Privacy Impact Assessment

Privacy Impact Assessment Summary for High-Integrity Personnel Security Screening Standard (HIPSSS)

In November 2007, the Canada Border Services Agency (CBSA) Executive Management Committee approved the development of all required processes to implement enhanced personnel security screening measures allowable to decrease the risk of infiltration and corruption and maintain program integrity under the Policy on Government Security for all CBSA positions; and the creation of a CBSA High-Integrity Personnel Security Screening Standard (HIPSSS). The approval from the TB Cabinet Ministers Committee was required for policy approval through a TB Submission. Approval to proceed as requested with the phased implementation of HIPSSS obtained at the May 31, 2012 meeting. The following information applies to the HIPSSS:

Current Security Screening Process

The current Personnel Security Screening Process collects personal information on an individual's (potential or current employee) by way of a criminal record check, credit check, fingerprint check, a Residency and Travel Outside Canada Questionnaire (Annex 27_RTOC.), CSIS indices checks (when applicable) employment/education verifications and when required, a subject interview. This information is collected with the informed consent of the individual prior to conducting any of the checks mentioned above. This information is protected in accordance with the Financial Administration Act and the Policy on Government Security.

New High Integrity Personnel Security Screening Process

The change to the current personnel security screening process involves a phased-in implementation of enhanced security screening initiatives for potential new employees to the CBSA and existing staff when a determination to grant, deny or revoke a security screening (Reliability Status) is made prior to processing a security clearance (i.e., Secret and Top Secret).

The additional integrity tools and background checks under the HIPSSS include:

• Royal Canadian Mounted Police (RCMP) Law Enforcement Checks;
• Citizenship Immigration Canada (CIC) and CBSA enforcement database checks;
• an Integrity Questionnaire;
• an Integrity Interview; and a Psychological Test administered for cause only.
• The enforcement database checks will also apply to existing employees upon security screening renewal, when an upgrade to their security screening is required to support a new position.
• An Integrity Interview may be administered when adverse information has been uncovered on new applicants or when a review for cause investigation is launched based on adverse information that may affect an existing employee's security screening level.
• Completion of the Integrity Questionnaire will be required by all external applicants who do not hold a valid security screening from a Federal Government Department.
• The implementation of these additional verifications for existing employees and new applicants to the CBSA occurred after Treasury Board approval and consultation with the Unions representing the Agency's employees had taken place.
• The collection, retention and disclosure of information from the above noted checks abide by the Financial Administration Act, the TBS Policy on Government Security, and the TBS Personnel Security Standard.

The additional personal information collected through the HIPSSS may be shared internally within the CBSA, with staffing, Labour Relations, Legal Services and Hiring Managers when Reliability Status is denied or revoked. Relevant information (ethics and integrity concerns) may also be shared with a psychologist when psychological testing for cause is required. The personal information is safeguarded electronically on the CBSA Personnel Security Screening Database (Protected B), Case Management System (Secret) and physically in the Personnel Security Screening Section's file room which has been security cleared to Secret. CBSA has strong safeguards in place for both the physical and digital storage of personal information related to HIPSSS. The safeguarding procedures have been consolidated in Annex E of the HIPSSS Standard Operating Procedures (Annex 3.)

The individuals that will be affected by these changes include all of the CBSA staff and potential recruits in a phased-in approach as follows:

• Phase 1 — Effective June 28, 2012 — All external applicants (including new recruits) applying to and existing employees applying to/or occupying "higher integrity"* positions will be screened through the HIPSSS either when applying or at the time of the renewal of their security screening.
  
  *Higher Integrity Positions are positions which provide employees with significant authorities and access to sensitive databases and/or information. Examples include authorities to make decisions related to the movement of people and goods, the issuance of contracts and other decisions that may have significant financial/revenue implications for the Agency.
• Phase 2 — October 2012 — December 2013 — Extension of Phase 1: A preliminary review of Phase 1 has resulted in the following modifications to the program, effective December 2012:
  • A revised Integrity Questionnaire will be implemented.
  • The Integrity Questionnaire portion of HIPSSS will be limited to individuals applying to "higher integrity" positions within CBSA who do not have a valid security screening from either CBSA or another Federal Government Department.
  • Only the following individuals will be screened through the HIPSSS during Phase 2:
    • All internal and external applicants "higher integrity" positions at the CBSA;
    • CBSA employees occupying "higher integrity" positions at the time of the renewal of their security screening or when they move into such positions;
    • All armed officers upon expiration of their Possession and Acquisition Licence (PAL) or security screening, whichever comes first; and all officers at the time they are scheduled to attend the Duty Firearm Course, if they do not have a PAL and have not yet been screened through the HIPSSS; and,
    • Existing employees where we have obtained or uncovered information that places their security screening status in question (Review for Cause).
• Phase 3 — January 2014 — Dec 2014 — Conduct a program evaluation of the HIPSSS and amend the program where required.
• Phase 4 — January 2015 — 2016 — At this point in time, all positions in CBSA will be deemed "higher integrity" and subject to the HIPSSS. All existing employees and applicants to the CBSA to any position (including contractors and external service providers) will be screened through the HIPSSS either at time of application or renewal.
  
  NOTE: The HIPSSS implementation will need to take into account any changes made to the Personnel Security Standard implemented by Treasury Board Secretariat.