Race-Based Data Collection Initiative project

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Overview and privacy impact assessment initiation

Government institution
Royal Canadian Mounted Police
Head of the government institution or delegate for section 10 of the Privacy Act
Danielle Golden
Director of Privacy, Access to Information and Privacy Branch
Senior official or executive responsible for the privacy impact assessment
Superintendent Darryl Dawkins
Name and description of the program or activity of the government institution
Anti-Racism, Equity, Diversity and Inclusion Secretariat (AREDIS), Human Resources Policies, Strategies and Programs, Chief Human Resources Officer
Legal authority for the program or activity
Section 18 of the Royal Canadian Mounted Police Act
Section 14 of the Royal Canadian Mounted Police Regulations
Standard or institution specific personal information bank
Operational Case Records, RCMP PPU 005

Description of the project, initiative or change

The collection, analysis and disclosure of disaggregated race-based data is a priority for the RCMP and Government of Canada to address systemic racism.

The Race-Based Data Collection (RBDC) Initiative supports the organization to accomplish its goal to address systemic racism and discrimination by encompassing critical components such as information management and technology, community and employee engagement, policy development, contextual analyses, communications, training development, open reporting and open data, and developing action plans.

The RCMP will adopt a "phased approach" to collecting, analyzing and reporting perceived race-based data; that is the member's perception of an individual's race or Indigenous identity whom they interact with in certain circumstances. As such, the RCMP will not be asking individuals to provide their self-reported race or Indigenous identities to the RCMP.

As a first step, the RCMP will initiate by piloting the collection of perceived race-based data, develop an analytical framework with input from local communities and analyze de-identified data extracted from a select number of locations to publicly report trends and develop action plans. The pilot is expected to help the RCMP to build capacities and competencies for scalability and sustainability for mandatory race-based data collection in a future national roll-out.

The PIA is focused on the pilot phase of the RBDC Initiative. It involves the collection of perceived race-based data and perceived Indigenous identity in selected locations, as well as data quality assessments in order to enable analytics of de-identified data and public reporting in relation to use of force, wellness checks and arrests.

Risk area identification and categorization

A) Type of program or activity

Program or activity that does not involve a decision about an identifiable individual

Level of risk to privacy: Low risk

B) Type of personal information involved and context

Sensitive personal information (perceived race and Indigenous identity)

Level of risk to privacy: Moderate risk

C) Program or activity partners and private sector involvement

Within the institution, with other government institutions, federal, provincial or territorial, and municipal governments and private sector organizations

Level of risk to privacy: Elevated risk

D) Duration of the program or activity

Short term (pilot) and Long-term program or activity

Level of risk to privacy: Moderate risk

E) Program population

The program's use of personal information affects certain individuals for non administrative purposes

Level of risk to privacy: Low risk

F) Technology and privacy

  1. Does the new or substantially modified program or activity involve implementation of a new electronic system or the use of a new application or software, including collaborative software (or groupware), 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 substantially modified program or activity require any modifications to information technology legacy systems?
    Risk to privacy: No
  3. Does the new or substantially modified program or activity involve implementation of new technologies or one or more of the following activities:
    • Enhanced identification methods
      Risk to privacy: No
    • Surveillance
      Risk to privacy: No
    • Automated personal information analysis, personal information matching and knowledge discovery techniques
      Risk to privacy: No

Level of risk to privacy: Low risk

G) Personal information transmission

The personal information is used in a system that has connections to at least one other system

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

Inconvenience, reputational harm, embarrassment
A potential breach of information related to perceived race and perceived Indigenous identity could, for some individuals, be considered embarrassing or an annoyance, especially if the individual does not agree with the member's perception. Such a breach would also diminish trust with RCMP members who are participating in the pilot project.
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