Executive Summary: CANPASS Program Umbrella Privacy Impact Assessment

From: Canada Border Services Agency

This Umbrella Privacy Impact Assessment (PIA) includes all activities relating to the collection, storage and use of personal information by the Canada Border Services Agency (CBSA) as it relates to the CANPASS suite of programs (CANPASS Corporate Air, CANPASS Private Air, and CANPASS Private Boats ), the Commercial Driver Registration Program (CDRP) and the Pilot Project for Travellers in Remote Areas – Québec (PPTRA-Q). These Trusted Traveller Programs (TTPs) store personal information in similar databases whereby CANPASS Corporate Air, Private Air, Private Boats and CDRP all use the Canadian Processing Centre System (CPCS) and PPTRA-Q uses the Global Enrolment Component (GEC).

The CANPASS suite of programs is a suite of voluntary TTPs in the air and marine modes offered by the CBSA to expedite the border clearance process for frequent, pre-approved, low risk travellers arriving in Canada. A separate application form is required for each applicant and CANPASS program. The existing CANPASS Corporate Air and CANPASS Private Air programs are open to Canadian and United States (US) citizens and permanent residents who meet the program eligibility criteria.

CANPASS Corporate Air

This CANPASS program is for eligible companies owning or operating a corporate aircraft that frequently flies directly to Canada from the US and is carrying no more than 15 pre-approved, low-risk passengers and crew. They report their estimated time of arrival to the Telephone Reporting Centre (TRC) of the CBSA. Corporations may also temporarily authorize up to four business associates (non-program members) when travelling on business matters if they are travelling with a CANPASS Corporate Air member and meet the eligibility criteria.

CANPASS Private Air

Eligible private aircraft operators that fly directly to Canada from the US and are carrying no more than 15 pre-approved, low-risk passengers and crew on board their aircraft can obtain expedited clearance by reporting their estimated time of arrival to the TRC of the CBSA.

To become a member of either the CANPASS Corporate Air or Private Air program, an applicant voluntarily submits an application to a CPC along with any photocopied documents in support of the application. The personal information received and stored by the CBSA is used to confirm an applicant’s identity and to determine their eligibility as well as their continued eligibility in the program.

CANPASS Private Boat

This program provides expedited border clearance for low-risk, pre-screened travellers entering Canada by private pleasure boat. Members are entitled to use telephone reporting marine sites not available to other boaters. Members meet their border clearance/declaration obligations through verbal reporting to the TRC. By April 4, 2023, all memberships should be expired^{Footnote 1}.

The Commercial Driver Registration Program (CDRP)

Since 2002, the CDRP offers expedited clearance processes for eligible goods to pre-authorized importers, carriers and commercial drivers. The program is open to citizens and permanent residents of Canada and the US who meet the program eligibility criteria.

CDRP-registered drivers can carry goods for carriers who participate in the CSA program. The CDRP is one of three components required for membership in the Customs Self-Assessment program (CSA), which include importer, carrier and commercial driver applications.

There are no electronic applications, an individual must complete the application form online then print a copy, sign it and submit the form to a CPC along with any supporting documents. A risk assessment to verify criminal and compliance history is a part of each application and renewal.

Pilot Project for Travellers in Remote Areas – Québec (PPTRA-Q)

The PPTRA-Q was launched on July 14, 2014, to pilot the provision of border services during specified hours of operation when there is no officer on site to provide access to 5 Canada/US ports of entry (POEs) in the Beauce, Kamouraska and Témiscouata Regions of Québec. The CBSA is in the process of including the PPTRA-Q into the Presentation of Persons (2003) Regulations and to specify the eligibility requirements as well as the application and enrolment processes.

PPTRA-Q membership is not required to cross through one of these POEs during regular hours of operation when there are officers on site. This program is intended for leisure travellers (with no commercial goods) and commercial drivers who are only carrying logs and wood shavings as described in tariff items 44.01 and 44.03 of the Schedule to the Customs Tariff in the cargo of a registered commercial vehicle.

Protecting your personal information

The following personal information elements will be managed by the TTPs:

• preferred language
• full name(s)
• gender
• date of birth
• place of birth
• administrative information (new application/renewal, border crossing most frequently used and participation in other CBSA TTP’s)
• residence
• proof of citizenship/immigration status
• address history for the last five years, mailing address, phone number, email address
• employment history for the last five years and employer name and address
• driver’s license number and issuing province or state (CDRP only)
• purpose of travel to Canada for foreign citizens and non-Canadian permanent residents of other countries
• questions to determine eligibility
• customs programs (company information)
• fee payment
• privacy and consent statements and certification
• signature

Personal information is not disclosed to other federal departments during the risk assessment process unless prescribed by the Regulations. The collection of information for the TTP’s is used to determine an applicant’s eligibility for inclusion in the program, as well as their ongoing eligibility. The CBSA uses the personal information to query various enforcement and information databases to which the CBSA has access, including the following:

• Canadian Police Information Centre (CPIC) – Royal Canadian Mounted Police (RCMP) – contains criminal records

The CBSA may also check:

• National Crime Information Center (NCIC) – contains US national intelligence information – wants/warrants and criminal records. This is only checked when an applicant self-discloses a US conviction on their application or when there are precipitating circumstances indicating that the applicant has engaged in some form of criminal activity

The CBSA systems that are used include the following:

• Integrated Customs Enforcement System (ICES) – CBSA database that contains customs seizures for a period of 6 years plus the current year, and current data. The ICES also contains customs and immigration lookouts and Wants and Warrants
• Interdiction and Border Alert System (IBAS) – CBSA database that accumulates data to allow high-speed/high-volume querying by other applications against multiple sources including the following:
  • Global Case Management System (GCMS) – Immigration, Refugees and Citizenship Canada (IRCC) – information related to Criminal Removals;
  • Lost, Stolen, Fraudulent documents (LSFDs); and
  • Criminal Records in Canada and the US

When an applicant pays by credit card, the credit card numbers and expiry date are captured in CPCS. For TTP’s using GEC, this data is sent to CPCS where a client record is created. This information is kept for two years after the redress period for refused applications or two years after the termination or expiration of the membership, as the case may be.

Right of access

A separate Privacy Statement and Consent Statement appears on each program’s application form which describes the purpose, use, disclosure and retention of personal information collected or created.

You may formally request access to your personal information, or access to corporate records related to or created by the CANPASS suite of programs, the CDRP or PPTRA-Q by contacting the Information Sharing, Access to Information and Chief Privacy Office (ISATICP Office). More information about this can be found at:
Access to information and privacy - Contact us.

Accountability

If a traveller has concerns about the collection, use, disclosure or retention of their personal information, they may issue a complaint to the CBSA ISATICP Office. Complaints should be made in writing, and include the traveller’s name, contact information and a brief description of their concerns. Contact information for the ISATICP Office at the CBSA can be found at:
Access to information and privacy - Contact us.

If a traveller is denied membership in one of the TTP’s or their membership is cancelled or suspended from any program, they may write to the Recourse Directorate at Headquarters or submit an E-appeal on-line to request a review of the decision. The request for review must be submitted within 90 days from the date the rejection, suspension or cancellation of the membership becomes effective. It becomes effective either immediately when notified in person or 15 days after the notice is mailed to you. Further information on these processes may be found on the Recourse: Appeals/Reviews section.