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

HIPSSS Executive Summary

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 through the creation of the CBSA High-Integrity Personnel Security Screening Standard (HIPSSS). These measures were designed to decrease the risk of infiltration and corruption and maintain program integrity as required under the Policy on Government Security for all CBSA positions. The CBSA put forward a Treasury Board (TB) Submission to obtain the required Policy approval from the TB Cabinet Ministers Committee. Approval to proceed with the HIPSSS implementation was obtained at the May 31, 2012 Committee meeting. Three versions of this Privacy Impact Assessment have been filed with the Office of the Privacy Commissioner (OPC): the first in May 2012 and updated versions in November 2012 and February 2013 in response to OPC feedback. This is the fourth and final version of the HIPSSS Privacy Impact Assessment. The following information applies to the HIPSSS:

Treasury Board Secretariat (TBS) Policy on Government Security (PGS), Personnel Security Standard

The TBS PGS, Personnel Security Standard[1] outlines the baseline Personnel Security Screening Process for the Government of Canada. The process sees the collection of personal information for an individual (potential or current employee or other individuals working at the CBSA) by way of a criminal record check, credit check, fingerprint check, a Residency and Travel Outside Canada Questionnaire (Previously submitted annex 27_RTOC), Canadian Security Intelligence Service (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 PGS.

New High Integrity Personnel Security Screening Process

The change to the former personnel security screening process involved the implementation of enhanced security screening initiatives for potential new employees to or individuals coming to work at 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, CBSA enforcement database checks, an Integrity interview, open source checks (for cause only) and a Psychological Ethical Judgement Test (for cause only). When the CBSA first implemented the HIPSSS in June 2012, it had intended to use a written Integrity Questionnaire for all candidates. In the months that followed, and with feedback from the OPC, the CBSA discontinued the use of the written questionnaire in October 2012. The written Questionnaire has been replaced with Integrity Interviews. The questions from the Questionnaire were modified based on consultation with the OPC and other stakeholders, and were used to develop an Integrity Interview Guide, henceforth referred to as the Guide. The Guide was implemented in May 2013. The Guide is used during face-to-face Integrity Interviews as part of the Reliability Status screening for the recruitment of Border Services Officers  and other individuals coming to work at the CBSA. Law Enforcement Record Checks and CBSA enforcement database checks will apply to existing employees upon security screening renewal and when an upgrade to their security screening is required to support a new position. The Integrity Interview may also apply to existing employees for cause if adverse information[2] is found. Please note that these types of Integrity or subject interviews have been authorized under the Treasury Board of Canada Secretariat’s Policy on Government Security, Personnel Security Standard since 2002.

Additional verifications may be administered to assess an individual’s integrity at time of application, when adverse information has been uncovered concerning an individual or when a review for cause investigation is launched based on adverse information that may affect an existing employee’s security screening level. 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.

Personnel Security Screening decisions based on the 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. However, the personal information itself will not be shared. 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 the previously submitted Annex 3 - Annex E of the HIPSSS Standard Operating Procedures.

Anyone requiring a CBSA security screening will be screened through the HIPSSS. This includes all CBSA employees (permanent, term, casual and part-time), contract and private agency personnel, and individuals seconded or assigned to CBSA (including students). Security screening requirements are identified as a condition of employment or an agreement (i.e. written collaborative arrangement or agreement).

In addition to the baseline verifications of employment history, credit and criminal record checks that are currently being conducted, individuals who are not employees and individuals who are being considered for employment with the CBSA will also undergo the following verifications:

  • Law Enforcement Record Checks
  • Internal data base checks
  • Integrity interviews
  • Other checks may be undertaken for cause on a case-by-case basis.

All individuals, upon renewal or upgrade to their CBSA security screenings, will undergo the following verifications:

  • Law Enforcement Record Checks
  • Internal data base checks
  • Integrity interviews (for cause)
  • Other checks may be undertaken for cause on a case by case basis.

In addition, all armed officers who do not hold a valid Possession and Acquisition Licence (PAL), or who have not yet been screened through the HIPSSS, will be screened through the HIPSSS in advance of their normal renewal cycle.

[2] Adverse Information is information that can reasonably be cause to believe that the individual may steal valuables, exploit assets and information for personal gain, fail to safeguard information and assets entrusted to him or her, or exhibit behaviour that would reflect negatively on their reliability.