Assessment, Benefit and Service Branch
Benefit Programs Directorate

On this page

• Overview & Privacy Impact Assessment Initiation (PIA)
• Summary of the project, initiative or change
• Risk identification and categorization

Overview & Privacy Impact Assessment (PIA) Initiation

Government institution

Canada Revenue Agency

Government official responsible for the PIA

Melanie Serjak
Assistant Commissioner
Assessment, Benefit, and Service Branchh

Head of the government institution or Delegate for section 10 of the Privacy Act

Anne Marie Laurin
Director General
Access to Information and Privacy Directorate

Name of program or activity of the government institution

Benefits

We deliver a range of ongoing benefits, credits, and one-time payment programs that support the economic and social well-being of Canadians. Through processing activities, we make sure that Canadians receive their rightful benefits in a timely manner. We offer benefit recipients timely and accessible information on their entitlements and obligations both through our call centres and securely online, which helps Canadians become more aware of the benefits they are entitled to and how to receive them.

Standard or institution specific class of record:

Benefit Programs - Children's Special Allowances (CSA) Program
CRA ABSB 625

Standard or institution specific personal information bank:

Children’s Special Allowances
CRA PPU 620
TBS Registration Number: 20150218

Legal authority for program or activity

The legal authority for the children's special allowances (CSA) program is governed in the Children's Special Allowances (CSA) Act and the Children's Special Allowances Regulations.

Information is collected pursuant to paragraph 4(1)(a) of the CSA Act and the specific data elements are listed in subsection 3(1) of the CSA Regulations. Subsection 10(2) of the CSA Act provides that CSA information can be used for the administration and enforcement of the ITA.

Paragraph 10(2)(b) of the CSA Act provides for the authority to release information to Employment and Social Development Canada (ESDC) for the administration of the one-time payment of the persons with disabilities payment.

Section 11 of the CSA Act provides the CRA with the authority to enter into an agreement with a province for the release of information and section 7 of the CSA Regulations lists the conditions for the release of that information. The Canada child benefit young child supplement (CCBYCS) equivalent (CCBYCSE) benefit payment was issued under amendments to section 8 of the Children’s Special Allowances Act.

The COVID-19 Emergency Response Act authorized a supplementary payment to recipients in May 2020.

Section 61 of the Canada Revenue Agency Act allows the CRA to implement agreements with other federal, provincial and territorial governments for the purpose of carrying out an activity or program administered by the CRA.

The legal authority to collect the SIN is under subsection 220(1) of the ITA. The social insurance number is required for the administration and enforcement of the ITA. Specifically, subsection 122.62(4). The social insurance number is used to determine if another individual is receiving Canada child benefits for the child now under the care of the registered agency claiming the CSA.

Summary of the project, initiative or change

Overview of the Program or Activity

Children’s special allowances

The CSA is a tax-free monthly payment for a child who:

• is under the age of 18;
• physically resides in Canada; and
• is maintained by a registered agency.

By "agency," the CRA means:

• a federal, provincial or territorial government department, an agency appointed by a province or territory to administer a provincial or territorial law for the protection and care of children, a group foster home or institution;
• an institution licensed or otherwise approved by a province or territory to have the custody and care of children; or
• the Indigenous governing body, a department or agency of the Indigenous governing body, or an agency appointed by the Indigenous governing body, including an authority established under the laws of the Indigenous governing body, or by an agency appointed by such an authority, for the purpose of administering any law of the Indigenous governing body for the protection and care of children.

A child is considered to be cared for by an agency (federal or provincial department, agency or institution approved by a province, territory or Indigenous governing body to have custody or care of the children) if, at the end of the month, the child is dependent on it for his or her care, maintenance, education, training, and advancement to a greater extent than any other agency or individual.

Prior to July 2016, the monthly CSA payment was equal to the maximum Canada child tax benefit (CCTB) payment plus the national child benefit supplement (NCBS). It also included a supplement amount for the child disability benefit (CDB), and the universal child care benefit (UCCB) if applicable.

