Police Transition
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Overview and privacy impact assessment initiation
- Government institution
- Royal Canadian Mounted Police
- Head of the government institution or delegate for section 10 of the Privacy Act
- Danielle Golden
Director of Privacy
Access to Information and Privacy Branch - Senior official or executive responsible for the privacy impact assessment
- Alison Whelan
Senior Assistant Deputy Minister Reform, Accountability and Culture Sector - Name and description of the program or activity of the government institution
- Contract Policing - Police Transitions
- Legal authority for the program or activity
- Royal Canadian Mounted Police Act
Section 8(2)(a) and Section 8(2)(f) of the Privacy Act - Standard or institution specific personal information bank
- Operational Case Records: RCMP PPU 005
Victim Services: RCMP PPU 139
Forensic Science and Identification Services and Canadian Criminal Real Time Identification Services: RCMP PPU 030
Description of the project, initiative or change
The Royal Canadian Mounted Police (RCMP) provides contract policing services to the three territories and eight provinces, as well as 150 municipalities and First Nations communities, under 20-year Police Service Agreements.
The current agreements are all set to expire on March 31, 2032. The agreements contain provisions that permit either party to terminate the policing contract on March 31 of any calendar year, provided sufficient notice of 24 months is provided; and allow for changes to geographic boundaries with one-year notice. Parties to these agreements include the Government of Canada, and either a province, territory, or municipality. As part of these agreements, parties also agree to cooperate and assist each other to affect an orderly transition of service from the RCMP to such other police services authorized by the Province or Territory to carry out the policing powers and duties.
In recent years, a number of municipal jurisdictions have indicated their intention to end their police service agreements with the Government of Canada and establish new municipal police services, namely the City of Surrey, British Columbia and the City of Grande Prairie, Alberta. In other jurisdictions geographic boundary changes are shifting the jurisdiction of the RCMP, for example, a change in policing boundaries in Newfoundland and Labrador, and boundary and population changes driven by municipal reforms in New Brunswick, resulting in a transition of specific geographical areas to other established provincial or municipal police services.
In the context of a transition of policing services from the RCMP to another police service, responsibility and accountability for policing and investigations shifts from the RCMP to the other police service, and along with it the police files associated with open investigations along with all evidence collected. The transfer of open police files involves the disclosure of the personal information and exhibits contained therein. This personal information falls into several personal information banks, such as operational case records, victim services, national sex offender registry, Forensic Science and Identification Services and Canadian Criminal Real Time Identification Services; however, in the context of this initiative, only open and relevant RCMP operational files will be handed over to the new police of jurisdiction, limiting the disclosure of personal information to the extent possible.
The objective of this activity is facilitate the transition of policing services from the RCMP to another police service in a manner that protects the continuity of police operations while ensuring police officer and public safety, all the while respecting both provincial jurisdiction for policing and the legislative and operational frameworks within which the RCMP operates.
Purpose and scope of the privacy impact assessment
The objective of the privacy impact assessment is to ensure that the RCMP meets its legal obligations under the Privacy Act in relation to its disclosure of personal information during a transition, and to ensure that privacy risks associated with any disclosures are appropriately mitigated.
Privacy analysis
Based on its assessment, privacy impacts associated to policing transitions are expected to be moderate. Recommendations from the privacy impact assessment processed, once fully adopted are expected to reduce those risk to an acceptable level of risk. Potential impacts on the privacy of individuals are managed by the RCMP through appropriate legal, policy and technical measures geared at the protection of personal information and prevention of potential breaches.
Risk area identification and categorization
A) Type of Program or Activity
Personal information is used for investigations and enforcement in a criminal context (for example, decisions may lead to criminal charges/sanctions or deportation for reasons of national security or criminal enforcement).
Level of risk to privacy: Elevated risk
B) Type of Personal Information Involved and Context
Sensitive personal information, including detailed profiles, allegations or suspicions and bodily samples, or the context surrounding the personal information is particularly sensitive.
Level of risk to privacy: Elevated risk
C) Program or Activity Partners
With other institutions or a combination of federal, provincial or territorial, and municipal governments.
Level of risk to privacy: Moderate risk
D) Program duration
Each transition represents a one-time, short-term activity.
Level of risk to privacy: Moderate risk
E) Program population
The program's use of personal information for external administrative purposes affects certain individuals.
Level of risk to privacy: Moderate risk
F) Technology and Privacy
- Does the new or substantially modified program or activity involve implementation of a new electronic system or the use of a new application or software, including collaborative software (or groupware), to support the program or activity in terms of the creation, collection or handling of personal information?
- Risk to privacy: No
- Does the new or substantially modified program or activity require any modifications to information technology legacy systems?
- Risk to privacy: No
- Does the new or substantially modified program or activity involve implementation of new technologies or one or more of the following activities:
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- Enhanced identification methods;
- Risk to privacy: No
- Surveillance;
- Risk to privacy: No
- Automated personal information analysis, personal information matching and knowledge discovery techniques?
- Risk to privacy: No
Level of risk to privacy: Low risk
G) Personal Information Transmission
All files to be transferred will be done through methods that comply with the RCMP security policies.
Further, the information will be stored in the receiving another police service's Records Management System that is complaint with RCMP process that governs how RCMP shares policing data with other agencies.
Level of risk to privacy: Moderate risk
H) Potential risk that in the event of a privacy breach, there will be an impact on the individual or employee
While the risk of a breach is minimal given the security measures put in place by the RCMP, given the nature of the information contained in open police files, it is likely that an individual named in an open police investigation may face reputational harm, embarrassment as well as financial harm and potential physical harm given the links to criminal activity.
The RCMP recognizes the need to maintain the integrity of data, not only for continuity and investigative purposes, but also to minimize the potential impacts to an individual's privacy. To that end, all RCMP handlers of this information are provided with training on the basic principles of the Privacy Act and the need to properly protect personal information from unauthorized disclosure. Similarly, the receiving police service will have an equivalent responsibility to protect personal information under provincial/territorial legislation – minimizing the risk of privacy breaches. The other police service's processes for the handling of personal information in line with their respective provincial legislation will be outlined in a Memorandum of Understanding with the RCMP prior to the handover of operational files.
Level of risk to privacy: Moderate risk
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