Canadian privacy & access decisions

The Office of the Privacy Commissioner (OPC) investigated three complaints concerning Public Services and Procurement Canada's (PSPC) Phoenix Pay System. Complainants alleged improper disclosure of federal public service employees' personal information, with PSPC being aware of privacy issues before the system's launch. The OPC's investigation revealed at least 11 breaches, more extensive than initially reported by PSPC, involving employee names, Personal Record Identifiers (PRIs), and salary information, with government-wide vulnerabilities. These breaches stemmed from inadequate testing, coding errors, and insufficient system controls. The OPC found that PSPC failed to adequately monitor access to personal information, provide timely and sufficient notification to affected individuals, and fully address known vulnerabilities. Consequently, the OPC found the complaints to be well-founded and issued six recommendations to PSPC, some of which PSPC's proposed actions were deemed inconsistent or insufficient by the OPC.

• Whether personal information was at issue in the reported incidents
• Whether the personal information at issue was improperly disclosed
• What was the scope of the improper disclosure
• Whether the personal information that was improperly disclosed was misused
• Whether PSPC was aware of potential privacy issues with Phoenix before the launch
• What kind of harm could result from the unauthorized disclosure of the personal information at issue
• Whether PSPC resolved all of the vulnerabilities within Phoenix
• Whether PSPC provided individuals with timely information regarding the breaches and vulnerabilities
• Whether PSPC developed and implemented controls to monitor and document access to personal information held in Phoenix (Recommendation 1)
• Whether PSPC developed more robust testing and response procedures (Recommendation 2)
• Whether PSPC conducted necessary assessments to identify potential risks and vulnerabilities in Phoenix (Recommendation 3)
• Whether PSPC took measures to mitigate the increased vulnerability of information used by employees in call centres (Recommendation 4)
• Whether PSPC reviewed its breach notification practices and provided notification of the extent of the Phoenix breaches (Recommendation 5)
• Whether PSPC completed the review of pages with row-level security (Recommendation 6)