Contributions Program 2013-14

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Applicant's Guide

Office of the Privacy Commissioner of Canada

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1. Purpose of this Guide

This guide is designed to help applicants prepare a project proposal for funding under the Contributions Program of the Office of the Privacy Commissioner of Canada (OPC). Specific instructions for completing the application form as well as information about the assessment process are provided.

1.1 Eligible Applicants

Academic institutions and not-for-profit organizations, including industry associations and trade associations, are eligible under the Program for funding of research and related knowledge translation initiatives related to the promotion of privacy and the protection of personal information. Eligible applicants include consumer, voluntary and advocacy organizations.

1.2 Non-Eligible Applicants

• For profit organizations
• Political parties and organizations involved in partisan political activity; and
• Current or former public office holders or public servants who are not in compliance with the Conflict of Interest Act or the Values and Ethics Code for the Public Service, or any other relevant guidelines, principles or codes relating to conflict of interest or post-employment.

1.3 Application Date

The deadline for receipt of applications is November 30, 2012 for fiscal year 2013-2014.

Please forward your application to the following address:

Office of the Privacy Commissioner of Canada
Care of: Contributions Program
112 Kent Street
Place de Ville, Tower B, 3^rd Floor
Ottawa, Ontario  K1A 1H3
Email: contrib@priv.gc.ca

1.4 Contributions Program Budget

The budget for the OPC's Contribution Program is $500,000 annually. This amount is subject to cancellation, reduction or increase in the event that funding levels are changed by Parliament.

The OPC will consider funding more than one project per organization. However, the maximum amount that can be awarded for any single project is $50,000 and the maximum total amount that can be awarded to any single organization is $100,000.

2. Contributions Program

2.1 Objectives

The Program’s objectives are to:

1) Strengthen existing privacy research capacity in academic and not-for-profit sectors;

2) Generate new knowledge and support the development of expertise in selected areas of privacy and data protection;

3) Increase awareness and understanding among individuals and organizations across Canada of their privacy rights and obligations; and,

4) Promote uptake and application of research results by relevant stakeholders.

2.2 Eligible Projects

The OPC will provide funding for research projects aimed at promoting privacy and the protection of personal information in the private sector. OPC will also provide funding for related knowledge translation initiatives aimed at disseminating research results and enabling their uptake and application among relevant stakeholders.

Important Note: The Contributions Program finds its authority under the Personal Information Protection and Electronic Documents Act (PIPEDA) which governs the collection, use or disclosure of personal information by organizations in the course of commercial activities. Accordingly, only research and/or related knowledge translation proposals that address privacy issues in the private sector or at the interface between the private and public sectors are eligible for funding under this program.

Research priority areas

The OPC encourages proposals to undertake research and related knowledge translation initiatives in one or more of the four priority areas described below. However, the Office will also consider proposals in other areas related to privacy and protection of personal information in the private sector.

Priority 1: Identity Integrity and Protection

A fundamental tenet of privacy is that individuals should have the ability to control when and how their personal information is collected, who collects their personal information, and how this information is used and disclosed. The capacity to collect and analyze data about individuals is growing in both the offline and online worlds. With more people active on the internet and users getting younger and younger, the need to understand the online and mobile environments, the privacy impacts they have on individuals and their ability to make decisions about their online “persona” is greater than ever.

How people manage their online identities or seek to be anonymous is increasingly challenging. We are seeing the merging of the public and private sectors, as well as our online and offline identities. There is a growing need for privacy-protective identity management strategies, including the development of effective identification and authentication frameworks. There is also a need for tools, policies or educational materials to inform and empower individuals and enable them to protect their privacy and manage their identity within this new online environment.

Examples of research questions in this priority area include:

• What are some of the emerging identity management frameworks and what are their impacts on data protection?
• How is the “public/private divide” evolving and how can we best protect privacy in this environment? What are the implications of individuals having multiple personas online for work, personal, and leisure purposes?
• How is “Big Data” challenging privacy norms and how do individuals and organizations define identity?  What practices do they, or should they, put in place to address issues of identity and anonymity?
• How have new technologies and payment models transformed how we view our identities?
• How do children, youth and other groups use the Internet and mobile devices and what impact might their unique practices and perspectives have on their understanding of, and approach to, privacy protection?
• How do organizations explain their online and mobile privacy practices to consumers and what are the relative merits of different approaches? How can organizations improve the content or method of such explanations so as to make them more understandable for consumers?

