Goods and Services Tax / Harmonized Sales Tax (GST/HST) Credit and Related Benefits and Credits v 2.0

Assessment, Benefit, and Service Branch
Benefit Programs Directorate

On this page

• Overview & Privacy Impact Assessment Initiation (PIA)
• Summary of the project, initiative or change
• Risk identification and categorization

Overview & Privacy Impact Assessment (PIA) Initiation 

Government institution

Canada Revenue Agency

Government official responsible for the PIA

Gillian Pranke
Assistant Commissioner
Assessment, Benefit, and Service Branch

Head of the government institution or Delegate for section 10 of the Privacy Act

Lia Jackson
Director
Access to Information and Privacy Directorate

Name of program or activity of the government institution

Benefits

Standard or institution specific class of record:

Benefits Programs - Goods and Services Tax/Harmonized Sales Tax (GST/HST) Credit and other related benefit and credit Programs
CRA ABSB 648

Standard or institution specific personal information bank:

Goods and Services Tax / Harmonized Sales Tax Credit (GST/HST credit) and Related
Benefits and Credits
CRA PPU 140

Legal authority for program or activity

The goods and services/harmonized sales tax credits are administered under section 122.5 of the Income Tax Act. 

Subsection 220(1) of the Income Tax Act provides for the Minister’s duty to collect information for the purpose of the administration and enforcement of any program covered under the Income Tax Act. In this case, the goods and services/harmonized sales tax credits are administered under section 122.5 of the Income Tax Act. The climate action incentive payment is administered under subsection 122.8(1) of the Income Tax Act and the advanced Canada workers benefit is administered under section 122.7 of the Income Tax Act.

Section 61 of the Canada Revenue Agency Act allows CRA to implement agreements with other federal, provincial, and territorial governments for the purpose of carrying out an activity or program administered by the CRA.

The authority to perform a set-off is granted under subsection 164(2) of the Income Tax Act and subsection 155(1) of the Financial Administration Act.

The legal authority to collect the social insurance number is found under section 237 of the Income Tax Act and is used for identification purposes.

Summary of the project, initiative or change

Overview of the Program or Activity

Goods and services tax/harmonized sales tax credit

In cooperation with federal, provincial, and territorial partners, CRA develops and coordinates a variety of federal, provincial, and territorial benefit and credit programs, which contribute to the economic and social well-being of Canadians. One of these programs is the goods and services tax/harmonized sales tax credit.

The goods and services tax/harmonized sales tax credit is a tax-free quarterly payment that helps individuals and families with low and modest incomes offset the goods and services tax/harmonized sales tax that they pay. It may also integrate payments from provincial and territorial benefit and credit programs administered by CRA. Taxpayers are automatically deemed to have applied for the goods and services tax/harmonized sales tax credit when they file their personal income tax and benefit return.

Eligibility criteria for the goods and services tax/harmonized sales tax credits are as follows:

• Be a resident of Canada for income tax purposes at the beginning of the month in which the CRA makes a payment. In the month before CRA makes a quarterly payment, you must also meet at least one of the following conditions during the same period:
  • Be 19 years of age or older
  • Have (or had) a spouse or common-law partner
  • Be (or were) a parent and live (or lived) with your child

The entitlement amount of the Goods and services tax/harmonized sales tax credit(s) is based on the number of children under 19, the marital status (credit for the spouse), and the combined adjusted family net income (when applicable).

Related programs

The CRA administers the following federal, provincial, and territorial programs that are related to or integrated with the goods and services tax/harmonized sales tax credit:

• Alberta climate leadership adjustment rebate
• British Columbia climate action tax credit
• British Columbia harmonized sales tax credit
• New Brunswick harmonized sales tax credit
• Newfoundland and Labrador income supplement, which includes:
  • Newfoundland and Labrador disability amount
  • Newfoundland and Labrador seniors’ benefit
• Prince Edward Island sales tax credit
• Saskatchewan low-income tax credit
• Ontario trillium benefit, which includes:
  • Ontario energy and property tax credit
  • Northern Ontario energy credit, and
  • Ontario sales tax credit
• Ontario senior homeowners’ property tax grant
• Yukon government carbon price rebate – individuals
• Northwest Territories cost of living offset
• Nova Scotia affordable living tax credit
• Climate action incentive payment
• Advanced Canada workers benefit

Note: Henceforward, the document will refer to the above programs as the “Goods and services tax/harmonized sales tax credit and related programs”.  

