The Western Diversification Program(WDP) supports activities that develop and diversify the western Canadian economy and activities where economic and/or employment benefits accrue primarily within Western Canada.
Announced in Budget 2012, the Western Innovative (WINN) Initiative is a $100-million, five-year federal funding initiative that will promote the development and diversification of the western Canadian economy by providing financial support to qualified SMEs. The Initiative aims to:
While the impetus of this Privacy Impact Assessment is the WINN Initiative, the scope of this assessment will cover the broader WDP, of which WINN is a sub-program. There are several other sub-programs or initiatives that utilize the WDP terms and conditions.
As part of the WINN assessment process, WD may conduct personal credit checks if deemed necessary (e.g. where the owner of a company is the only employee). This would involve the collection of personal information that has not been collected to date under the WDP or any of its sub-programs. WD would obtain consent from an individual in order to conduct a personal credit check, along with his/her full legal name, complete home address and date of birth, as well as the individual’s financial history as presented in credit reports obtained via one or more of the credit reporting agencies (e.g. Equifax). A Social Insurance Number is not required for a credit check and will not appear on any credit reports pulled by Western Economic Diversification Canada (WD).
The personal information may only be collected if it is deemed essential for the processing and due diligence required to assess the eligibility and viability of project submissions, and specifically to assess the financial health of applicants, such as when the applicant under consideration is an incorporated company with the owner being the sole employee.
Based on the completion of the Privacy Impact Assessment, the privacy risks associated with the launch of WINN, and the possible future provision of repayable contributions to for-profit entities under WDP, is regarded as low and will require a minor adjustment in the existing administrative process to mitigate against privacy concerns. The department has developed a process by which the information received will be tracked and protected.
This PIA is intended to be evergreen and will be modified as new implementation details, lessons learned, or best practices arise in the future delivery of WINN and WDP programming.
Risk Area Identification and Categorization
|Risk Area||Level of Risk to Privacy
1 (low) to 4 (high)
|Description of Risk|
|A. Type of Program or Activity||2||Personal information is used to make decisions that directly affect the individual.|
|B. Type of Personal Information Involved and Context||3||Financial and/or the context surrounding the personal information is sensitive.|
|C. Program or Activity Partners and Private Sector Involvement||4||Private sector organizations, international organizations or foreign governments.|
|D. Duration of the Program or Activity||2||A program or an activity that supports a short-term goal with an established “sunset” date.|
|E. Program Population||1||The program affects certain employees for internal administrative purposes.|
|F. Technology and Privacy||Yes||Use of automated personal information analysis, personal information matching and knowledge discovery techniques.|
|G. Personal Information Transmission||3||The personal information is transferred to a portable device or is printed.|
|H. Risk Impact to the Institution||4||Reputation harm, embarrassment, loss of credibility.|
|I. Risk Impact to the Individual||3||Financial harm.|