This report contains a Privacy Impact Assessment (PIA) for the Indian Registration System / Certificate of Indian Status (IRS/CIS) Project. The purpose of this PIA is to provide recommendations on measures to mitigate any privacy issues or risks that may be identified with the IRS/CIS Project.
The Indian Act Indian Act sets out the criteria a person must meet in order to be registered as an Indian and identifies the Registrar as the Indian and Northern Affairs Canada (INAC) officer responsible for maintaining the Indian Register. The Indian Act, section 87, confers certain rights and privileges to status Indians living on reserve. The rights apply to benefits such as tax exemptions for goods purchased on, or delivered to, reserves, and to health care taxes.
The Registrar is responsible for determining who is entitled to be registered as an Indian and to enter the names into the Indian Register. As a result, all persons seeking to be registered must apply to the Registrar in Ottawa. Once an applicant has been registered, however, all subsequent administration of their record (including births to registered parent[s]) is normally delegated to First Nation-employed Indian Registry Administrators (IRAs).
INAC provides Registered Indians with a card certifying their registration as an Indian. The Certificate of Indian Status (CIS), commonly referred to as a Status Card or Treaty Card, is issued both by INAC (HQ/Regions) and by IRAs after the Registrar has determined that an individual is entitled to have Indian status.
The Indian Register is currently contained within the Indian Registration System (IRS), a legacy database that is over ten years old. Very few of the several hundred IRA offices have remote access to the system and the capability to input data. The present dial-up method of connecting First Nation offices is cumbersome and costly.
Currently most IRAs manually record life events, such as marriage, batch them and send the information to INAC Regional Offices. Regions are responsible for training and monitoring the work of IRAs and for entering data from the batched forms into the IRS.
The Business Case for IRS/CIS describes the need for a re-engineered system and a new and secure CIS. The risk is that the IRS - a mission-critical system - will begin to experience significant downtime and higher maintenance costs if it is not re-engineered.
Among the deliverables, the IRS/CIS Project seeks to accomplish the following by March 2005:
The original project proposal for the CIS included an integrated circuit on the front of the card as a security measure. For both business and privacy reasons, a computer chip on the card and the machine-readable zone were eliminated from the IRS/CIS proposal in Spring 2002. The card being used in the CIS pilot contains a digital photograph and a digital signature. In addition to the digital photo, the front of the card displays name, alias, registry number, sex and date of birth. On the back of the card, the digital signature is displayed, as well as the date of issuance and date for renewal of the card. The back of the card also has a magnetic strip that contains name, registry number and the serial number of the card.