There is no need, for most individuals, to apply separately to qualify under the above programs. If eligible, the payments are calculated automatically based on information from the recipients Canada child benefits application and/or their personal income tax and benefit return, as well as their spouse or common-law partner’s file.

Effective July 2023, individuals are deemed to have applied for the advanced Canada workers benefit payments if they are eligible for the Canada workers benefit on schedule 06 of the personal income tax and benefit return in the previous year.

Individuals can apply for the Ontario senior homeowner’s property tax grant and the Ontario trillium benefit (Ontario energy and property tax grant and Northern Ontario energy credit components) by completing form ON-BEN in the Ontario provincial schedule of the personal income tax and benefit return.

Applications for the rural supplement of the climate action incentive payment are made on the personal income tax and benefit return or verbally through a CRA contact centre.

New residents of Canada who have not yet filed a Canadian personal income tax and benefit return and who have children can apply for the Goods and services tax/harmonized sales tax credit and related programs using the form “RC66 Canada Child Benefits Application” and the form “RC66SCH Status in Canada and Income Information”.

Individuals who become residents of Canada for tax purposes during the calendar year who are not Canada child benefit recipients can provide a separate application form titled “RC151 GST/HST Credit and Climate Action Incentive Payment Application for Individuals Who Become Residents of Canada”.

The Canada.ca site will host an estimator to help individuals to estimate what benefits and credits they may be entitled based on their unique situation. No personal information will be collected or kept in the online estimator.

What’s New

• The British Columbia low-income climate action tax credit was retitled as the British Columbia climate action tax credit. Although changing its name, there were no changes to administration or use of the data. The payments are integrated with the goods and services tax/harmonized sales tax credit.
• The British Columbia harmonized sales tax credit eligibility period ended January 2013. There are no new entitlement after this date but new assessments and reassessments continue for previous eligible periods. The payments are integrated with the goods and services tax/harmonized sales tax credit.
• The New Brunswick harmonized sales tax credit was introduced in October 2016. This credit is a tax-free amount paid to help offset the increase in the sales tax for households with low and modest incomes for individuals living in New Brunswick. The payments are integrated with the goods and services tax/harmonized sales tax credit.
• The Newfoundland and Labrador harmonized sales tax credit evolved into the Newfoundland and Labrador income supplement in October 2016. The Newfoundland and Labrador income supplement is a tax-free payment made to low-income individuals and families, living in Newfoundland and Labrador, who may be impacted by additional provincial tax measures. The amount is calculated based on family composition and adjusted family net income with additional supplements for seniors and persons with disabilities. Individuals or spouses eligible for the disability tax credit are eligible for the disability supplement amount. The payments are integrated with the goods and services tax/harmonized sales tax credit.
• The Saskatchewan sales tax credit was retitled as the Saskatchewan low-income tax credit. The payments are integrated with the goods and services tax/harmonized sales tax credit.        
• The Yukon government carbon price rebate – individuals’ payment was introduced in October 2019. This rebate is a non-taxable amount paid to individuals and families, living in Yukon, to help offset the cost of the federal carbon pollution pricing levy. The payment amount is integrated with the goods and services tax/harmonized sales tax credit.
• Northwest Territories cost of living offset payment was introduced in October 2019. This offset is a non-taxable payment made to individuals and families living in the Northwest Territories to help offset the cost of the Northwest Territories carbon tax. The payment is integrated with the goods and services tax/harmonized sales tax credit.
• The Nova Scotia affordable living tax credit is a non-taxable quarterly payment to make life more affordable for low and modest income individuals and families living in Nova Scotia. The payments are integrated with the goods and services tax/harmonized sales tax credit.
• The climate action incentive program changed from a refundable tax credit claimed annually on the personal income tax and benefit returns to quarterly tax-free payments in July 2022. The Climate action incentive program is a tax-free amount paid to help individuals and families offset the cost of the federal pollution pricing. It is available to residents of a province or territory who have chosen not to price pollution or proposed a system that did not meet the standards set by the federal pricing system. Starting in July 2022 Alberta, Saskatchewan, Manitoba, and Ontario residents are eligible for the Climate action incentive payments. Starting in July 2023 Newfoundland and Labrador, Nova Scotia, New Brunswick, and Prince Edward Island residents became eligible. The payments consist of a non income tested basic amount and a supplement for residents of small and rural communities. The payments are calculated based on family composition and are issued quarterly as a stand-alone payment.

