Contributions Program – Research and public education funded by the OPC
Contributions Program 2011-2012
Office of the Privacy Commissioner of Canada
112 Kent Street, 3rd floor
- 1.1 Eligible Applicants
- 1.2 Non Eligible Applicants
- 1.3 Application Date
- 1.4 Contributions Program Budget
- 2.1 Objectives
- 2.2 Eligible Projects
- Research priority areas
Priority 1–Identity integrity and protection
Priority 2–Information technology
Priority 3–Genetic privacy and biobanking
Priority 4–Public Safety and National security
- Public education & awareness initiatives
- 2.3 Duration of Projects
- 2.4 Allowable Expenses
- 3.1 Application for Funding
- 3.2 The Proposal
- 3.3 Declarations
- 3.4 Other Sources of Funding
- 4.1 Assessing the Organization
- 4.2 Assessing Proposals
- 5.1 Contribution Agreement
- 5.2 Reporting Requirements
- 5.3 Method of Payment
- 5.4 Public Acknowledgement and Recognition
- 5.5 Audit Requirements
- R5.6 ecovery
Top of Page1. Purpose of this Guide
This guide is designed to help you prepare an application for funding under the Contributions Program of the Office of the Privacy Commissioner of Canada (OPC). Specific instructions for completing the application form as well as information about the assessment process are provided.
Top of PageTable of Contents1.1 Eligible Applicants
Not-for-profit organizations, including education institutions and industry and trade associations, are eligible under the Program for funding in support of research into, as well as the promotion of, the protection of personal information. Eligible applicants include consumer, voluntary and advocacy organizations.
Top of PageTable of Contents1.2 Non-Eligible Applicants
- For profit organizations
- Political parties and organizations involved in partisan political activity; and
- Current or former public office holders or public servants who are not in compliance with the Conflict of Interest Act, or any other relevant guidelines, principles or codes relating to conflict of interest or post-employment.
Top of PageTable of Contents1.3 Application Date
The deadline for receipt of applications is March 14, 2011 for fiscal year 2011-2012.
Please forward your application to the following address:
Director of Research, Education and Outreach
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville, Tower B, 3rd Floor
Ottawa, Ontario K1A 1H3
Telephone: (613) 947-7226
Fax: (613) 995-1139
Applicants should note that all information requested in the Guide and Application Form must be received by the Office before a request is considered complete.
Only complete applications received at the above noted coordinates on or before the Program deadline will be considered.
Applications are deemed to have been received by the Office of the Privacy Commissioner of Canada on the date they are post-marked; or delivered to a messenger or specialized courier agency; or on the day they are sent by fax or e-mail.
It is recommended that you verify with our Office to ensure that delivery of your application has been received by us.
Top of PageTable of Contents1.4 Contributions Program Budget
The total amount available under the OPC's Contribution Program is $500,000 for fiscal year 2011-2012. This amount is subject to cancellation, reduction or increase in the event that funding levels are changed by Parliament.
The OPC will consider funding more than one project per organization. However, the maximum amount that can be awarded for any single project is $50,000 and the maximum total amount that can be awarded to any single organization is $100,000.
Top of PageTable of Contents2. Contributions Program
Top of PageTable of Contents2.1 Objectives
The Program’s objectives are to capitalize on existing research capacity in academic, not-for-profit and other sectors, to generate new knowledge, and to support the development of expertise in selected areas of privacy and data protection.
The Program also aims to increase awareness and understanding among individuals and organizations across Canada of their privacy rights and obligations.
Top of PageTable of Contents2.2 Eligible Projects
The OPC will provide funding on a project basis to eligible organizations to conduct privacy-related research and public education/awareness raising initiatives. The OPC will allocate funds in support of knowledge creation and to broker that knowledge among a variety of stakeholders.
Research priority areas
To stimulate research in addressing knowledge gaps and to provide guidance for policy development and best practices, we encourage research proposals that address privacy issues in the following four priority areas. However, the Office will also consider requests to fund research on issues that fall outside these areas.
Priority 1: Identity Integrity and Protection
A fundamental tenet of privacy is that individuals should have the ability to control when and how their personal information is collected, who collects their personal information, and how this information is used and disclosed. The capacity to collect and analyze data about individuals is growing in both the offline and online worlds. We are interested to learn more on the tools, policies or educational materials that are needed to empower individuals so they are able to manage how they interact and are represented within this new environment.