As of July 2016 (2015 benefit year) the federal government enhanced the CCTB to the Canada child benefit program. This replaced the Canada child tax benefit, national child benefit supplement, and the universal child care benefit.

However, for the July 2016 to June 2018 period, the CRA continued to support the national child benefit supplement initiative and calculate an equivalent amount within the Canada child benefit.

As of July 2017 (2016 benefit year), the monthly CSA payment for each child is equal to the maximum basic amount of the Canada child benefit (CCB) for children under 6, and for children aged 6 through 17, plus it may also include a supplement amount for the child disability benefit (CDB). The monthly amount of the CSA benefit is adjusted yearly, based on the indexation rate for personal income tax amounts as announced by the Department of Finance, beginning with the July payment.

To be eligible to receive the CSA, an agency must first register with the CRA and obtain a registered account business number. The process to create and administer a business number is not within the scope of this PIA.

The registered agency must then submit an RC64 Children's Special Allowances application for each child for whom it maintains care of.

Applications may be received electronically using an electronic file transfer, secure web application, or paper format.

What’s New

This PIA was updated to include Covid 19 pandemic relief measures impacting the children’s special allowances program.

Disclosure to Employment and Social Development Canada (ESDC)

The transfer of Children’s Special Allowances data to Employment and Social Development Canada (ESDC) for the administration of the one-time payment of the persons with disabilities payment was established in 2020. This was a one-time payment in recognition of the extraordinary expenses incurred by persons with disabilities during the COVID-19 pandemic. Children under 18 under the care and guardianship of an agency with a valid Disability Tax Credit Certificate for the 2020 tax year were eligible for a payment up to $600. Payments were issued to the agency on behalf of the eligible child(ren).

Canada child benefit young child supplement (CCBYCS) equivalent (CCBYCSE) benefit

The children’s special allowances (CSA) – Canada child benefit young child supplement (CCBYCS) equivalent (CCBYCSE) benefit was introduced in May 2021 as part of Canada’s Building Back Better pandemic recovery benefits. No new application was required for this new payment. Agencies that received the children’s special allowances (CSA) were entitled to an additional CSA payment of $300 for each child under the age of six eligible for the CSA in January 2021, April 2021, July 2021, and October 2021. The first payment for the CCBYCSE was issued in May 2021 and included the January and April quarterly entitlement amounts. These payments were issued as stand-alone payments separately from the CSA payments.

May 2020 supplement payment

On March 25, 2020, as part of the COVID-19 Emergency Response Act, the government increased the maximum annual payment for the 2019–2020 benefit year, by $300 per child. The regular May 2020 CSA eligibility period included a $300 supplement per child (under 18 years of age).

Scope of the Privacy Impact Assessment

The scope of this privacy impact assessment is the administration of the children’s special allowances program, including potential compliance activities for enforcement purposes such as detecting fraud or investigating possible abuses within the CSA program.

Certain compliance activities such as audits and criminal investigations are separate programs and therefore are not included within the scope of this PIA. In addition, the application process to determine if a child is eligible for the disability tax credit is not included in this PIA.

The calculation, enforcement, and administration of Canada child benefits—not limited to the CCB, the national child benefit supplement (NCBS), the child disability benefit (CDB), the universal child care benefit (UCCB) and the goods and services tax credits (GSTC)—are not included in this PIA.

Programs and initiatives that focus on child benefits and credits are constantly changing. Therefore, when a new initiative or a change to an existing benefit is identified, this PIA will be reviewed and updated accordingly.

Risk identification and categorization

A) Type of program or activity

Compliance / Regulatory investigations and enforcement

Level of risk to privacy: 3

Details:

CSA Agency is defined as a federal or provincial department, agency or institution approved by a province or territory to have custody or care of children. As these Agencies are either part of or approved by a government body, the non-compliance risk has been determined to be extremely low. Notwithstanding, information could also be used for the validation of the benefits, and to determine whether an Agency knowingly participated in or made a false statement or omission. The consequences could result in the termination and/or recoup of benefits, and possibly levying civil penalties under section 163(2) of the Income Tax Act.