Priority 2: Information Technology

Chief among new challenges to privacy is the impact of emerging information technologies and in particular, the increasing adoption of mobile technologies (e.g., smartphones, tablets), the increasing convergence of capabilities/services on single devices or with single service providers and the expansion of technologies into new areas of individuals’ lives (e.g., smart homes, smart vehicles).

There is a need to build further capacity among researchers and labs working specifically on privacy and security, from a scientific and/or technical point of view. Emerging information and communication technologies can threaten Canadians’ privacy, but also enhance it if properly designed and built into information systems from the outset.

Examples of research questions in this priority area include:

• What are the vulnerabilities of mobile communications devices (e.g. smartphones) and related infrastructures (e.g., app stores) and services (e.g., location-based services), and the implications for identity theft, privacy and the protection of personal information?
• What is the state of the art with respect to privacy enhancing technologies (e.g. encryption and anonymization)?
• What is the state of the art with respect to smart systems (e.g., smart utility grids, smart homes, smart vehicles, intelligent transportation systems)? To what extent are these systems being interconnected? What are the associated privacy implications and how are these being addressed?

Priority 3: Genetic Privacy & Biobanking

As a result of advances in science and sophisticated analytical tools, the cost of genetic testing is falling rapidly. This means that increasing amounts of genetic information are being generated, stored and used for a variety of purposes. The greater availability and accessibility of genetic information – particularly when offered direct to consumer over the internet – raises a host of privacy issues.

Controlling access to one’s person and to information that goes to the very essence of who we are is an intrinsic element of the concept of privacy. Exercising control over our genetic information, however, can be particularly challenging. Genetic information is not necessarily information about only ourselves; certain genetic information may be shared with family members, communities and sub-populations. Biological science is still evolving at a rapid rate and the results of genetic tests or human genome sequencing may be difficult to understand. How to interpret their significance in terms of individual health or life outcomes is not always clear, depending on their predictive value.

Examples of research questions in this priority area include:

• What are the privacy implications arising from the communal/shared nature of genetic/genomic information?
• What are the privacy implications of the increasing collection and use of genetic/genomic information by private sector organizations?
• How can we enhance public awareness and understanding of the privacy implications arising from the collection, use and disclosure of genetic/genomic information?

Priority 4:  Public Safety and National Security

In recent years, there has been rising public concern about the significant erosion of privacy rights in the post 9-11 public safety and national security environment. Various initiatives that touch on national security, such as the Beyond the Border Initiative; the financial monitoring regime under FINTRAC; the considerable powers of the Anti-terrorism Act; the increased sharing of law enforcement information; and the array of aviation security programs such as the Passenger Protect Program and Canadian Air Transport Security Authourity’s (CATSA) full body scanning and behavioural screening initiative, have served to challenge Canadians’ privacy rights.

Risks to privacy posed by such programs are further compounded by the rapid development of new technologies that aid security agencies in their acquisition and analysis of information. Fundamental questions about how this information is collected, by whom, with whom it is shared, and for what purpose, must be answered. In the absence of such knowledge, it is often difficult, if not impossible, for individuals in a democratic society to hold government accountable for the use of their personal information, or to meaningfully exercise the rights of access and correction.

Examples of research questions in this priority area include:

• What are the impacts of government security measures on the financial privacy of Canadians?
• What is the nature and extent of personal information exchange between the private sector and government for public safety and national security purposes?
• What are the potential and actual privacy impacts of government travel-related security programs (e.g. Passenger Protect Program, Secure Flight, behavioral screening, etc.) that involve the airline industry and other private sector actors in the pursuit of the national security goals of the State?
• What are the privacy impacts of private sector involvement in the increased automation of security checks and processes at borders to reduce costs? What are the privacy implications arising from competitive pressures within the private sector to sell such products or services to border control authorities?
• What is the role of the private sector in promoting the increased use of audio-video surveillance?

Integrated Knowledge Translation Activities

Given the OPC’s ultimate objective of promoting respect for the right to privacy and the protection of personal information in Canada, we strongly encourage applicants to integrate related knowledge translation activities as part of their project proposals. Knowledge translation is the process by which theoretical research results get transformed into useable outcomes that relevant end-users can apply in practice.