Specifically, we would be interested in funding research on issues such as:
- Case studies on how data on individuals is collected, analyzed and used to influence the options available to them.
- Design choices and user interaction decisions that affect consumer understanding of privacy choices;
- Quantitative analysis of the cost associated with protecting personal or corporate data, or the value of data to consumers, organizations and governments.
- The protection of privacy through the “de-identification” of personal data, or the privacy risks associated with the “re-identification” of personal data;
- Innovative work in respect to anonymous credentials or pseudonymization techniques.
Priority 2: Information Technology
Chief among new challenges to privacy is the impact of emerging information technologies.
The OPC this year wants to reach out to researchers and labs working specifically on privacy and security, from a scientific and/or technical point of view. Emerging information and communication technologies can both threaten Canadians’ privacy, as well as enhance it.
And so, with this in mind, we are particularly interested in funding research addressing the following issues:
- An examination of the vulnerabilities of mobile communications devices (e.g. smartphones), and the implications for identity theft, privacy and the protection of personal information.
- An assessment of the state of the art with respect to privacy enhancing technologies (e.g. encryption and anonymization).
- A study of the privacy implications of smart sensor networks, such as Smart Grid (electricity), and intelligent transportation systems.
- A study of the technologies underlying electronic health records.
- The “Internet of things”— e.g. radio frequency identification technologies (RFIDs), sensor technologies and smart technologies;
- Nanotechnology and the danger of ubiquitous surveillance;
- The privacy and security implications of location-based services.
Priority 3: Genetic privacy & biobanking
The OPC is interested in funding ground breaking research in the area of genetic privacy and biobanking. As a result of advances in science and sophisticated analytical tools, the cost of genetic testing is falling rapidly with the result that increasing amounts of genetic information is being generated and stored in biobanks. Biobanks can include samples collected during medical procedures; samples sent to direct-to-consumer companies for testing; samples collected from volunteers participating in studies; and samples collected by law enforcement agencies for forensic purposes.
We would be interested in funding research on issues such as:
- The privacy implications arising from the communal/shared nature of genetic information;
- The privacy implications of the increasing collection and use of genetic information by private sector organizations; and
- Strategies for increasing consumer awareness of the privacy implications arising from the collection, use and disclosure of genetic information.
Priority 4: Public Safety and National Security
In recent years, the OPC has grown increasingly concerned with the incremental but significant erosion of privacy rights in the post 9-11 public safety and national security environment. Various national security initiatives, such as the financial monitoring regime under FINTRAC, the new powers of the Anti-terrorism Act or an array of new aviation security programs like the Passenger Protect Program or behavioral screening initiatives have undermined the privacy rights we have until recently taken for granted. As a result, our Office is particularly interested in funding research projects on public safety and national security issues.
Important: Please note that we may only fund research projects under “public safety and national security” that also touch on issues which relate to or involve the private sector in some fashion. This is an important caveat because the Contributions Program finds its authority under the Personal Information Protection and Electronic Documents Act (PIPEDA) — which provides for the privacy rights of Canadians in the commercial sector. With this proviso in mind, we would be interested in funding cutting-edge research on issues such as:
- The impact of government security measures on the financial privacy of Canadians;
- Private sector-to-government information exchanges generally, for national security purposes;
- The impact of government travel-related security programs (e.g. Passenger Protect Program, Secure Flight, behavioral screening, etc.) and the marshalling of the airline industry in the pursuit of the national security goals of the State;
- Proposed updates to Canada’s interception and surveillance regime — as embodied in bills C-51 and C-52 — and the potential impacts on privacy;
- The “reasonable expectation of privacy” Canadians have been left with in the 21st century, given the expanding role of both private/public organizations in public safety/national security programs and intelligence gathering.
Call for Public Education & Outreach Proposals
In addition to research proposals, the OPC is calling for funding proposals for the organization of public education and awareness raising initiatives. Public education is one of the Office’s key mandates. The Personal Information Protection and Electronic Documents Act (PIPEDA) mandates the Privacy Commissioner to promote—by any means that the Commissioner considers appropriate—the purposes of the Act.
