A Preliminary Privacy Impact Assessment (PPIA) was developed as per the request of the Access to Information and Privacy Protection Division (DCP) to review and assess privacy compliance and identify possible risks associated with the International Academic Relations Program’s international scholarships, which are administered by the Canadian Bureau for International Education (CBIE). Since no previous privacy assessments have been conducted on these activities, the International Education and Youth Division of the Public Diplomacy Bureau has embarked on a preliminary review and assessment using the department’s Privacy Assessment Tool. The Division has reviewed the privacy tutorials offered as part of the tool as well as completed the answers to the Preliminary Privacy Examination Questionnaire that is part of the Privacy Assessment Tool. This document is considered a PPIA of these activities. It examines potential privacy risks and offers mitigation strategies for the risks identified.
The Government of Canada’s Academic Relations Program’s international scholarships are managed by the Department of Foreign Affairs and International Trade. The program’s objective is to promote Canadian values and identity around the world, in order to strengthen Canada’s international relations. Through its international scholarships activities, which include scholarships for Canadians by foreign governments (Canada-China Scholars Exchange Program, Commonwealth Scholarship Plan, Foreign Government Awards, Organization of American States (OAS) Fellowships Programs) and scholarships for non-Canadians by the Government of Canada (Canada China Scholars’ Exchange Program, Commonwealth Scholarship Plan, Government of Canada Awards), DFAIT creates friends of Canada who could hold positions of authority in their respective countries, reinforcing Canada’s international ties and influence. In developing countries, these scholarships are designed to contribute to the development of human capital. The Commonwealth Scholarships, which were among the first international scholarships to be established, were initiated in 1959, when Commonwealth countries, led by Canada, set up a scholarship plan to strengthen the links between them and to encourage higher education. Canada is the largest contributor of Commonwealth scholarships after the United Kingdom.
The Canadian Bureau for International Education (CBJE) is currently under contract with the Department of Foreign Affairs and International Trade to provide daily administrative services to six programs that are related to scholarships and awards offered to foreign students by DFAIT and scholarships and awards offered to Canadians by foreign governments, the Organization of American States (OAS), and other bilateral arrangements. Approximately $6 million are transferred annually to the Contractor to provide scholarships and awards for between 250 and 325 foreign students from approximately 60 different countries.
The Canadian Bureau for International Education (CBIE) is an umbrella non-governmental organization comprised of 200 colleges, universities, schools, school boards, educational organizations and businesses across Canada. Nationally, CBIE engages in policy development, research, advocacy and public information. CBIE manages vital services for foreign students in Canada. Internationally, CBIE engages in cooperative projects in capacity building, institutional strengthening and human resource development. CBIE focusses on education at all levels, specialized training programs, civil society and public administration. CBIE works in partnership with educational institutions, community-based organizations and governments in Africa, the Middle East, Asia, the Americas, the Former Soviet Union, and Central and Eastern Europe.
Foreign students accepted for scholarships must satisfy the Department of Citizenship and Immigration (CIC) requirements for entry to Canada. The Department of Foreign Affairs and International Trade does not communicate any personal information to CIC. The CIC process is a standalone process designed for foreign students. Through an approved agreement, DFAIT does however, communicate the personal information of the students to a private health insurance company As part of their conditions of entry, students must have access to Canadian health services that are offered through private insurance and paid for by the scholarship fund. Consequently, the personal information of the students is disclosed to the Cowan Insurance Group (CIG).
The management of the funds and the process has been contracted out to a non-profit organization in Canada. This risk is identified as low. To mitigate this risk, all steps have been taken to ensure personal information protection. The students and scholars are assigned a liaison or contact person for their duration of their stay in Canada.
The personal information of the scholars and students is communicated with a designated health insurance company. This risk is identified as low. To mitigate this risk, foreign students are required to have proper health insurance in Canada. DFAIT/ Government of Canada has arranged agreements with a designated insurance company to offer health insurance while the foreign students are in Canada.
Canadian scholars and students provide their personal information on their application. This personal information needs to be communicated to foreign government and academic institutions for selection and admission purposes.
This risk is identified as low. To mitigate this risk, DFAIT is looking to institute alternate procedures in which DFAIT is not a party to the scholarship awards by foreign governments or to organize arrangements to protect and govern personal information disclosed.
As a result of the PPIA conducted using DFAIT’s Privacy Assessment Tool’s questionnaire, DFAIT’s International Education and Youth Division, Public Diplomacy Bureau, has determined that there is no requirement to undertake a full Privacy Impact Assessment at this time. The three low level risks identified have been mitigated and addressed by CBIE The department will assess and review privacy requirements associate with the service regularly to ensure all privacy issues and concerns are addressed.