Knowledge translation activities may be built into current research proposals, or further build upon past OPC-funded research.

Examples of knowledge translation activities that help enable uptake and practical application of research results among relevant end-users include:

• Workshops, conferences and symposia aimed at disseminating research results to relevant stakeholders and providing an opportunity for effective knowledge exchange between theoretical concepts and practical realities;
• Engagement of relevant end-users as active participants in an iterative process throughout the research project to obtain relevant feedback and enable early uptake and application of research results;
• Innovative and interactive online approaches for disseminating research findings and raising public awareness of privacy issues;
• Survey, evaluation or other methods of assessing the relevance, effectiveness or impact of knowledge dissemination approaches and strategies aimed at raising privacy awareness and understanding among individuals or organizations;
• Initiatives that transform research results into useable knowledge for relevant intermediaries to further expand the breadth of research impact among ultimate end-users. (As examples, privacy guidelines for parents to use in discussions with children, education curriculum for teachers to use in teaching students, relevant content for journalists and specialized media to report on privacy issues impacting Canadians, toolkits for consumer protection organizations to use in better supporting consumers to make informed choices, privacy best practices for professional associations to promote among their members, etc.)

2.3 Duration of Projects

The OPC Contribution Program is structured to provide funding for eligible expenses that are incurred within the same fiscal year that funds have been awarded—that is, April 1, 2013 to March 31, 2014. Exceptionally, the OPC may fund projects that extend beyond the end of the fiscal year (i.e. March 31, 2014) if the proposal persuasively demonstrates why the research requires more time to be completed and should be funded beyond the typical one-year period.

2.4 Allowable Expenses

Funds may be used only for expenses directly related to the activities of the project. These activities are as reflected in either the original budgetary submission, or via subsequent approved budgetary adjustments. Expenses would include:

• salary and benefits for members of the project team, inclusive of researchers and research assistants, students, postdoctoral fellows, technical support, etc.;
• administrative costs, translation, secretarial assistance and publication costs;
• contract costs for expertise not available in-house or work not reasonably performed in-house (for example surveys); and
• other costs including travel (not to exceed government travel regulations), workshops, materials and supplies, and communications.

The OPC will not support any expenses incurred prior to, or after completion of, the funding period stipulated in the Agreement.

Other ineligible expenses that will not be funded under the Agreement include the purchase of buildings, land, vehicles and most other major capital costs.

Administrative expenses should be limited to no more than 15 per cent (15%) of the total project cost.

Contribution funds awarded to an applicant are subject to the terms of the Contribution Agreement signed by the applicant and the OPC. Funds must be spent only on the project and cannot under any circumstances be diverted to any other use. Expenses associated with the project are subject to audit.

For full details, refer to the Costing Memorandum in “Schedule B – Eligible Costs”

3. Completing the Application

The following information corresponds to each section of the Application Form. You should provide answers to all questions and include any required detailed information in an appendix to the application form.

3.1 Identification of Applicant

• Provide the full name of your organization along with any abbreviations frequently used, as well as the section name or division name;
• Previous name, if changed in the last year;
• Address, telephone numbers (with extension), fax numbers, e-mail addresses, and web site addresses, where applicable.

The mailing address and billing address should include full information on the organization's location, such as floor, suite or room number, street number and postal code. Should a Post Office Box be designated as the official mailing address, please provide this information as well.

3.2 The Proposal

Applicants must provide a project proposal which, once agreed to by the OPC, will serve as a basis for the Contribution Agreement and cash flow. The project proposal should contain:

1. Basic Information: Name, address, billing address, telephone number, facsimile number and e-mail address of the applicant's authorized representative, organizational structure including legal status, names of principal personnel and project administrators. Please provide contact information for both the principal researcher (where applicable), and/or the person responsible for administering the project.
2. Legal Status: An attestation/confirmation that your organization is a not-for-profit organization.
3. Organizational Background: Background of the organization including its mandate, objectives, and accomplishments.
4. Previous Financial Support:  An indication of any previous financial support received from the OPC including the amount, the year when the funding was provided, the purpose of the funded activity, and the results achieved.
5. Project Description: A detailed project description including project title, goals and objectives, identification of the target groups for the proposed project, identification of the anticipated results and expected benefits for Canadians in terms of the creation and application of new knowledge in the area of privacy and data protection. A listing of project deliverables must also be provided.
6. One-Page Summary: A concise one-page summary of the proposed project that can be used for the Contribution Agreement.
7. Timeline and Monitoring: Timeframe, work plan detailing activities to be undertaken to support the attainment of project objectives, and monitoring activities.
8. Budget: A detailed budget of the project including amount(s) being requested from the OPC (see Schedule B in the Contribution Agreement, which can also be found on our web site) and other proposed sources of revenue including in-kind support.
9. Community Involvement and Support: Where appropriate, an indication of the level of community involvement (commitment, endorsement, scope and level of participation, co-operation and volunteer involvement).
10. Provincial/Territorial Support:  Where appropriate, an indication of the degree of provincial and territorial support for the project.
11. Knowledge Translation Activities: A plan for disseminating research results and enabling their uptake and application by relevant end-users (e.g. targeted stakeholders, organizations, industry associations, individuals, consumers, communities, educators, journalists, and/or general public, etc.)
12. Acknowledgement of OPC Funding: An indication of how the project will acknowledge the financial support (and where relevant, other contributions) of the Office of the Privacy Commissioner of Canada to the project.

3.3 Declarations

Applicants are required to answer the questions in the Application form regarding the Conflict of Interest Act, the Values and Ethics Code for the Public Service, and the Lobbying Act.

3.4 Other Sources of Funding

Applicants may seek other sources of funding for proposed projects. Potential recipients are required to disclose all sources of funding for a proposed project when applying for funding from the OPC. This includes financial assistance (grants, contributions, etc.) from all levels of government, anticipated or received, that is related to the subject matter of the proposed project. This should also include applications for financial assistance which are still pending.

In the event that total government assistance (including provincial and municipal assistance) received for the project exceeds the cost of the project, the recipient will repay the Crown on a pro-rated basis (based on the OPC's share of total government assistance received).

4. The Assessment Process

Each request for financial support will be reviewed to determine the quality, relevance and timeliness, feasibility and expected outcomes/benefits of the proposed project. Applicant organizations and applications for funding will be reviewed in accordance with the general Program objectives as well as the specific eligibility criteria as outlined above and described below.

4.1 Assessing the Proposals

In assessing proposals, the OPC may, where appropriate, consult with other federal departments, provincial and territorial governments and other privacy commissioners or ombudsmen. The OPC may also involve independent, external reviewers from academic or other not-for-profit sectors.

In reviewing and recommending proposals for approval by the Privacy Commissioner of Canada, the OPC will take into consideration the following factors:

Overall Quality

1. What is the overall quality, importance and originality of the proposed project?
2. Does the proposal demonstrate a solid understanding of the relevant privacy issues?
3. Are the proposed methods appropriate and likely to produce reliable evidence and/or effective results in accordance with stated objectives?
4. Does the applicant have the requisite expertise, knowledge and track record to carry out the proposed project? In the case of an organization, has it demonstrated the necessary credibility, accountability and reputation to successfully carry out the proposed project?
5. Does the research team integrate the various disciplinary perspectives/approaches needed to answer the questions identified?
6. Is there an effective strategy in place to consult or collaborate with key stakeholders, where needed, to validate and/or improve upon the quality of research results?

Relevance and Timeliness

7. Is the proposed project aligned with one or more of OPC’s identified priorities and/or with OPC's mandate generally?
8. Are the expected deliverables timely, relevant and responsive to Canadians’ needs?
9. Are the expected outcomes of the project likely to be useful for legislators, policy makers, organizations, industry associations, consumer groups and/or the general public, etc.?

Feasibility

10. Is the amount of money requested to carry out the proposed project reasonable and are the estimated costs realistic given the nature and scope of the project?
11. What are the applicant’s demonstrated ability, competence and qualifications to manage the project and deliver project results on time based on past experience?
12. Is the scope of the proposed project feasible and likely to be accomplished in terms of expected deliverables and timeframes?

Expected Outcomes and Benefits

13. Will the proposed project advance the creation and application of new knowledge in support of promoting increased awareness of privacy issues and enhancing protection of personal data in Canada?
14. Is there a clear and effective strategy for engaging key stakeholders throughout the research process and for disseminating research results to relevant audiences and/or the public at large?
15. Is there a clear and effective strategy for transforming research results into useable outcomes and enabling relevant end-users to apply them in practice?