We would be interested in receiving funding proposals for:
- The organization of workshops targeted to specific audiences, such as industry, trade and consumer groups, aimed at raising awareness and understanding of Canada’s privacy protection framework;
- The organization of conferences and symposiums that would bring together privacy stakeholders and experts from Canada and abroad to discuss emerging challenges and opportunities in personal data protection;
- Innovative online approaches to delivering information and raising awareness of privacy issues which could include (but is not limited to) games, viral videos, contests and campaigns.
- Education and outreach initiatives that support increasing privacy awareness among children and young people, and/or their parents, educators and other influencers.
Public education and awareness raising proposals need not be focused on the four research priority areas identified above. All proposals touching on any area related to privacy promotion and personal information protection will be considered for funding.
Top of PageTable of Contents2.3 Duration of Projects
Our preference is to fund projects that are completed within the fiscal year in which the funding is provided—that is, fiscal year 2011-2012. However, we are also open to funding projects that that go beyond the end of the fiscal year (i.e. March 31, 2012) if it is made clear to us that these projects require more time to be completed.
Top of PageTable of Contents2.4 Allowable Expenses
Funds may be used only for expenses directly related to the activities of the project. These activities are as reflected in either the original budgetary submission, or via subsequent approved budgetary adjustments. Expenses would include:
- salary and benefits for members of the project team, inclusive of researchers and research assistants, students, postdoctoral fellows, technical support, etc.;
- administrative costs, translation, secretarial assistance and publication costs;
- contract costs for expertise not available in house or work not reasonably performed in house (for example surveys); and
- other costs including travel (not to exceed government travel regulations), workshops, materials and supplies, and communications.
OPC support will not include amounts for costs/debts previously incurred, or costs/debts that will take place prior to authorization/commencement of the Agreement. Other costs which are ineligible for funding under the Agreement include the purchase of buildings, land, vehicles and most other major capital costs. Administrative expenses should be limited to no more than 15 per cent of the total project cost.
Finally, contribution funds awarded to an applicant are subject to the terms of the Contribution Agreement signed by the applicant and the OPC. Funds must be spent only on the project and cannot under any circumstances be diverted to any other use. Expenses associated with the project are subject to audit.
For full details, refer to the Costing Memorandum in “Schedule B – Eligible Costs”
Top of PageTable of Contents3. Completing the Application
The following information corresponds to each section of the application form - a copy of which is provided at the end of this Guide. You should provide answers to all questions and include any required detailed information in an appendix to the application form.
Top of PageTable of Contents3.1 Application for funding
Top of PageTable of ContentsIdentification of Applicant
- Provide the full name of your organization along with any abbreviations frequently used, as well as the section name or division name;
- Previous name, if changed in the last year;
- Address, telephone numbers (with extension), fax numbers, e-mail addresses, and web site addresses, where applicable.
The address should include full information on the organization's physical location, such as floor, suite or room number, street number and postal code. Should a Post Office Box be designated as the official mailing address, please provide this information as well.
Top of PageTable of Contents3.2 The Proposal
Applicants will have to provide a project proposal which, once agreed to by the OPC, will serve as a basis for the Contribution Agreement and cash flow. The project proposal should contain:
- Basic Information: Name, address, telephone number, facsimile number and e-mail address of the applicant's authorized representative, organizational structure including legal status, names of principal personnel and project administrators. Please provide contact information for both the principal researcher (where applicable), and/or the person responsible for administering the project.
- Legal Status: An attestation/confirmation that your organization is a not-for-profit organization.
- Organizational Background: Background history of the organization including its mandate, objectives, and accomplishments.
- Previous Financial Support: An indication of any previous financial support received from the OPC including the amount, the year when the funding was provided, the purpose of the funded activity, and the results achieved.
- Project Description: A detailed project description including project title, goals and objectives, identification of the target groups for the proposed project, identification of the anticipated specific benefits for Canadians, the anticipated results, how the OPC could benefit in terms of knowledge to advance policy development, increase public awareness, and improve the protection of personal information. A listing of project deliverables should also be provided.
- One-Page Summary: A concise one-page description of the project that can be used for the Contribution Agreement.
- Timeline and Monitoring: Time frame, work plan detailing activities to be undertaken to support the attainment of project objectives, and monitoring activities.
- Budget: A detailed budget of the project including amount(s) being requested from the OPC (see Schedule B in the Contribution Agreement, which can also be found on our web site) and other proposed sources of revenue including in-kind support.