While the climate action incentive payments are not integrated with the goods and services tax/harmonized sales tax credit similar eligibility requirements apply. In the month before CRA makes a quarterly payment, the individual residing in one of the eligible provinces must also meet at least one of the following conditions during the same period:

• Be 19 years of age or older
• Have (or had) a spouse or common-law partner
• Be (or were) a parent and live (or lived) with your child

Starting with the 2022 tax year, taxpayers eligible for a rural supplement of the climate action incentive payment will no longer need to apply on schedule 14 of the personal income tax and benefit return but will need to apply on page 2 of the return or by contacting the CRA to review their eligibility. The rural supplement payments are integrated with the quarterly climate action incentive payment.

• In November 2022, a one-time top up to the goods and services tax credit was issued in an effort to address rising costs of living due to inflation.
• A one-time grocery rebate supplement will be available for all individuals who were entitled to the goods and services tax/harmonized sales tax (GST/HST) credit in January 2023. The grocery rebate payment will be made in July 2023 and will be issued alongside the GST/HST credit payments, if applicable.
• Effective January 2017, paper records are no longer sent to a third-party paper storage provider. All paper records are scanned and stored on an internal database. Existing records continue to be retained for the appropriate disposition period.
• Effective February 2023, the goods and services tax/harmonized sales tax credit and related programs began to participate in the digital mailroom project (a separate privacy protocol assessment was done for this project in 2021). All direct deposit and identification change requests received by mail are sent to a third party, to be digitized into the document management portal prior to processing.
• The Canada workers benefit is a refundable tax credit for low-income individuals and families who have working income earned from employment or business. This credit can be claimed each year on the personal Income Tax and Benefit Return if an individual has;
  
  • earned working income
  • is 19 years of age or older on December 31st
  • and is a resident of Canada for income tax purposes throughout the year
  • individuals under 19 who have a spouse or common-law partner, or an eligible dependent on December 31st, are also eligible

In the past, individuals may apply for this credit in advance of filing a tax return by completing the form RC201 – Canada working benefit advance Payments Application or applying through My Account. These early payments are referred to the Canada working benefit advance payments and corresponded to a maximum of 50% of the estimated income provided by the recipient and divided into 4 quarterly payments. The advance payments included a disability supplement if the eligible individuals had a valid disability tax credit. Payments were stand alone and not integrated with any other benefits. Privacy considerations for the original application based payments were assessed under the Working Income Tax Benefit (WITB) Advance Payments PIA file and in personal information bank Working Income Tax Benefit (WITB) CRA PPU 178.                                                           

Effective July 28, 2023, individuals will automatically be deemed to have applied for the advanced Canada workers benefit payments if they were entitled to the Canada workers benefit refundable tax credit on their personal income tax and benefit return for the previous year. Eligible individuals will automatically receive 50% of the Canada workers benefit entitlement broken into three payments. Payments are issued in July, October and January, any additional entitlements for the year will be reconciled when the individual files a tax return for the new year. These advanced payments are calculated based on income, family status (married, dependants), province or territory of residence and include a disability supplement if the eligible individual has a valid disability tax credit for the tax year. Payments will continue to be stand alone and not integrated with any other benefits. An information slip (RC210) will be issued annually through the MyAccount secure portal, or via mail for those who have not registered for secure online correspondence, and is used to report the advanced payments received on the income tax and benefit return.

