Privacy Impact Assessment Summary: National Register of Electors (NROE) IRCC Citizenship Data Transfers

A Privacy Impact Assessment was conducted for the transfer of new citizenship data from Immigration, Refugees and Citizenship Canada (IRCC) to Elections Canada’s National Register of Electors (NROE).

The Elections Canada (EC) National Register of Electors (NROE) is the permanent, continually-updated database of Canadians who are qualified to vote in federal elections and referendums and is used by EC to create preliminary lists of electors (voters’ lists) at the beginning of federal elections and referendums.

IRCC maintains databases with information on new Canadian citizens, permanent residents, temporary residents, asylum claimants and protected persons (refugees) as well as former Canadian citizens who have renounced their citizenship or individuals whose citizenship has been revoked or whose citizenship certificate has been recalled or cancelled by the Registrar.

Transfers of new citizen data has occurred from IRCC to EC NROE since 1997, when the NROE was created. Canadian citizenship applicants aged 18 and over can consent on IRCC’s Application for Canadian Citizenship to transfer personal information associated with citizenship status upon citizenship conferral to EC to be added to the NROE and subsequently to federal voters’ lists. In May 2017, EC and IRCC updated their Memorandum of Understanding pertaining to the initiative, to allow EC to also obtain a unique client identifier (UCI) number and the date of citizenship conferral for new citizens. As a result, the EC consent question on the citizenship application has been updated to include the UCI and citizenship conferral date in the question.

In addition, changes made to IRCC’s Citizenship Regulations in 2014 allow IRCC to disclose information on citizenship revocations, recalls and renunciations (collectively called ‘loss citizenships’) to government departments and agencies, including Elections Canada. The new EC-IRCC MOU now also covers this transfer, and EC will now receive personal information for these individuals: name, sex, date of birth, address, UCI and date of citizenship loss.

A total of 10 privacy risks, categorized as low to moderate, have been identified as part of this assessment. Six of these risks are applicable to IRCC or are in collaboration with Elections Canada and action has been taken to mitigate four in advance of the signing of this PIA. A mitigation plan has been developed within the assessment to address the remaining issues.