June 30, 2020

Canadian Alliance of Student Associations // Alliance canadienne des associations étudiantes

Daniel Therrien
Privacy Commissioner of Canada
Office of the Privacy Commissioner of Canada 30 Victoria Street
Gatineau, QC
K1A 1H3

Re: Privacy concerns regarding the outsourcing of Canada Student Service Grant administration

Mr. Therrien,

It is with grave concern for the safety and privacy of students’ personal information that we write asking you to investigate the implementation of the Canada Student Service Grant through an outsourced party.

The Canada Student Service Grant program as announced on June 25, 2020 involves a platform that is detailed to be funded by Employment and Social Development Canada. This platform is designed to connect students with volunteer opportunities that would then render the student eligible for a one-time grant of up to $5,000.00, commensurate with their service.

However, for students to register, they are required to supply personal information to a website that is neither housed nor administered by Employment and Social Development Canada. This information includes, but is not limited to their age, education status, email address, civic address, name of the individual in conjunction with additional personal information. In essence, there is tremendous data on thousands of young Canadians being collected by a third-party in the auspices of a government initiative. It is worth noting, that the initial search for opportunities can begin on canada.ca/iwanttohelp, but students are then routed to iwanttohelp.org (a third-party site) to register. We are concerned about the privacy implications of this data use and collection.

Furthermore, we have many concerns about the security and privacy of this data and humbly request that you investigate the safety and security of students’ personal information within this program at your earliest opportunity. Specifically, we have the following concerns:

  • Who owns and stores, and thus is responsible for, data submitted by students to register for a volunteer placement under the Canada Student Service Grant program?

  • Will this data, its use, and its storage be held to the standards as prescribed in the Privacy Act?

  • Will the information submitted be subject to Canada’s Anti-Spam Legislation, or is registration deemed to be

    ‘expressed consent’?

  • If students’ data is to be held by the third-party, is it thus subsequently able to be accessed and acquired by other entities?

This program is bringing many questions at this juncture. At the Canadian Alliance of Student Associations, student safety is paramount, and we hope that you will be able to investigate the privacy considerations of the third-party administration of the Canada Student Service Grant to ensure safeguarding of students’ data and privacy.

Should you have any questions, or require further clarification, please do not hesitate to let us know. Sincerely,

Kalin McCluskey
Executive Director
Canadian Alliance of Student Associations

 

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The Canadian Alliance of Student Associations advocates for better post-secondary education and aims to improve the lives of students. L'Alliance canadienne des associations étudiantes défend les intérêts des étudiant(e)s.
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Privacy concerns regarding the outsourcing of Canada Student Service Grant administration
Privacy concerns regarding the outsourcing of Canada Student Service Grant administration
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