Canadian Travel Number
Section 1 – Privacy Impact Assessment Overview
- Name of Program or Activity:
Canadian Travel Number
- Institution responsible for delivering Program or Activity:
Public Safety Canada
- Government Official Responsible for the Privacy Impact Assessment:
Senior Assistant Deputy Minister, National and Cyber Security Branch
- Head of Institution/Delegate:
Senior Assistant Deputy Minister, National and Cyber Security Branch
- Description of Program or Activity (from Results Framework):
In 2019, legislative amendments made to the Secure Air Travel Act (SATA) through the National Security Act, 2017, established the legal basis for the enhancements to Public Safety Canada’s Passenger Protect Program (PPP), including bringing the SATA list screening function under government control (i.e., centralized screening) and introducing a new redress mechanism, known as the Canadian Travel Number (CTN).
The Minister of Public Safety and Emergency Preparedness (hereinafter the Minister) has the authority under the SATA to establish a list of individuals who may pose a threat to transportation security or who may be travelling or attempting to travel by air to commit certain terrorism offences and to disrupt their ability to do harm, through directions such as denying them transportation or requiring them to undergo additional screening before boarding an aircraft.
Public Safety Canada’s PPP is an essential component to Canada’s multi-layered approach to security, which screens all passengers from commercial passenger flights traveling to, from or within Canada, against the SATA list. As a result, a “match” can happen either because the passenger is indeed the person who is on the SATA list (i.e., a true match), or because of similarities between the name of the passenger and the name of a listed person (i.e., a false match).
The ability to check-in online or at the self-service kiosk is prohibited for passengers who have been identified as a potential match. Therefore, false matches negatively impact legitimate passengers by forcing them to perform their check-in at the service counter with an air carrier agent. This process requires these passengers to undergo further verifications by providing additional personal information (e.g., other identification documents) to ensure that they are not the person who is on the SATA list, which frequently corresponds to them experiencing additional air travelling difficulties at the airport.
The CTN aims to support the PPP’s centralized screening model by strengthening privacy safeguards and the integrity of the PPP by reducing false name matches against the SATA list. This will facilitate legitimate air travelling experiences to, from and within Canada. The CTN Office aims to voluntarily collect personal information from any individuals for the purpose of issuing a unique identifier (known as a CTN) to assist with pre-flight verification of their identity. Individuals who encounter delays when travelling by air due to the fact that their name is the same or similar as individuals on the SATA list will benefit from this pre-flight identity verification. Passengers will be able to provide their CTN at the time of reservation and/or at check-in, which will help to distinguish them from SATA listed individuals, should their name, date of birth and/or gender be similar or the same as that of a SATA listed person.
To apply for a CTN, travellers will have to go to Public Safety Canada’s PPP website and either use the secure online CTN Office Portal, or download a paper CTN Application Form and submit it by mail. Personal information is required, as well as the name variations that could be associated with the different identification documents used to present at the boarding gate, prior to boarding a flight. In the case of a child or children who are under 16 years of age, a parent or legal guardian∕ tutor can apply for a CTN on their behalf. Personal information is required for both the child and the person applying on their behalf as well as certain additional information such as proof of parentage∕ legal guardianship∕ tutorship. Applicants must confirm that they have read and understood the Privacy Notice Statement and the Consent Statement in order for the CTN Office to process their application.
- If a copy of a Canadian passport is provided, in certain circumstances when there could be doubts about the legitimacy or validity of the document, the traveller’s information will be shared with their consent to Immigration, Refugees and Citizenship Canada (IRCC) for identity verification and validation purposes.
- If a copy of a foreign passport is provided, in certain circumstances when there could be doubts about the validity of the document, the traveller’s information will be shared with their consent to the Canada Border Services Agency (CBSA) for identity validation purposes.
In all cases, eligibility will be evaluated by the CTN Office and a CTN will be provided to everyone who applies and fulfills the application requirements along with including all the necessary documents.
- Class of records associated with the program or activity:
With respect to the PIA identified in this Summary, a COR has been updated to include:
Record Number: PS NCSB 05
In addition, it also includes records related to Centralized Screening and the Canadian Travel Number (CTN) Office. Centralized Screening requires air carriers to provide the Minister of Public Safety and Emergency Preparedness with prescribed data on each person who is on board or expected to be on board an aircraft for any flight captured under the Secure Air Travel Regulations, if that information is in the air carrier’s control, within a prescribed time and manner. The CTN Office supports government-controlled centralized screening by facilitating pre-flight verification of passengers’ identity. Records include personal information related to individuals or parents/legal guardians/tutors (applying on behalf of a child or children) who apply for a CTN.
- Personal Information Bank:
With respect to the PIA identified in this Summary, a PIB needs to be updated, and registered to include:
Personal information is voluntarily collected by the CTN Office pursuant to section 10.1 of the Secure Air Travel Act, for the purposes of issuing a unique identifier (i.e., CTN) to a person to assist with the verification of their identity before a flight, collect any personal information that they provide.
