Contributions Program applicant’s guide 2017-18

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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 concerning 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, the Values and Ethics Code for the Public Service, the Lobbying Act, 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 January 16, 2017, at 11:59 PM (your local time).

Please forward your application to the following address:

Office of the Privacy Commissioner of Canada
Care of: Contributions Program
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Email: contrib@priv.gc.ca
Fax: 819-994-5424

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 per year, and the maximum total amount that can be awarded to any single organization is $100,000 per year.

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 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 will be considered.  Proposals that touch on issues that fall within the federal public sector can be submitted, provided that the primary focus of the proposal deals with the private sector.

2.3 Strategic Priorities 2017-18

Innovative Research Related to OPC Strategic Priorities

As in past years, the OPC is inviting research and knowledge translation applications that relate to one or several of our priority areas and related implementation strategies.
The OPC’s priority areas are:

1. The Economics of Personal Information
2. Government Surveillance
3. Reputation and Privacy, and
4. The Body as information

In implementing these priorities, the OPC has committed to adopting the following cross-cutting strategies:

• Exploring innovative and technological ways to protect privacy
• Strengthening accountability and promoting good privacy governance
• Protecting privacy in a borderless world
• Enhancing our public education role
• Enhancing privacy protection for vulnerable groups.

Special Call for Codes of Practice

In addition, this year, the OPC is launching a Special Call for proposals aimed at developing Privacy Codes of Practice. Specifically, we are inviting proposals by not-for-profit industry, trade or professional associations, academics, civil society groups, and/or consumer advocacy groups to develop privacy codes of practice that will:

• Enhance organizational accountability,
• Promote regulatory compliance through greater certainty and predictability, and
• Augment information to individuals beyond privacy policies, helping to promote transparency and openness with respect to how privacy obligations are met and addressed.

Codes of practice can be aimed at a particular industry sector (e.g. finance, retail, automotive) or a particular activity (e.g. de-identification, online behavioral advertising, telematics).

Paragraph 24(c) of PIPEDA mandates the OPC to encourage organizations to develop codes of practice to meet their obligations under PIPEDA. This year’s OPC call for proposals is a unique opportunity to spark creative and innovative approaches to do so.

Though not mandatory criteria, the following elements have been suggested as desirable characteristics of a successful code of practice^{Footnote 1}:

• Multi-stakeholder participation and consultation, including on the intended purpose of the code;
• A coordinated framework outlining how the code will be planned, developed, implemented, reviewed and updated;
• Agreement on the content of the code by a critical mass of stakeholders.

Our main objective through this year’s Special Call is to provide seed funding for interested applicants to propose a well-developed plan and process for achieving a successful code of practice on a PIPEDA-related compliance issue of importance to Canadians. Our preference is to fund one-year projects that result in a successful code by the end of the fiscal year 2017-2018.  However, recognizing the challenges of fully developing a code of practice within a 12-month timeframe, the OPC would be open to funding proposals over a two-year period if considered justifiable (see section 2.9 below).

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 findings are transformed into 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 stakeholders and providing an opportunity for effective knowledge exchange between theoretical concepts and practical realities;
• Engagement of 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 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, educational games, videos, and documentaries aimed at general and public audiences, etc.)

2.4 Allocation of Research Funding

The OPC has a budgetary envelope of $500,000 set aside each year which is specially-dedicated to successful projects under its Contribution Program, wherein successful projects can be awarded up to a maximum of $50,000 each. Specifically for the 2017-18 fiscal year, the OPC will sub-allocate its annual $500,000 research fund as follows:

1. At least $300,000 will be set aside for successful research proposals related to OPC’s Strategic Priorities;
2. A maximum of $150,000 will be allocated to successful proposals related to the development of Codes of Practice (Note: If there are insufficient successful proposals related to the development of Codes of Practice, the unused balance of $150,000 will be redirected to proposals related to the OPC’s Strategic Priorities); and,
3. Up to $50,000 will be set aside for the 2017 Pathways to Privacy call for proposals. (Note: This call will be issued in the spring/summer of 2017 and does not form part of the current call for proposals.)

2.5 Encouraging Partnerships between Academia and Civil Society

The Program has made substantial gains over the past years in funding a greater diversity of research applicants. The Office wishes to continue to actively engage civil society groups through the Program, so that by way of these groups increased public awareness of research findings generated under the Program may be achieved. To this end, the Office this year again encourages universities and other research groups to develop new partnerships with civil society organizations as part of their proposals. For example, universities could partner with public education groups, or advocacy associations could partner with research groups. Additional points will be allocated to proposals that put forward plans for such partnerships.

