Privacy Impact Assessment Summary: Interview Facilitation Service (IFS)

About the Program

Immigration, Refugees and Citizenship Canada (IRCC) is charged with processing various types of immigration applications. For some of these applications, there are instances in which IRCC requires additional or clarifying information from the applicant, prompting the need for an in-person interview. These interviews have historically occurred at an IRCC Migration Office or, at times, at a location closer to the applicant.

Interviewing applicants is an integral part of the application process as it risk manages applications that require closer scrutiny. As a result of the COVID-19 health risks, IRCC was forced to limit its physical interaction with the public, or where interaction is absolutely necessary, to ensure it is being done with direct control over the environment to ensure the safety of its employees. During the initial waves of COVID-19, this meant halting the physical interviews at the Visa office in order to limit client and employee exposure.

Applications were still being processed, and still are, but where interviews are critical for the continuation of the application processing, delays have occurred and, in some cases, halted the process.

To alleviate the backlog of Applicants awaiting interviews, IRCC explored options to deploy a virtual interview solution. After exploring several solutions, IRCC decided to take advantage of its third party vendor who maintains a global Visa Application Centre (VAC) network, and to utilize the MS Team Application across this network. The newly approved solution, internally called the Interview Facilitation Service (IFS), requires an amendment to the existing VAC contract to require the vendor, VFS Global, to:

• Build a secure interview room at VAC locations chosen by IRCC. The secure rooms must be compatible with the Royal Canadian Mounted Police (RCMP)/Public Services and Procurement Canada (PSPC) Contract Security Program sound proof requirements and IRCC’s secure room requirements.
• Maintain an appointment calendar for the secure room by allowing IRCC personnel to schedule time slots to conduct virtual interviews with applicants and ensure the secure interview rooms are ready to receive them.
• Maintain a work station in the secure room to facilitate a MS Teams connection/meeting.
• Perform a security sweep of the secure room before and after an interview.
• Receive applicants, validate individual identities, escort them to the secure room, and establish the MS Teams connection with the interviewing IRCC Officer.
• Ensure no laptops, cell phones, tablets or other similar devices with recording capabilities are brought into the secure room by the applicant.
• Leave the room once the MS Teams connection is established; and
• Once the interview is concluded, close the MS Teams meeting and escort the applicant out of the secure room/VAC.

Through the IFS, the collection of personal information by IRCC is not changing. The only change is the manner and location in which an interview takes place – instead of face to face, the interview is performed via MS Teams from a VAC (for the applicant). For the VAC, it already maintains an appointment calendar for other services, including processes requiring the vendor to validate identity. The biggest change for the VAC is not related to personal information – it is the construction or retrofitting of a secure room and ensuring a dedicated workstation is set up in the secure room for the MS Teams meeting.

Scope of the PIA

The scope of this PIA is narrowly limited to the deployment of MS Teams (called the IFS solution) and its use in the immigration examination process. This is not a PIA on the totality of a specific immigration process, nor the assessments and decisions made in that process or from the interviews.

Summary of Privacy Issues and Mitigation Strategies

The PIA identified three Low privacy risks and corresponding recommendations. First, changes to MS Teams features and functionality may pose future risks to the use of the application, therefore, IRCC will monitor those changes to ensure an assessment is conducted to determine how they impact the uses described in the PIA. Second, while all security approvals for MS Teams were provided, it is important to continuously monitor the security of MS Teams and for users to ensure no unwanted persons are in a meeting. And third, existing personal information banks do not identify IRCC’s use of a third party vendor to support overseas application processes, therefore, changes to four PIBs will be made to account for VAC’s involvement in those process.