Administration of the Privacy Act Annual Report
April 1, 2022 to March 31, 2023

Introduction

This report is prepared in accordance with section 72 of the Privacy Act and is tabled in Parliament by the Minister of Health in accordance with the aforementioned section. It describes how the Canadian Institutes of Health Research (CIHR) fulfilled its responsibilities under the Act during the fiscal year beginning April 1, 2022 and ending March 31, 2023.

The Privacy Act provides citizens with the legislated right to access personal information held by the government, subject to certain limitations and specific exemptions, and protection of that information against unauthorized use and disclosure

CIHR was created in 2000 under the authority of the CIHR Act as the Government of Canada’s health research investment agency. The mandate of CIHR as stated in the Act is:

To excel, according to internationally accepted standards of scientific excellence, in the creation of new knowledge and its translation into improved health for Canadians, more effective health services and products and a strengthened Canadian health care system.

CIHR is the largest funder of health research in Canada. Composed of 13 “virtual” institutes and three business portfolios, CIHR provides leadership and support to over 15,000 world-class researchers and trainees from all pillars of health research and from all regions of Canada.

Organizational Structure

CIHR is led by a President and a Governing Council comprised of up to 18 members appointed by Order-in-Council. The Governing Council sets the overall strategic direction and goals. It establishes, maintains and terminates Health Research Institutes and determines the mandate of each. As outlined in the legislation, the Governing Council is responsible for developing its strategic direction and goals; evaluating its performance, approving its budget; establishing a peer review process for research proposals submitted to CIHR; approving funding for research; approving other expenditures to carry out its objective; establishing policies; and dealing with any other matter that the Governing Council considers related to the affairs of CIHR.

The Access to Information and Privacy (ATIP) Office, part of the CIHR’s Strategic Policy Division, administers the provisions of the Access to Information Act and the Privacy Act for the CIHR and is accountable to the President of CIHR. The ATIP Compliance Office, which is comprised of one Senior ATIP Coordinator, one Senior ATIP Analyst and one Junior ATIP Officer. In addition, in 2022-2023, CIHR engaged the services of one consultant. The ATIP Office is responsible for the following activities:

CIHR was not party to any service agreements under section 73.1 of the Privacy Act during the 2022-2023 reporting period.

Delegation of Authority

The President of CIHR, as designated Head of CIHR under the Access to Information Act, exercises powers entrusted to the position by the Act, such as exemptions and exclusions.

In accordance with his authority under Section 73, the President has designated the Executive Vice-President; the Associate Vice-President, Government and External Relations; the Director General, Strategic Policy; the Senior Access to Information and Privacy (ATIP) Coordinator, the Senior ATIP Analyst and the Junior ATIP Officer to exercise his powers, duties or functions under the Act (See Appendix A - Delegation Order).

Highlights of the Statistical Report 2022-2023

CIHR collects and manages a great deal of personal information to adjudicate thousands of research grant and scholarship proposals, making merit-based awards based on peer review.

a. Formal Requests

During the April 1, 2022 to March 31, 2023 reporting period, CIHR received five requests under the Privacy Act. Four requests were closed during the fiscal year and one request was carried over to the next fiscal year. Of the 4 requests completed, 3 were completed within the first 30 days of reception and 1 request was completed within 61-120 days. One request was disclosed in full, one request was disclosed in part and two requests resulted in no records. (See Appendix B - Statistical Report). A total of 848 pages were processed and 657 pages were disclosed in 2022-2023. During this period, 75% of the requests (3) were processed within the legislated time limit. The one request that was not closed within legislated timelines was due to workload.

The number of requests received over the past five years has fluctuated between zero and sixteen. Although the number of requests received in 2022-2023 is not large, the complexity of the files was significant.

b. Informal Requests

In 2022-2023, CIHR responded to more than 40 informal requests, all of which were received internally by CIHR employees. CIHR did not receive any informal requests from external sources.

Over the past five years, there has been a consistent increase in the volume of internal informal requests that have been made. All of the informal requests received during the 2021-2022 reporting year came from business units related to the review of corporate documents and interpretation of the Privacy Act, primarily related to program and service delivery. These requests are not reflected in the statistical report in Appendix B.

c. Requests for Correction of Personal Information

During the 2022-2023 reporting period, CIHR did not receive any requests for correction of personal information.

d. Consultations

During the 2022-2023 reporting period, the CIHR Access to Information and Privacy Office did not receive any consultation requests from external sources.

CIHR managers and staff sought and obtained advice from the ATIP Coordinator on a regular basis for matters where there were privacy considerations in their programs or activities. In 2023-2023, CIHR contributed to the review and development of many new privacy notices. In depth and ongoing reviews of corporate practices were conducted with significant support and input from the Access to Information and Privacy office.

e. Costs

During 2022-2023, the Access to Information and Privacy Office incurred $145,750 in salary costs to administer the Privacy Act. Owing to the difficulty of tracking all of the operational costs related to the administration of the Act, the costs and human resource statistics are conservative estimates. Almost all costs are attributable to salary, and include fractions of the salaries of the directors, managers and employees who participated in work related to the Act.

Training Activites

During the 2022-2023 fiscal year, ATIP related training was provided on request to staff at all levels through eight customized sessions. While most of these information sessions focused on privacy, there were nevertheless key concepts related to access to information and information management that were covered as well. These sessions were presented with a goal to enhance the knowledge, skills and perspectives of all employees, concerning Access to Information and Privacy. The CIHR ATIP Office continues to develop educational tools and deliver training sessions to CIHR staff. This has been identified as a key priority for 2023-2024.

Policies, Guidelines and Procedures

While there were no significant revisions to current access to information policies, guidelines or procedures, CIHR dedicated time to reviewing efficiencies in the collection use and disclosure of personal information processes.

Initiatives and Projects to Improve Privacy

As part of a broader process led by TBS, CIHR is in the process of securing a new Request Processing Software Solution (RPSS). The options currently being explored will offer significant improvement and automation to the processing of requests. In addition to a new RPSS, the CIHR ATIP Office obtained new software for the purpose of providing response packages to requestors in accessible formats, particularly those relying on screen readers.

During the 2022-2023 fiscal year, CIHR allocated resources to secure consulting services. These services were utilized to process ATIP requests received by CIHR and have proven to be an effective method during periods of high volume.

Complaints and Investigations

CIHR received one privacy complaints during the reporting period. The complaint was carried over to the 2023-2024 fiscal year.

Material Privacy Breaches

No material privacy breaches occurred during the reporting period.

Privacy Impact Assessments

In 2022-2023, CIHR did not conduct any Privacy Impact Assessments (PIAs).

Public Interest Disclosures

CIHR did not make any public interest disclosures under Subsections 8(2) and 8(5) of the Privacy Act during the reporting period.

Monitoring Process

The ATIP Office monitors the time to process requests and administer the Access to Information Act through weekly verbal status reports and a weekly written status report is provided to the Health Minister’s Office for their information. Any issues of significant interest are discussed with the President and Communications department on an as needed basis.

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