Scope of the Privacy Impact Assessment

This privacy impact assessment identifies and assesses privacy risks relating to the administration of the goods and services tax/harmonized sales tax credit and the related federal, provincial, and territorial benefits and credits.

Certain compliance activities such as audits and criminal investigations are separate programs, and therefore are not included within the scope of this privacy impact assessment. In addition, the calculation, enforcement, and administration of the Canada child benefits and the federal and/or provincial personal income tax and benefit returns, and the application process to determine if a person with a disability is eligible for the disability tax credit and the income verification services are not included in this privacy impact assessment.

Programs and initiatives that focus on economic benefits and credits are constantly changing. Therefore, when a new initiative or a change to an existing credit or benefit is identified, this privacy impact assessment will be reviewed and updated accordingly.

Risk identification and categorization

A) Type of program or activity

Compliance / Regulatory investigations and enforcement 

Level of risk to privacy: 3

Details:

The personal information is used for the identification, determination, validation, and payment of benefits and credits.

Information is also used to determine whether an individual knowingly participated in or made a false statement or omission. The consequences can include reviews, which may result in termination and/or recoup of benefits and possibly levying civil penalties under subsection 163(2) of the Income Tax Act.

Also in limited cases, information obtained during validation or compliance activities may be referred to the Criminal investigations program of the CRA for further investigation against a particular individual. This may result in the laying of criminal charges under section 238 or section 239 of the Income Tax Act against a particular individual.

B) Type of personal information involved and context

Social insurance number, medical, financial or other sensitive personal information and/or the context surrounding the personal information is sensitive. Personal information of minors or incompetent individuals or involving a representative acting on behalf of the individual.  

Level of risk to privacy: 3

Details:

Personal information collected includes details such as: name, contact information, financial information, social insurance number and signature, biographical information, disability tax credit indicator, student indicator, and residency.

In addition, some of the information will include the personal information of minors and individuals incarcerated in a federal institution.

C) Program or activity partners and private sector involvement

Private sector organizations or international organizations or foreign governments 

Level of risk to privacy: 4

Details:

The program includes the administration of benefit and tax credit programs on behalf of federal, provincial, and territorial partners. Information is disclosed by the CRA to our partners for the purpose of accurate calculation of programs and/or program evaluation, and to Public Services and Procurement Canada for the issuance of payments.

CRA sends information including eligibility, entitlement, payment, and identification data to Provincial/Territorial Finance departments for policy and program evaluation.

The information is also used internally within CRA for collection of outstanding balances, audit activities, appeals, statistical gathering, and call centre enquiry responses.

CRA receives information from Correctional Service Canada (CSC) to determine continued eligibility to the goods and services tax/harmonized sales tax credits and related benefits and credits.

Achieved historical paper documents containing personal information are stored by a third party in the private sector.

Select paper documents for changes are now digitized and stored by a third party in the private sector prior to processing.

D) Duration of the program or activity

Long-term program 

Level of risk to privacy: 3

Details:

Although some of the individual provincial/territorial credits may be short term, most are not, and the goods and services tax/harmonized sales tax credit and related benefits and credits are long-term programs with no established end date.

E) Program population

The program affects certain individuals for external administrative purposes.

Level of risk to privacy: 3

Details:

The program affects any individual who submits an application or files a personal income tax and benefit return, their spouse or common-law partner, and their children under 19 years of age.

F) Technology & privacy

1. Does the new or modified program or activity involve the implementation of a new electronic system, software or application program including collaborative software (or groupware) that is implemented to support the program or activity in terms of the creation, collection or handling of personal information?
   Risk to privacy: No
2. Does the new or modified program or activity require any modifications to IT legacy systems and/or services?
   Risk to privacy: Yes
3. Does the new or modified program or activity involve the implementation of one or more of the following technologies?

