Privacy Impact Assessment Summary - Immigration Medical Examiners Quality Assurance Information Sharing Memorandum of Understanding

Immigration Medical Examiners (IMEs) play an important role for Citizenship and Immigration Canada (CIC) by conducting the immigration medical examination of applicants for permanent and temporary residency in Canada. CIC’s Health Branch and Australia’s Department of Immigration and Citizenship (DIAC) operate a similar program for the Quality Assurance (QA) of its IMEs. In many instances, Canada and Australia will use the same IME to conduct the immigration medical examination. In order to increase efficiency, CIC and DIAC will be sharing QA information when both use the same IME so that both governments are not conducting QA on the same IME. For the purposes of data sharing, CIC’s Health Branch and DIAC are entering into a Memorandum of Understanding (MOU). The QA MOU and the information sharing process are the subjects of the PIA Report.

This PIA Report identified privacy risks primarily centered on completing documentation to support the privacy and security obligations for CIC’s Health Branch’s QA information sharing. The following recommendations are made to mitigate or eliminate these privacy risks:

• Establish a process for regular compliance checks on the privacy requirements in the Memorandum of Understanding.
• Amend the Personal Information Bank for Immigration Medical Examiners to reflect the sharing of quality assurance information.
• Determine whether or not a Threat and Risk Analysis for the Immigration Medical Examiner process is required.
• Review the use of consent and the need to provide the Privacy Notice.
• Obtain the Records Disposition Authority for the Medical Immigration Examiner information.
• Develop and document the security procedures for the management of immigration medical examiner quality assurance information.