Additional Considerations

In addition to a relative assessment of project proposals based on the merit criteria set out above, consideration will also be given to balancing the selection of successful projects across all four priority areas, wherever possible.

5. Control Procedures

5.1 Contribution Agreement

On approval of a request for a contribution, a detailed Contribution Agreement will be drawn up and signed by the recipient and the OPC. A Contribution Agreement is an agreement between the organization and the OPC regarding the project contribution awarded.

By accepting a contribution, your organization agrees to carry out the funded project and to be accountable for the amounts received. Accordingly, the Office agrees, subject to conditions stipulated in the Contribution Agreement, to fund all or part of the project's costs.

As specified in the Agreement, the recipient cannot make material changes to the scope of the project without the prior written consent of the OPC.

5.2 Reporting Requirements

By signing the Agreement, your organization agrees to submit progress and financial reports, as specified in the Agreement for the duration of the project.

The OPC reserves the right to publish the name of your organization, a summary of your project, as well as the amount of the contribution awarded in any manner it deems fit including, but not limited to, posting on the OPC's web site, publication in the Main Estimates, and so forth.

Recipients of OPC funding under the Contributions Program may also be surveyed some time after the completion of the project about further related work or follow up activities in an ongoing effort to evaluate the impact of the research and the value of the Contributions Program.

5.3 Research Ethics and Integrity

Where applicable, applicants are required to adhere to the principles and responsibilities of researchers as set out in the Tri-Agency Framework: Responsible Conduct of Research, and if their proposed project involves human participation, the 2nd Edition of the Tri-Council Policy Statement:Ethical Conduct for Research Involving Humans.

5.4 Method of Payment

Payment will be in accordance with the approved cash flow as well as the work plan, and will be consistent with the Treasury Board guidelines for cash payment under the Policy on Transfer Payments. See http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=13525.

Final payment of the hold back, not exceeding 20 per cent of the total contribution, or recovery of surplus, if necessary, will be made when the recipient has satisfied all the requirements of the project and on receipt and acceptance by the OPC of financial statements.

Payments will be made on the basis of documented claims for reasonable eligible costs incurred, to be submitted by recipients as per the Agreement. The Privacy Commissioner is unable to make any payment to recipients prior to receiving an invoice for eligible costs that have been incurred.

Contributions are normally awarded for specific projects on an annual basis. In the case of projects extending over more than one year, payment is subject to the appropriation of funds by Parliament, and satisfaction of review and reporting requirements by the recipient, in accordance with the terms and conditions of the Contribution Agreement.

5.5 Public Acknowledgement and Recognition

The recipient shall acknowledge the Privacy Commissioner of Canada's contribution to the project in all materials, be they written, oral or electronic, used to describe the project or resulting from the project. The Privacy Commissioner, or a designated representative of her Office, will be given the opportunity to participate in a public announcement of the project.

5.6 Audit Requirements

According to the Contribution Agreement, your organization shall keep proper books, accounts and records of revenues and expenses received in connection with the funded project. Such accounts and records shall be open to audit and inspection by the OPC to ensure compliance with the terms of the Contribution Agreement. The OPC may make copies and take extracts at all reasonable times for a period of six years after completion of the project.

The OPC may request at any time that recipients provide satisfactory evidence to demonstrate that all eligible costs claimed have been paid.

5.7 Contribution Payments

Where for any reason:

1. a recipient is not entitled to the contribution, or
2. the amount of the contribution exceeds the amount expended, or
3. a recipient is late in submitting a deliverable as per the terms of the contribution agreement, or
4. a recipient submits deliverables that are incomplete or unsatisfactory as per the terms of the contribution agreement,

the Commissioner may at her discretion withhold payment or a portion of the total amount awarded to the Recipient for the project, or require the Recipient to repay all or part of the advances or interim payments to the Office, those amounts being a debt due to Her Majesty the Queen in Right of Canada.

6. Language Policy

Project deliverables may be produced and/or submitted in the Official Language of your choice. Organizations working at the national level and receiving substantial financial assistance from the OPC are encouraged to provide services in both English and French and to foster the recognition and use of those languages especially in areas of significant demand recognized by the Office.