Pathways to Privacy Applicant’s Guide 2017-18

Applicant's Guide

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1. Purpose of this Guide

The Office of the Privacy Commissioner of Canada (OPC) is making $60,000 available for funding of knowledge translation initiatives in Canada under our Pathways to Privacy (P2P) Program.

Funding will be provided to initiatives that translate into action the results of previously-funded research under the OPC Contributions Program and other funding programs relevant to advancing privacy protection in Canada.

This guide is designed to help interested applicants prepare project funding proposals. 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. 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 September 22, 2017, at 11:59 p.m.

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

We encourage applicants to submit their proposals electronically at the above noted email address.

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 is making $60,000 of this budget available for this year’s P2P program, which is the maximum amount that can be awarded to any one initiative under this call.

2. Contributions Program

2.1 Objectives

The general objectives of OPC’s Contribution Program 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.

The P2P program places more specific emphasis on the 3^rd and 4^th of these objectives.

2.2 Eligible Projects and Research Priority Areas

Knowledge translation is the process by which research results are designed, transformed and/or disseminated in order to broaden awareness and enable practical application by relevant users.  

Insofar as this specific call is concerned, it involves translating knowledge about privacy risks and how to mitigate them in practice.

Examples of these types of initiatives that can be funded under this call include:

• Art shows, exhibits or performances that feature privacy as the key theme of the event;
• Workshops, conferences or symposia aimed at disseminating privacy related knowledge to relevant stakeholders;
• Innovative and interactive online approaches for disseminating research findings and raising public awareness of privacy issues;
• Education curriculum for teachers to use with students or parents to use with their children;
• 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 or mobile applications, aimed at increasing awareness of privacy threats and how to better protect personal information;
• Videos or documentaries aimed at general and targeted audiences;
• Any other innovative and creative knowledge translation projects that help people or organizations better understand privacy risks and how to mitigate them in practice.

Funding will be provided to initiatives that translate into action the results of previously funded research under the OPC Contributions Program and other funder’s programs relevant to privacy protection in Canada.

Research outcomes resulting from the OPC Contributions must form at least 50% of the content of the knowledge translation initiatives presented for consideration under this call for proposals.

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 proposals that address privacy issues in the private sector or at the interface between the private and public sectors are eligible for funding.

Research priority areas

For the purposes of this call, the OPC will only accept and review proposals that address one or more of the four priority areas of the Office, namely:

1. The economics of personal information
2. Government surveillance
3. Reputation and privacy, and
4. The body as information

For full details on the research priorities, refer to the OPC publication The OPC Strategic Privacy Priorities 2015-2020.

2.3 Timing of Knowledge Translation Initiatives

Knowledge translation initiatives funded under this call must be completed no later than March 31, 2018.

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, i.e. no later than March 31, 2018.  The budget plan for the initiative must therefore reflect this constraint, and incur no expenses expected to be reimbursed by the OPC after March 31, 2018.

2.4 Allowable Expenses

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

• salaries and benefits for members of the project team;
• administrative costs, translation, administrative assistance and publication costs;
• contract costs for specialized technical or other expertise not available in-house or work not reasonably performed in-house; and
• other costs including travel (not to exceed government travel regulations), 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.

Indirect administrative expenditures (i.e. overhead) 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 initiative 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 – Project Budget”.

3. Completing the Application

3.1 The Application Form

Applicants must fill out and submit the Application Form provided for under this call.  It is important that you provide answers to all questions in the form and include any additional material in an appendix to the form.  Application forms that are not properly or completely filled out may lead to the rejection of funding proposals.

3.2 The Proposal

Applicants must provide a detailed project proposal. If your proposal is retained for funding, it will serve as a basis for your Contribution Agreement with the OPC and related cash flow. The project proposal must contain the following sections/information:

1. Basic Organizational Information: Name of applicant organization, 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 the initiative’s title, goals and objectives, identification of the target groups, identification of the anticipated results and expected benefits for Canadians in terms of the dissemination and application of new knowledge in the area of privacy and data protection. Note that the project description must show how at least 50% of the substantive content of the project will draw upon previously or currently funded research under OPC’s Contributions Program.
6. Stakeholder Engagement: A plan to involve relevant stakeholders in the knowledge translation initiative, so as to enable uptake and application of research.
7. One-Page Summary: A concise one-page summary of the proposed privacy knowledge translation initiative that can be used for the Contribution Agreement.
8. Timeline and Monitoring: Timeframe, work plan detailing activities to be undertaken to support the attainment of project objectives, and monitoring activities. Privacy knowledge translation initiatives funded under this call must be completed no later than March 31, 2018, and proposals for funding must plan accordingly to be eligible for funding.
9. Budget: A detailed budget of the knowledge translation initiative, including amount(s) being requested from the OPC and other proposed sources of revenue including in-kind support. In presenting the budget, the applicant must use the form provided by the OPC in Schedule B—Project Budget.
10. Community Involvement and Support: An indication of the level of community involvement (commitment, endorsement, scope and level of participation, co-operation and volunteer involvement).
11. Provincial/Territorial Support:  Where appropriate, an indication of the degree of provincial and territorial support for the project.
12. Acknowledgement of OPC Funding: An indication of how the applicant intends to 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 their proposed privacy knowledge translation initiatives. Potential recipients are required to disclose all sources of funding 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 privacy knowledge translation initiatives. This should also include applications for financial assistance which are pending.

In the event that total government assistance (including provincial and municipal assistance) received for the project exceeds the total cost of the initiative, 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 initiative. Applicant organizations and applications for funding will be reviewed in accordance with the Contributions Program objectives as well as the specific eligibility criteria as outlined above and described below.

4.1 Assessing 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:

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 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. In exchange, the OPC 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 and publication in the Main Estimates.

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 initiative 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.

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.

Payment will be processed using a direct deposit to the Recipient’s bank account. The Recipient will be asked to provide banking information for that purpose.

5.5 Public Acknowledgement and Recognition

Applicants must commit to recognizing OPC support for the initiative in promotional material prior to the initiative being made public. Applications must include a detailed communications plan (strategies, tools and timeline), a proposal on the use of social media platforms, and a commitment to use pre-existing OPC Pathways to Privacy graphics and branding, if appropriate.

Funding recipients shall acknowledge the Privacy Commissioner of Canada's financial contribution to their knowledge translation initiative in all materials, be they written, oral or electronic, used to describe the initiative. The Privacy Commissioner, or designated representatives of the OPC, will be given the opportunity to participate in public announcements related to the initiative.

5.6 Audit Requirements

The funded 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 related to their privacy knowledge translation initiative as per the terms of the Contribution Agreement, or
4. a recipient submits a deliverable that is incomplete or unsatisfactory as per the terms of the Contribution Agreement,

the Commissioner may at his or 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 interim payments to the Office, those amounts being a debt due to Her Majesty the Queen in Right of Canada.

6. Language Policy

Knowledge translation initiatives may be produced and/or submitted in the Official Language (English and French) of the Recipient’s choice.

Organizations working at the national or regional level and receiving substantial financial assistance from the OPC through its Contributions Program are encouraged to produce outcomes in both English and French.

The ability of applicants to produce outcomes in both official languages will be considered by the OPC in evaluating proposals under its P2P program.

7. Access to Information and Privacy

The information provided to the OPC as part of the application for funding and Contribution Agreement is subject to the Privacy Act and the Access to Information Act, and may be accessible or protected, as required, under the provisions of the Acts. For more information contact the OPC.