2.6 Work Previously Done Under the Program

The Contributions Program seeks to advance the creation and translation of new knowledge on emerging issues related to privacy promotion and protection. Accordingly, applicants are encouraged to take into account previous projects done or currently being completed under the Contributions Program when developing their proposals, with a view to complementing past work to further advance the development and translation of new knowledge or perspectives. A full list of Contributions Program-funded projects since the Program’s inception in 2004 is available.

2.7 Projects Must be National in Scope

The mandate of the OPC is to oversee compliance with the Personal Information Protection and Electronic Documents Act, Canada’s private sector privacy law. Accordingly, only projects that are nationwide in scope and/or application, and are relevant to the federal government’s sphere of jurisdiction will be considered for funding. Projects that examine issues or address concerns that are exclusively or predominantly local, provincial or foreign in scope will not be considered for funding.

2.8 Projects Must Include Detailed Methodology

The proposals that are submitted under the Contributions Program can be qualitative and/or quantitative in nature. In both instances, the OPC seeks to fund proposals that demonstrate sound methodology. In order for the OPC to evaluate a proposal’s methodology, the applicant must provide a detailed description of the means by which they seek to achieve their results. Where applicable, applicants should provide a detailed list of stakeholders they intend to survey/interview and the survey method and instruments they intend to use.

2.9 Duration of Projects

The OPC Contributions Program is structured to provide funding for eligible expenses that are incurred within the same fiscal year that funds have been awarded—that is between April 1, 2017 and March 31, 2018. Incurred expenses must have been paid by the Recipient before they are invoiced to the OPC. Exceptionally, the OPC may fund projects that extend beyond the end of the fiscal year (i.e. March 31, 2018) if the proposal persuasively demonstrates why the project requires more time to be completed and should be funded beyond the typical one-year period. For multi-year proposals, applicants are requested to submit work plans that cover the entire duration of the project.

2.10 Allowable Expenses

Funds may be used only for expenses directly related to the activities of the project. These activities must be 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 a Contribution Agreement. The OPC will not support any expenses that have not been paid by the Recipient before they are invoiced to the OPC.

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

Indirect administrative expenses (i.e. overhead) should be limited to no more than 15 per cent (15%) of the total project expenses incurred under the Contribution Agreement.

Contributions 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, see the Costing Memorandum in “Schedule B – Project Budget”.

3. Completing the Application

The following information corresponds to each section of the Application Form. Applicants 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:

• Basic Information: Organization name, address, billing address, telephone number, facsimile number and e-mail address of the applicant's authorized representative, , names of principal personnel and project administrators. Please provide contact information for the principal researcher (where applicable), the person responsible for administering the project, and the finance/accounting contact person.
• Legal Status: An attestation/confirmation that your organization is a not-for-profit organization.
• Organizational Background: Background of the organization including its mandate, objectives, and accomplishments.
• Previous Financial Support: An indication of any previous financial support received received in the last five years from the OPC including the amount, the year when the funding was provided, the purpose of the funded activity, and the results achieved.
• 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.
• One-Page Summary: A concise one-page summary of the proposed project that can be used for the Contribution Agreement.
• Timeline and Monitoring: Timeframe, work plan detailing activities to be undertaken to support the attainment of project objectives, and monitoring activities.
• Budget: A detailed budget for the project showing amount(s) being requested from the OPC and other proposed sources of revenue, including in-kind support. In presenting the budget to the OPC, Applicants must use the form provided with this Guide, namely Schedule B — Project Budget. Furthermore, in their proposal, Applicants must provide detailed information explaining and justifying each amount entered in Schedule B—namely for salaries and benefits; travel expenses; telecommunications; contractual services; materials and supplies; rentals (includes equipment and meeting rooms); and other expenses.
• Community, Sectoral, or Industry Involvement: Where appropriate, an indication of the level of community, sectoral or industry involvement (commitment, endorsement, scope and level of participation, co-operation and volunteer involvement).
• Provincial/Territorial Support: Where appropriate, an indication of the degree of provincial, territorial and municipal support for the project (cash and/or in-kind).
• Knowledge Translation Activities: A plan for disseminating project 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 the general public).
• 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. Applicants 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 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 Her Majesty the Queen in Right of Canada 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 in this Guide.

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 academia or the not-for-profit sector.

