OPC on Privacy Impact Assessments

In March, Stuart Bloomfield of the Office of the Privacy Commissioner of Canada gave a good speech about privacy impact assessments to the "Managing Government information" forum in Ottawa. I didn't link to it when I first came across it, but I thought I'd highlight it today because it's a good read for those who are interested in PIAs or are evangelists about the risk-management benefits of conducting privacy impact assessments before significant projects. Here is an extract from the speech:

Speech: Managing Government Information 2nd Annual Forum - March 10, 2004 - Office of the Privacy Commissioner of Canada - Privacy Commissioner of Canada:

"In sum, PIAs perform the following roles:

1. They act as an early warning and planning tool;
2. They forecast and/or confirm the impacts of a government proposal on the privacy of individuals and groups;
3. They provide a mechanism to assess a proposal's compliance with privacy protection legislation and principles; and
4. They provide a framework for the development and implementation of actions and strategies required to avoid or overcome the negative impacts of the proposal on privacy.

In conducting a PIA and acting upon the advice advanced therein, government departments can:

1. Avoid adverse publicity, the loss of credibility and public confidence and the legal costs, remedies and sanctions that could result from negative impacts; and
2. Increase Canadians' privacy awareness and confidence with the government's handling of their personal information by informing them of the details of the proposal.

The potential costs to departments by not conducting a PIA where one is required should not be underestimated. One need only recall the highly publicized debacle over HRDC's Longitudinal Labour Force File (LLF) whose subsequent dismantlement following public complaints against the database cost the department millions of dollars. Arguably had a PIA been done on the LLF prior to implementation, HRDC could have avoided the adverse publicity and financial losses that it suffered as a result of this incident."