B) Type of personal information involved and context

Social insurance number, medical, financial or other sensitive personal information and/or the context surrounding the personal information is sensitive. Personal information of minors or incompetent individuals or involving a representative acting on behalf of the individual.

Level of risk to privacy: 3

Details:

Personal information on minors is collected and used to identify dependants (minors) and administer CSA payments.

Information is also collected on previous caregivers and foster parents.

C) Program or activity partners and private sector involvement

Private sector organizations or international organizations or foreign governments

Level of risk to privacy: 4

Details:

The program includes the administration of benefit programs to registered agencies that maintain minors. Aggregated information is disclosed by the CRA to Public Services and Procurement Canada for the issuance of payments.

CRA provides information on children in the care of Employment and Social Development Canada in support of the Canada Education Savings Program and Learning Bond. Information on children in care eligible for the disability supplement was shared with ESDC for the administration of the one-time payment of the persons with disabilities payment.

The information is also used internally within the CRA for the administration of benefits accounts and collection of outstanding balances, audit activities, appeals, statistical gathering, and contact centre enquiry responses.

Records containing personal information are stored by a third party in the private sector.

D) Duration of the program or activity

Long-term program

Level of risk to privacy: 3

Details:

The Children’s Special Allowances is a long-term program with no established end date.

E) Program population

The program affects certain individuals for external administrative purposes.

Level of risk to privacy: 3

Details:

The program affects individuals under the age of 18 who are maintained by a registered agency within Canada.

F) Technology & privacy

1. Does the new or modified program or activity involve the implementation of a new electronic system, software or application program including collaborative software (or groupware) that is implemented to support the program or activity in terms of the creation, collection or handling of personal information?
   
   Risk to privacy: No
2. Does the new or modified program or activity require any modifications to IT legacy systems and/or services?
   
   Risk to privacy: Yes
3. Does the new or modified program or activity involve the implementation of one or more of the following technologies?

Enhanced identification methods - this includes biometric technology (i.e. facial recognition, gait analysis, iris scan, fingerprint analysis, voice print, radio frequency identification (RFID), etc.) as well as easy pass technology, new identification cards including magnetic stripe cards, "smart cards" (i.e. identification cards that are embedded with either an antenna or a contact pad that is connected to a microprocessor and a memory chip or only a memory chip with non-programmable logic).

Risk to privacy: No

Use of Surveillance - this includes surveillance technologies such as audio/video recording devices, thermal imaging, recognition devices, RFID, surreptitious surveillance/interception, computer aided monitoring including audit trails, satellite surveillance etc.

Risk to privacy: No

Use of automated personal information analysis, personal information matching and knowledge discovery techniques - for the purposes of the Directive on PIA, government institutions are to identify those activities that involve the use of automated technology to analyze, create, compare, identify or extract personal information elements. Such activities would include personal information matching, record linkage, personal information mining, personal information comparison, knowledge discovery, information filtering or analysis. Such activities involve some form of artificial intelligence and/or machine learning to uncover knowledge (intelligence), trends/patterns or to predict behavior.

Risk to privacy: Yes

G) Personal information transmission

The personal information is transmitted using wireless technologies.

Level of risk to privacy: 4

Details:

Personal information can be used in a system that has access to other systems and can be transferred to a secure portable device using CRA-approved encryption technologies as required.

Portable devices:

Some employees’ workstations include CRA-issued laptops in docking stations. Laptops comply to the Security requirements of the Computing Environment Policy with encryption and access control. Any telework is carried out through Secure Remote Access (SRA).

In contingency situations, any removable media used must be issued by the CRA and formatted with encryption technology specific to the user.

Reconciliation Notices containing personal child details are sent electronically and via traditional mail each month to the registered agencies.

H) Potential risk that in the event of a privacy breach, there will be an impact on the individual or employee

Details:

If the personal information was compromised, it has the potential to cause embarrassment to the affected individual. The affected individual may also become a victim of identity theft, and their information may be used without their knowledge or consent.