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Overarching Privacy Impact Assessment (PIA)
The Assisted Voluntary Return and Reintegration (AVRR) Pilot Program was implemented by the Canada Border Services Agency (CBSA) in the Greater Toronto Area Region from June 29, 2012 to March 31, 2015. The pilot was intended to support the Removals Program by providing a mechanism to facilitate the voluntary removal of failed refugee claimants to their country of origin by:
- Providing added incentives and a clear framework for failed refugee claimants to leave Canada voluntarily within a shorter timeframe, and;
- Alleviating pressure on CBSA's regular removals program by working with an independent service partner to facilitate low-risk removals.
The International Organization for Migration (IOM), an intergovernmental organization, delivered the pilot on behalf of the CBSA.
The exchange of information received between the CBSA and the IOM had few privacy implications, mainly due to the limited nature of the information exchanged; the method by which the information was provided; and the voluntary nature of the pilot.
The collection of personal client information by the IOM had some privacy implications. This was mitigated through the voluntary nature of the program as consent from individuals was obtained before any information was disclosed, and through strict measures incorporated into the Memorandum of Understanding (MOU) between the CBSA and the IOM to administer the program. These measures governed the collection, sharing, retention and disposal of the personal information of applicants. Furthermore, the IOM was required to obtain the consent of the individual before disclosing any personal information to a third party.
With the exception of specific IT functionality developed to identify AVRR participants, there was minimal change to the information entered into CBSA's business systems. Based on a Statement of Sensitivity conducted for the National Case Management System, much of the data collected and stored was assessed as unclassified. The most significant change, from a technology perspective, was the collection of information by the IOM that was housed in their internal database. For due diligence, the CBSA ensured that the IOM implemented reasonable administrative, physical and technical security and safeguarding measures and solutions to govern the collection, use, retention and disposal of personal client information.
Protecting your Personal Information
Personal information was managed by the CBSA's Removals Program for the purposes of program administration: to determine eligibility, to record (AVRR) program participation, report and monitor, and to complete an application for a travel document (as required). The IOM collected personal information directly from the participant – with their consent – to administer the program at the operational level: to provide the appropriate level of counselling, make flight arrangements (if applicable), and arrange for in-flight or transit assistance (upon request) and post-departure re-integration assistance delivered by local service providers in the applicant's country of origin/destination country.
Right of Access
You may formally request access to your personal information, or access to corporate records related to or created by the Removals Program by contacting the Access to Information and Privacy Division. More information about this can be found on the Access to Information and Privacy page.
If you have concerns about the collection, use, disclosure or retention of your personal information, you may issue a complaint to the CBSA Access to Information and Privacy Division. Complaints should be made in writing, and include your name, contact information, and a brief description of your concerns. Contact the Access to Information and Privacy Division at the CBSA.
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