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The CBSA Uniform Program procures unifor. components and equipment, including soft body armour, for CBSA uniforme. employees. Employees acquire uniforms and soft body armour in two separate processes:
- Uniform components and equipment are ordered directly by the employee from Logistik Unicorp Inc. of Saint Jean, Quebec through the vendor's secure web portal. This process is called the Uniform Supply System, or USS.
- Soft body armour is ordered by the CBSA's Uniform Program in Ottawa who receive, review and forward employee sizing information to Pacific Safety Products Inc. (PSP) of Arnprior, Ontario.
USS is scheduled to be implemented in August, 2015, and will support a modernized and optimized supply chain for uniform components and equipment through the efficient warehousing, pro-active inventory management and efficient delivery. The CBSA has been ordering soft body armour from PSP since the early 1990's.
The personal information bank (PIB) associated with the Uniform Program is the Treasury Board of Canada Secretariat (TBS) standard PSE 901 – Employee Personnel Record. The Class of Record Number for the Uniform Program is 2015/008 (Material Management MIDA). The legislative authority for the Uniform Program is found in s. 5(1)(a) of the Canada Border Services Agency Act.
The USS and the Soft Body Armour initiatives are elements of the Uniform Program, which is managed and administered internally by the CBSA. The Uniform Program oversees the provision of uniform components and equipment to approximately 8,000 uniformed employees. The program has managed a national supply chain consisting of 30 multi-year contracts in coordination with the Comptrollership Branch of Public Works and Government Services Canada (PWGSC).
With the implementation of USS, these contracts will end. Logistik Unicorp Inc. will become the sole provider for uniform components, and PSP will become the sole provider of soft body armour as noted aboveFootnote 1.
The USS initiative will collect, use, disclose, retain and dispose of personal information belonging to uniformed staff of the CBSA. Personal information will be collected directly from employees, who will upload it to a secure web portal provided by the vendor, Logistiks Unicorp Inc. of St. Jean, Quebec. Information will include name, address, phone, body measurements, and the existence of any medical conditions requiring the issuance of a specific uniform component, such as a maternity blouse or a shirt designed to go over a medical device. Personal information will also include the employee's Personal Record Identifier (PRI), which will be used by the vendor to associate orders to specific individuals, and by the CBSA to monitor employee use of the program (see section 3 for a complete list of personal information data elements used by the USS program). Employee data will also be provided to the vendor on an encrypted USB periodically so that the vendor can check the employee's input against a pre-populated databaseFootnote 2.
The soft body armour initiative collects body measurements directly from the employee, and other personal information from the Corporate Administrative System (CAS), and sends this data to the vendor Pacific Safety Products (PSP) on an encrypted USB on a periodic basis. Both vendors will use this data to fill and ship the order to the employee's work location, and to maintain the order history of the employee.
Necessary, Effective, Proportionate and Minimal
The personal information collected under this initiative is necessary to ensure that the requested uniform components and soft body armour are tailored to the exact measurements and specifications of the requestor (including allowances for medical devices or physical conditions), and are delivered to the correct individual.
Allowing employees to order uniform components directly from the vendor effectively reduces costs, delays, and overall administrative burdens to the program.
The intrusion on the privacy of uniformed personnel is proportionate to the need of the program, and only those data elements essential to production, delivery and inventory management are collected, used, disclosed and retained by the program.
Potential Privacy Risk and Recommendation
The overall risk to the privacy of employees posed by this program is low. The CBSA has a clearly established legislative authority to administer these two initiatives (para. 5.(1)(a), Canada Border Services Act), and will be publishing a Uniform Program Class of Record Description in its Info Source Chapter. A corresponding Standard Personal Information Bank (PIB) has been identified (Employee Personnel Record PSE 901), and CBSA will ask TBS to update it to reflect these initiatives. Privacy Notification Statements (PNS) will be provided to employees when their personal information is collected, and their consent will be sought as required (see attached). Personal information will only be used by the vendors to fulfill the orders and maintain inventories – there will be no additional sharing of personal information. Personal information will only be transmitted to the vendors in a secure manner, in accordance with para. 16.4.4 of the TBS's Operational Security Standard: Management of Information Technology Security (MITS) . The privacy safeguards employed by both vendors are extensive. Both Logistik and PSP are participants in the government of Canada's Industrial Security program, and have both undergone extensive reviews to ensure they meet the government's strict requirements for the handling of sensitive personal information.
Right of Access
An individual will be informed of the purposes, uses, disclosure and retention of his/her personal information through a Privacy Notice Statement (PNS). Employees ordering uniform components from Logistik will view and accept this PNS in the Terms and Conditions when first logging on to the Portal. Employees ordering soft body armour will be made aware of their right of access in a PNS included on the order form, and will be provided the opportunity to consent, as required, to the use and disclosure of their personal information for the program's purposes.
An individual may formally request access to his/her personal information, or access to corporate records related to or created by uniform component or body armour requisitions by contacting the CBSA Access to Information and Privacy (ATIP) Division. More information about this can be found at: /agency-agence/reports-rapports/pia-efvp/atip-aiprp/menu-eng.html.
Individuals with concerns about this program's collection, use, disclosure or retention of their personal information may contact the CBSA Access to Information Division. Individuals wishing to make a formal complaint concerning their personal information may do so in writing to the Office of the Privacy Commissioner of Canada. More information about this can be found at: /agency-agence/reports-rapports/pia-efvp/atip-aiprp/menu-eng.html. These rights of access and complaint will be provided to the employees at the time their personal data is collected.
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