Enhanced identification methods - this includes biometric technology (i.e. facial recognition, gait analysis, iris scan, fingerprint analysis, voice print, radio frequency identification (RFID), etc.) as well as easy pass technology, new identification cards including magnetic stripe cards, "smart cards" (i.e. identification cards that are embedded with either an antenna or a contact pad that is connected to a microprocessor and a memory chip or only a memory chip with non-programmable logic).

Risk to privacy: No

Use of Surveillance - this includes surveillance technologies such as audio/video recording devices, thermal imaging, recognition devices, RFID, surreptitious surveillance/interception, computer aided monitoring including audit trails, satellite surveillance etc.

Risk to privacy: No

Use of automated personal information analysis, personal information matching and knowledge discovery techniques - for the purposes of the Directive on PIA, government institutions are to identify those activities that involve the use of automated technology to analyze, create, compare, identify or extract personal information elements. Such activities would include personal information matching, record linkage, personal information mining, personal information comparison, knowledge discovery, information filtering or analysis. Such activities involve some form of artificial intelligence and/or machine learning to uncover knowledge (intelligence), trends/patterns or to predict behavior.

Risk to privacy: Yes

G) Personal information transmission

The personal information is transmitted using wireless technologies. 

Level of risk to privacy: 4

Details:

Personal information can be used in a system that has access to other systems and can be transferred to a secure portable device using CRA approved encryption technologies as required.

Online Services:

CRA uses specially configured computer Web servers for any online services (e.g., My Account); and uses corporate firewalls to protect our Web servers from unauthorized access. Personal information is not stored on these servers; CRA securely stores personal information on separate computer systems that are not directly accessible from the Internet.

When transmitting personal information, access to our Web servers is limited to Web browsers that meet our security standards of encryption. We ensure that personal and financial information is encrypted—or scrambled—when it is transmitted between an individual’s computer and our Web servers. This ensures that computer hackers and other Internet users cannot view or alter the data being transmitted. We encrypt all web communication as prescribed by the Canadian Centre for Cyber Security (CCCS) published standard ITSP.40.111. This is one of the most secure forms of encryption available in North America and is a typical requirement for Web-based services—such as online banking or shopping—where securing personal information is a priority.

Portable Devices:

Some employees’ workstations are composed of CRA-issued laptops in docking stations. Laptops comply to the Security for the Computing Environment Policy with Encryption and access control. Any telework done is through secure remote access (SRA) with a combination of government issued phones and/or approved limited use of personal telephone devices such as landlines.

Any USB keys used must be CRA issued and formatted with encryption technology specific to the user.

Data Transfers and Exchanges:

All electronic transactions are securely transferred using Entrust encryption software with public key infrastructure, as prescribed by the CCCS published standard ITSP.40.111. By using the Entrust public key, only the corresponding private key owned by the partner can decrypt the file. In addition, all internet-based web applications require the use of a user ID and Password.

To register for a CRA public key infrastructure enabled program, participants must first become CRA public key infrastructure subscribers and be approved by a CRA Local Registration Authority. CRA system administrators can control or limit access to specific directories on the server. In addition to restricting access to the server, the data for each partner is encrypted using the Entrust public key, only the corresponding private key owned by the partner can decrypt the file.

Although wireless technology (ex: Wi-Fi) may be used to transmit information, CRA employees are located in Canada and utilize Secure Remote Access to authenticate using their public key infrastructure certificate.

Direct deposit and identification changes (such as an address change) received in writing are digitized and stored in the Document Management Portal for later access by CRA employees on a need-to-know basis.

H) Potential risk that in the event of a privacy breach, there will be an impact on the individual or employee

Details:

If the personal information is compromised, it has the potential to cause financial harm and embarrassment to the affected individual. The affected individual may also become a victim of identity theft, and their information may be used without their knowledge or consent.