Personal information in this bank includes: biographical information (e.g., air travel experience, child air travel experience, relationship with child [i.e., parent, legal guardian/tutor], proof of parentage document, if the child is the subject of an adoption process, and if the child is partially or fully in the care of a family services organization), contact information (e.g., current home address, mailing address, e-mail address, and preferred communication method), citizenship status (e.g., country of citizenship, and second country of citizenship), date of birth, gender (e.g., female, male, another gender, and unspecified), language (e.g., English, French, and preferred communication language), name, other identification numbers, and signature.
- Legal Authority for Program or Activity:
Under the Secure Air Travel Act (SATA), as amended through the National Security Act, 2017, subsection 10.1 states that the Minister may, for the purpose of issuing a unique identifier (i.e., CTN) to a person to assist with the verification of their identity before a flight, collect any personal information that they provide.
Section 10 of the SATA mentions that the following persons or entities may assist the Minister in the administration and enforcement of the SATA, including by collecting information from, and disclosing information to, the Minister and each other:
- the Minister of Transport Canada (TC);
- the Minister of Immigration, Refugees and Citizenship Canada (IRCC);
- a member of the Royal Canadian Mounted Police (RCMP) or a civilian employee of that police force;
- the Director or an employee of the Canadian Security Intelligence Service (CSIS);
- an officer or employee of the Canada Border Service Agency (CBSA); and
- any other person or entity prescribed by regulation, such as the Minister of Foreign Affairs (GAC).
As such, IRCC and the CBSA have the legal authority to collect a traveller’s personal information to assist the Minister in the verification and/or validation of their identity for the purposes of assessing their eligibility for a CTN.
- Summary of the project / initiative / change:
Public Safety Canada’s Passenger Protect Program (PPP) is an essential component to Canada’s multi-layered approach to security. The purpose of the program, created in 2007, is to prevent individuals who could be a threat to national security from boarding a plane. The Secure Air Travel Act (SATA) list (sometimes called Canada’s “No-Fly List”) has names of individuals who the Minister of Public Safety and Emergency Preparedness has reasonable grounds to suspect will:
- engage, or attempt to engage, in an act that would threaten transportation security; or
- travel by air to commit terrorism offenses, such as participating in or contributing to terrorist activities; or funding, training and/or recruiting for a terrorist group.
In the fall of 2016, through the National Security Consultations, the Government engaged Canadians, stakeholders and subject-matter experts on issues related to national security and the protection of rights and freedoms. The outcome of the Consultations revealed that participants were generally supportive of the SATA list but wanted measures to reduce the number of individuals who were not on the list, but experienced delays due to their name being the same or similar as an individual on the SATA list.
In Budget 2018, the Government committed to “establish a redress mechanism for legitimate air travellers who are affected by the program [PPP].” In 2019, legislative amendments made to the SATA through the National Security Act, 2017, established the legal basis for the enhancements to the PPP, including introducing a new redress mechanism, known as the Canadian Travel Number (CTN).Applying for a CTN is voluntary, free and available to anyone who fulfills the application requirements and includes all the necessary documents. Travellers with a CTN will be able to use it when reserving flights to, from and/or within Canada by entering it into the air carrier or travel/booking agency’s online reservation system. The government-controlled centralized screening system will use the CTN when checking passenger lists against the SATA list. This will help resolve false name matches to the SATA list prior to boarding which will reduce travel delays.
Section 2 - PIA Risk Area Identification and Categorization
The following section contains risks identified in the PIA for the new or modified program. A risk scale has been included for each risk area lettered "a – f". The numbered risk scale is presented in ascending order: the first level represents the lowest level of potential risk for the risk area; the fourth level (4) represents the highest level of potential risk for the given risk area. Please refer to “Appendix C” of the TBS Directive on PIAs to learn more about the risk scale.
- Type of program or activity
- Risk Scale - 2: Administration of program or activity and services
- Type of Personal Information Involved and Context
- Risk Scale – 2: Personal information, with no contextual sensitivities after the time of collection, provided by the individual with consent to also use personal information held by another source
- Risk Scale – 3: Social Insurance Number, medical, financial or other sensitive personal information and/or the context surrounding the personal information is sensitive.
- Program or Activity Partners and Private Sector Involvement
- Risk Scale – 2: With other government institutions
- Duration of the Program or Activity
- Risk Scale - 3 Long-term program
- Program Population
- Risk Scale – 3: The program affects certain individuals for external administrative purposes
- Technology and Privacy
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? Yes
Does the new or modified program or activity require any modifications to IT legacy systems and / or services? Yes
Does the new or modified program or activity involve the implementation of one or more of the following technologies:
- Enhanced identification methods? No
- Use of Surveillance? No
- Use of automated personal information analysis, personal information matching and knowledge discovery techniques? No
- Personal Information Transmission
- Risk Scale – 2: The personal information is used in a system that has connections to at least one other system
- Risk Scale – 4: The personal information is transmitted using wireless technologies.
- Risk Impact to the Institution:
- Risk Scale – 4: Reputation harm, embarrassment, loss of credibility
- Risk Impact to the Individual or Employee
- Risk Scale – 1: Inconvenience
- Risk Scale – 2: Reputation harm, embarrassment
- Risk Scale – 3: Financial harm
- Date modified: