Global Commerce Support Program (GCSP) – Privacy Impact Assessment

Executive Summary

The Department of Foreign Affairs and International Trade (DFAIT) is the federal government's centre of expertise on foreign affairs and international trade and provides ongoing benefits to Canadians by, inter alia:

1. leading a government–wide approach to formulating and implementing policies on foreign affairs and international trade, as well as related programs;
2. concentrating on the department's core business in order to advance Canada's global agenda as it relates to the key issues of peace and security, trade and investment, and international law and human rights, while making full use of the department's geographic expertise worldwide; and,
3. promoting international trade and commerce through initiatives such as negotiation of agreements to open and/or expand markets, facilitation of two–way trade and investment, and encouragement of innovation by means of international partnerships for science and technology commercialization.

The Global Commerce Support Program (GCSP) was established in December 2008 in an effort to be more consistent with Canada’s international commercial policy framework, the Global Commerce Strategy (GCS). The objective of the GCS is to position Canada as a world leader in the highly competitive global economy of today by strengthening the environment and support system for Canadian firms to participate in global commerce, thereby enhancing Canada’s productivity and competitiveness.

The GCSP is a contribution program that amalgamates three existing funding programs:

• Invest Canada – Community Initiatives (ICCI) formerly known as Community Investment Support Program (CISP)

It was originally approved in 1998 as Program for Export Market Development – Investment (PEMD–I). It is designed to support Canadian community efforts to achieve the ultimate outcome of creating jobs through attracting, retaining and expanding Foreign Direct Investment (FDI).  Through ICCI, communities are provided with assistance to aid in the development and delivery of localized investment attraction strategies, a critical element of a community’s ability to be innovative.

• Going Global Innovation (GGI) formerly known as Going Global Science and Technology Program (GG)

It is designed to promote and enhance Canada’s international collaborative efforts by supporting Canadian researchers in pursuing international research and development (R&D) opportunities through the development of partnerships with key players in other countries/economies.

It supports projects that aim to build on targeted relationships between Canadian companies and/or researchers and key players in other countries with the expectation that these relationships will progress to formal discussions leading to future international R&D initiatives eventually leading to downstream commercialization results.

GCSP fills a unique niche by being the only federal contribution program that provides early–stage financing to Canadian researchers for the specific purpose of assisting them in establishing partnerships with key players in other countries.  In an effort to increase the likelihood of downstream commercialization going forward, more emphasis will be placed on private sector participation and on projects that are more likely to lead to initiatives with strong market potential.

• Global Opportunities for Associations (GOA) formerly known as Program for Export Market Development – Associations (PEMD–A)

The GOA component of the GCSP will increase Canadian prosperity and competitiveness in the international marketplace by financially supporting national sectoral trade or industry associations (or a regional sectoral association with a national perspective) or national horizontal/multi–sectoral organizations to undertake new or expanded international business development promotion activities for the benefit of its entire industry (member and non–member firms).

As a way of aligning with and focusing on the Department’s international priorities as outlined in the GCS, the GOA component integrates departmental strategic market and sector priorities in its programming policies.  In addition, while the focus of PEMD–A was on export market development and export sales, the focus of the GOA component shifts to a broader definition of international business development which allows for integrative trade activities, including global value chain activities, making the component more relevant to today’s global economy and competitiveness.

The objective of the GOA component is to establish business relationships and market potential for Canadian industry in strategic markets and sectors, by sharing the risks and costs of activities that associations normally could not or would not undertake alone, thereby reducing risks involved in international business development.

The amalgamation of these programs has been identified as the most efficient and effective way to maximize the use of limited resources to support the recipients’ efforts to connect to the global value chain consistent with the GCS.

The purpose of the GCSP is to build stronger and more competitive Canadian capacity to effectively compete in the global economy. As the GCSP is a contribution program, it is accessed by clients who apply for financial support to assist them to attract, retain and expand foreign direct investment, increase Canadian innovation and commercialization opportunities and to increase Canada’s business share in foreign markets.

The legislative authority through which funding is dispensed is the Department of Foreign Affairs and International Trade Act, RSC 1985, c. E–22.

Funds are allocated through successful application forms for each of the three components of the program.

Personal information required as part of each application is limited to:

• The name and address of a contact person representing the organization who is applying for the contribution; and,
• The name(s) and address(es) of individuals representing organizations participating in the initiative with the applicant

A PIA was conducted to assess the privacy implications associated with collection, and use of the personal information of these contact individuals.

The findings of the Privacy Assessment are:

1. Given the fact that the personal information being collected is used to contact representatives of organizations who are applying for, and/or participating in the spending of, GCSP contributions consent to collect their contact information would seem to be redundant.
2. Use of the personal information i.e. contact persons’ names, addresses, telephone numbers and e–mail addresses to contact the applying and participating organizations would seem to be appropriate.
3. Disclosure of the contact information to other organizations federal and provincial who may have a specific interest in the intent of the contribution for the purpose of contacting the applicant organization would seem to be both necessary and appropriate.
4. Protection of the personal information and validation of the applicant’s identity using an existing privacy–evaluated process (Virtual Trade Commissioner Service) would also seem to be appropriate.
5. Access to the contact information is provided both by self review and update via the Virtual Trade Commissioner and if needed by contacting DFAIT’s ATIP office for procedures on how to file a request under the Privacy Act is commensurate with level of risk.
6. DFAIT’s processes to manage personal information through corporate policies and processes are consistent with best privacy practices and have been in place for some time.

However the following items have been identified and will be addressed:

• Notices at the collection stage that identify the specific purposes for the collection, the authority for so doing and the individual serving as the official contact as required by section 5(2) of the Privacy Act are not in place for all collection forms. Recent electronic collection processes are still to include notices that conform to Treasury Board Secretariat guidelines.
  Action: Electronic collection processes will be updated to include notices that conform to Treasury Board Secretariat guidelines.

• A Threat and Risk Assessment (TRA) has not been completed for Going Global.
  Action: A TRA will be commissioned for Going Global.

Therefore, given the nature and use of the personal information collected, there is a minimal risk of privacy exposure. Furthermore, aside from the two action items noted above, no further action is needed.

However, it is important to note that during the development of the PIA for GCSP, it was determined that a separate PIA should also be conducted for Going Global Innovation (GGI). The Executive Summary of that PIA will also be posted on this website once the PIA has been completed.