In order to proceed to full assessment, all proposals submitted to us must, in addition to meeting the eligibility criteria in section 1.1, also meet these two (2) exclusionary criteria:

1. OPC priorities and strategic approaches – Only proposals that align with at least one of the OPC’s new priorities will be considered. The OPC’s new priorities are: the Economics of Personal Information; Government Surveillance; Reputation and Privacy; the Body as Information. (See section 2.2 above for more information.)
2. PIPEDA – Only proposals that address privacy issues relevant to the Personal Information Protection and Electronic Documents Act (PIPEDA) will be considered. Proposals that touch on issues that fall within the federal public sector can be submitted, provided that the primary focus of the proposal deals with the private sector or the interface between the private and public sectors. (See section 2.2 above for more information.)

Projects that are screened in based on the above-mentioned conditions will then be evaluated on the basis of the following evaluation criteria:

A. Assessment Criteria for Proposals Related to OPC Strategic Priorities

General Quality and Competencies (25 points)

1. Overall quality of the project (10 points)
2. Requisite knowledge and understanding of relevant privacy issues (5 points)
3. Integration of interdisciplinary perspectives and approaches (5 points)
4. Relevant partnerships and collaborations (5 points)

Innovation (30 points)

5. Novelty of issues being examined (15 points)
6. Creative research method and/or knowledge translation approach (15 points)

Feasibility (15 points)

7. Realistic budget (5 points)
8. Sound methodology (5 points)
9. Manageable scope and timelines (5 points)

Expected Benefits and Outcomes (30 points)

10. Expected positive impact on Canadians’ privacy rights (10 points)
11. Soundness of knowledge translation strategy (10 points)
12. Relevance and timeliness of expected outcomes (10 points)

B. Assessment Criteria for Proposals Related to Codes of Practice

General Quality and Competencies (20 points)

1. Overall quality of the project (5 points)
2. Requisite knowledge and understanding of relevant privacy issues (5 points)
3. Integration of diverse stakeholder perspectives (10 points)

Innovation (15 points)

4. Novelty of proposed approach (15 points)

Feasibility (15 points)

5. Realistic budget (5 points)
6. Sound methodology (5 points)
7. Manageable scope and timelines (5 points)

Expected Benefits and Outcomes (50 points)

8. Expected positive impact on Canadians’ privacy rights (25 points)
9. Relevance and timeliness of expected outcomes (25 points)

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 Recipient and the OPC regarding the amount of Contribution awarded, in consideration for specific deliverables to be completed.

By accepting a Contribution, the Recipient agrees to carry out the funded project, to be responsible for realizing all deliverables specified in the Contribution Agreement, and to be accountable for the amounts received. As consideration, the OPC agrees, subject to conditions stipulated in the Contribution Agreement and to renewal of the program by the Minister, to fund all or part of the project's costs.

IMPORTANT – As specified in the Agreement, the Recipient cannot make material changes to the scope of a project—e.g. significantly changing or dropping a deliverable, or reallocating significant amounts of money from a budget line item to another—without the prior written consent of the OPC.

5.2 Reporting Requirements

By signing the Agreement, the Recipient 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 the Recipient, a summary of the 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 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 made in accordance with the approved cash flow in the Contribution Agreement, as well as the work plan and the agreed-to deliverables, and will be consistent with Treasury Board guidelines for cash payment under the Policy on Transfer Payments.

Final payment of a 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 upon receipt and acceptance by the OPC of financial statements.

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

Payment will be processed using a direct deposit to the Recipient’s bank account, and the Recipient will be asked to provide banking information to the OPC for deposit purposes.

Contributions are normally awarded for specific projects on an annual basis. In the case of projects extending over more than one fiscal year (April 1 to March 31), 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 his Office, will be given the opportunity to participate in public announcements related to the project.

5.6 Audit Requirements

According to the Contribution Agreement, the Recipient shall keep proper accounts and records of revenues and expenses received in connection with the funded project, for at least six years after completion of the 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:

• a Recipient is not entitled to the Contribution,
• the amount of the Contribution exceeds the amount actually expended,
• a Recipient is late in submitting a deliverable as per the terms of the Contribution Agreement,
• a Recipient fails to submit one or more deliverables as per the terms of the Agreement,
• a Recipient submits deliverables that are incomplete or unsatisfactory in relation to the terms of the Contribution Agreement,
• a Recipient does not provide in his deliverable(s) appropriate value for money, as assessed by the Commissioner in evaluating the quality of the deliverables submitted to him,

the Commissioner may, at his 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 the Recipient’s choice. Organizations working at the national level and receiving 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.

7. Access to Information and Privacy

The information provided to the OPC as part of the application is subject to the Privacy Act and the Access to Information Act. For more information about what this entails please contact the OPC’s Chief Privacy Officer at (819) 994-5970.

8. Appendices

• Application Form (PDF version)
• Schedule B – Project Budget (PDF version)
• Schedule C – Project Expenditures Report (PDF version)