- Community Involvement and Support: Where appropriate, an indication of the level of community involvement (commitment, endorsement, scope and level of participation, co-operation and volunteer involvement).
- Provincial/Territorial Support: Where appropriate, an indication of the degree of provincial and territorial support for the project.
- Follow-Up Activities: The identification of anticipated follow-up activities or next steps, which might include activities related to the dissemination of information.
- Acknowledging the OPC: How the project will acknowledge the financial support (and where relevant other contributions) of the Office of the Privacy Commissioner of Canada to the project.
Top of PageTable of Contents3.3 Declarations
You are required to answer the questions in the Application form regarding the Conflict of Interest Act, the Values and Ethics Code for the Public Service, and the Lobbying Act.
Top of PageTable of Contents3.4 Other Sources of Funding
Applicants may seek other sources of funding for proposed projects. Potential recipients are required to disclose all sources of funding for a proposed project when applying for funding from the OPC. This includes financial assistance (grants, contributions, etc.) from all levels of government, anticipated or received, that is related to the subject matter of the proposed project. This should also include applications for financial assistance which are still pending.
In the event that total government assistance (including provincial and municipal assistance) received for the project exceeds the cost of the project, the recipient will repay the Crown on a pro-rated basis (based on the OPC's share of total government assistance received).
Top of PageTable of Contents4. The Assessment Process
Each request for financial support will be reviewed to determine the scope, nature, objectives, and feasibility of the proposed project. Applicant organizations and applications for funding will be reviewed in accordance with the general Program objectives as well as the specific eligibility criteria as outlined above and described below.
Top of PageTable of Contents4.1 Assessing the Organization
Key considerations include:
- an assessment of the competence, credibility and accountability of the organization requesting financial assistance;
- the organization's ability to manage the project and its past experience, if any, with the type of project proposed;
- the OPC's previous experience with the applicant; and
- the organization's ability to deliver project results on time.
Top of PageTable of Contents4.2 Assessing Proposals
In selecting recipients for contributions, the OPC may, where appropriate, consult with other federal departments, provincial and territorial governments and other privacy commissioners or ombudsmen.
In reviewing and recommending proposals, the OPC will take into consideration the following factors:
- Does the project advance the OPC's knowledge base and/or directly support the promotion of privacy and the protection of personal information?
- Is the proposed project aligned with the OPC's priorities?
- Is the amount of money requested to carry out the project reasonable given the nature of the project?
- Is the application submitted to the OPC of high quality? ( i.e. the description of the project, the work plan, the business plan, the budget, etc.)
- Does the principal researcher or the applicant possess the expertise to carry out the project successfully?
- To what extent are other stakeholders involved in carrying out the project.
- The project deliverables, including distribution plans for any reports produced.
Top of PageTable of ContentsTimeliness and Relevance of the Issue
- How does the project align with the OPC’s mandate and priorities generally?
- In the case of research proposals in particular, how does the project relate to the OPC’s four research/policy priorities, as described above?
- Will the research project report be completed in time to ensure input to upcoming legislation, regulatory review, relevant enquiries or consultation processes?
Top of PageTable of ContentsMethodology, Capability and Cost
- Is the scope of the project proposal realistic in terms of deliverables and time frames (e.g. is the project too big or complex to be effectively addressed in the specified time frame)?
- In the case of research projects, is the methodology sound and will it yield reliable data? Will the methodology produce data relevant to the stated objectives?
- In the case of public education/awareness raising projects, is the approach sound and is it likely to lead to increased knowledge and awareness of privacy rights and obligations?
- Does the organization tap into the expertise/experience/previous work of other stakeholders, including the OPC, where appropriate?
- Are the estimated costs realistic?
- Is the time frame realistic taking into account the scope of the project?
- Does the proposal demonstrate that the project team is qualified and capable of producing quality work?
- Does the proposal demonstrate that the organization has a good understanding of:
- the issue?
- the major stakeholders involved?
Top of PageTable of ContentsIntended Uses of Project Results
Does the project proposal identify the intended use(s) of the deliverable — for example the deliverable’s usefulness to Canadians, government policy makers, Canadian organizations and stakeholders?
Top of PageTable of ContentsCommunication of Project
Does the project proposal include recommendations for making stakeholders aware of the project? In particular, in the case of research projects, does the proposal include recommendations for disseminating research results?
