Executive summary
Mobile Border Privacy Impact Assessment
As part of the Canada Border Service Agency's (CBSA) modernization initiative, a new service channel is being introduced to provide the ability for travellers to present, report goods and appear for an examination using a mobile application to communicate remotely with a border services officer (BSO). The introduction of mobile technology will help the CBSA address increasing difficulties in maintaining the required infrastructure and BSOs in regions with geographical challenges and low staffing levels. Mobile Border will be deployed in a phased approach starting with a soft launch to be tested as a voluntary, alternative option at existing telephone reporting sites in regions that have limited CBSA resources.
It is expected that by providing a more convenient and accessible reporting tool, travellers who do not currently fulfill their obligations when entering Canada will make an effort to be compliant. Mobile Border has the potential to reduce processing times and simplify CBSA procedures by automating routine activities that are currently done manually by BSOs at the TRC (e.g. verbal collection and manual entry of traveller information). Furthermore, it will enable the CBSA to achieve the required identity assurance level for remote primary processing in accordance with the Treasury Board Secretariat's (TBS) Directive on Identity Management.
Following the soft launch the agency will evaluate the results to determine a strategy for future implementation of a mobile application as a nation-wide program and expansion to additional CBSA locations with larger volumes and varying operational models (e.g. airports, buses and cruise ships).
Protecting Personal Information
The following personal information will be collected from travellers using the mobile application and managed by Mobile Border.
Traveller Profile
- Full name
- Gender
- Date of birth
- Citizenship country
- Country, province and postal code of residence
- Identification/travel document (type, number, expiry date, photo and issuing authority)
- Photo of travel document (if traveller does not have a chip-enabled document)
- Trusted Traveller membership information (if applicable)
Entry Declaration
- Method of entry (e.g. air, land, marine, etc.)
- Location of Entry
- Conveyance information
- Facial photo (new real-time photo submitted with each entry declaration)
- Geolocation data from mobile device (captured only when traveller confirms arrival in Canada)
- Cell phone number and/or email address
- Customs declaration
Individuals using the mobile application will be required to create a traveller profile with their identity, citizenship, residency and document information in order to submit an entry declaration to the CBSA. Electronic capture of this data will improve the accuracy of information currently keyed manually by a BSO and reduce the time required to verify and record it in CBSA databases. Information stored in the traveller's profile will be managed and stored by the user on their personal mobile device to be used to simplify and expedite future entry declarations.
When a traveller submits an entry declaration their information will be encrypted and transmitted securely over a cellular or Wi-Fi network to a Protected B certified cloud. The cloud will host a web-based interface that will enable BSOs to manage traveller information and interact with travellers virtually. Information in the cloud will be encrypted and transmitted to CBSA systems over dedicated lines with built-in safeguards and will be automatically risk assessed against data that is held within CBSA enforcement databases.
While Mobile Border introduces a new means of capturing information from travellers, the majority of data is already collected by the CBSA in accordance with subsection 11(1) of the Customs Act. Travellers using the mobile application will be required to provide some additional information elements to facilitate remote primary processing by a BSO including a real-time facial photograph, geolocation, and cellular phone number and email address. These data elements will be used only during processing and will be deleted immediately once complete.
Right of Access
The personal information collected through the mobile application is considered "customs information," as defined under section 107 of the Customs Act. The majority of this information will be retained for the purpose of establishing travel history information in compliance with the Privacy Act, Sections 4, 7 and subsection 8(2).
Travellers using the mobile application will be required to provide their consent for the collection, use, retention and disposition of their personal information by accepting the Terms and Conditions of Use. A Privacy Statement will be presented each time the application is opened to inform travellers what personal information the application will collect and why, where it will be stored, who it will be shared with and why, how long it will be retained, and any other issues that may affect user privacy. New data elements to be captured by the mobile application (photograph, geolocation and contact information) will not be retained in the cloud or CBSA databases. This information will be treated as administrative data, and used only to verify traveller identities and locations and to communicate with them in the event that connectivity does not support the video chat or notification features.
Individuals using Mobile Border may formally request access to their personal information, or access to CBSA records related to or created by the mobile application by contacting the Access to Information and Privacy (ATIP) Division.
Accountability
Individuals with concerns about the collection, use, disclosure or retention of their personal information may submit a complaint to the CBSA ATIP Division. Complaints should be made in writing, and include the individuals name, contact information, and a brief description of their concerns.
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