institutions do not need a Privacy Impact Assessment (PIA) to engage with us on privacy issues.
We encourage you to consult us early in the development and throughout the lifecycle of an initiative, long before finalizing a PIA. For more information on our consultation services, we invite you to review Section 3 of Expectations: OPC’s Guide to the Privacy Impact Assessment Process.
Consulting with the OPC about urgent COVID-19-related initiatives
The OPC has acknowledged the urgency of limiting the spread of COVID-19, and has published A Framework for the Government of Canada to Assess Privacy-Impactful Initiatives in Response to COVID-19. The document is an assessment framework intended to assist government institutions faced with responding to the crisis. In addition, the OPC’s Government Advisory Directorate is available for consultation on measures introduced in response to COVID-19. We encourage you to request a consultation meeting with our office early in the development of urgent COVID-19-related initiatives, particularly those deemed high-risk.
Notifying the OPC
Consulting with the OPC can satisfy a Treasury Board of Canada Secretariat (TBS) privacy policy obligation. The TBS Policy on Privacy Protection requires federal institutions to notify the Office of the Privacy Commissioner of Canada (OPC) of any planned initiatives (legislation, regulations, policies, programs) that could relate to the Privacy Act or impact the privacy of Canadians.
We encourage institutions to request a consultation meeting with our office. However, should you choose to provide written notification instead, we recommend you include:
- a brief description of the initiative;
- the anticipated start date;
- details on whether the initiative relates to any other initiative(s); and
- information on who to contact should our office have questions.
Providing this information will help us to review and consider the issues involved, and to follow up with you to provide privacy advice as needed.
Getting in touch with the OPC
We recommend coordinating any request for consultation or notification with those responsible for privacy management (i.e. ATIP) at your institution. If you are unsure of who is responsible, please consult TBS’ List of access to information and privacy coordinators by institution.
Please address your consultation requests and notifications to the OPC’s Director, Government Advisory at scg-ga@priv.gc.ca.
Register now for a Privacy Awareness Week webcast
On May 7, 2021, as part of Privacy Awareness Week, we invite you to join a webcast given by Nicole Frantz and Lacey Batalov from the OPC’s Government Advisory Directorate. They will explain why assessing potential privacy risks is more important than ever, and how you can integrate a privacy-first mindset into your work.
Register for the webcast on the Canada School of Public Service website.
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