Top of PageTable of ContentsAdditional Considerations
Applicants should bear in mind the competitive nature of the application process. Where more than one proposal is received for the same issue, the relative costs of the proposals to the Program will be considered along with other factors in assessing their relative merits.
Top of PageTable of Contents5. Control Procedures
Top of PageTable of Contents5.1 Contribution Agreement
On approval of a request for a contribution, a detailed Contribution Agreement will be drawn up and signed by the recipient and the OPC. A Contribution Agreement is a contractual agreement between the organization and the OPC regarding the project contribution awarded.
By accepting a contribution, your organization agrees to carry out the funded project and to be accountable for the amounts received. Accordingly, the Office agrees under certain conditions to contribute all or part of the project's costs. Conditions for project contributions type funding are detailed in the Contribution Agreement.
As specified in the Agreement, the recipient cannot make material changes to the scope of the project without the prior written consent of the OPC.
Top of PageTable of Contents5.2 Reporting Requirements
By signing the Agreement, your organization agrees to submit progress and financial reports, as specified in the Agreement for the duration of the project. More specifically, recipients will provide progress reports with each claim for payment.
The OPC reserves the right to publish the name of your organization, as well as the amount of the contribution awarded in any manner it deems fit including, but not limited to, posting on the OPC's web site, publication in the Main Estimates, and so forth.
Top of PageTable of Contents5.3 Method of Payment
Payment will be in accordance with the approved cash flow as well as the work plan, and will be consistent with the Treasury Board guidelines for cash payment under the Policy on Transfer Payments. See http://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=13525.
Final payment of the hold back, not exceeding 20 per cent of the total contribution, or recovery of surplus, if necessary, will be made when the recipient has satisfied all the requirements of the project and on receipt and acceptance by the OPC of financial statements.
Payments will be made on the basis of documented claims for reasonable eligible costs incurred, to be submitted by recipients as per the Agreement.
The Privacy Commissioner may make advance payments, further to a review of the project's budget, not exceeding 20 per cent of the total contribution, where it is necessary for the success of the project. When such advances are made, they will be made in accordance with the Treasury Board Policy on Transfer Payments.
Contributions are normally awarded for specific projects on an annual basis. In the case of projects extending over more than one year, payment is subject to the appropriation of funds by Parliament, and satisfaction of review and reporting requirements by the recipient, in accordance with the terms and conditions of the Contribution Agreement.
Top of PageTable of Contents5.4 Public Acknowledgement and Recognition
The recipient shall acknowledge the Privacy Commissioner of Canada's contribution to the project in all materials, be they written, oral or electronic, used to describe the project to the public and within his/her own community. The Privacy Commissioner, or a designated representative of his Office, will be given the opportunity to participate in a public announcement of the project.
Top of PageTable of Contents5.5 Audit Requirements
According to the Contribution Agreement, your organization shall keep proper books, accounts and records of revenues and expenses received in connection with the funded project. Such accounts and records shall be open to audit and inspection by the OPC to ensure compliance with the terms of the Contribution Agreement. The OPC may make copies and take extracts at all reasonable times for a period of six years after completion of the project.
The OPC may request at any time that recipients provide satisfactory evidence to demonstrate that all eligible costs claimed have been paid.
Top of PageTable of Contents5.6 Recovery
Where for any reason:
- a recipient is not entitled to the contribution, or
- the amount of the contribution exceeds the amount to which the recipient is entitled,
the amount of the contribution or the excess, as the case may be, constitutes a debt to Her Majesty the Queen in Right of Canada and will be recovered as such from the recipient.
The Contribution Agreement will specify events of default, including failure of the recipient to comply with the terms and conditions of the Agreement, and set out the remedies for the Privacy Commissioner on default, including:
- suspend or terminate any obligations of the Commissioner to contribute or continue to contribute to the eligible costs of the project, including any obligation to pay any amount owing prior to the date of such suspension; and
- require the recipient to repay all or part of the contribution forthwith to the Office, that amount being a debt due to Her Majesty the Queen in Right of Canada.
Top of PageTable of Contents6. Language Policy
Project deliverables may be produced and/or submitted in the Official Language of your choice. Organizations working at the national level and receiving substantial financial assistance from the OPC are encouraged to provide services in both English and French and to foster the recognition and use of those languages especially in areas of significant demand recognized by the Office.