Executive Summary: Chain of Trust Privacy Impact Assessment

From: Canada Border Services Agency

The global outbreak of the COVID-19 pandemic introduced new travel restrictions in countries around the world, elevating the need for additional border requirements. Prior to the pandemic, air travel volumes were increasing at a steady pace, and over the next several years they are expected to return to pre-pandemic levels and potentially increase. To address emerging risks and responsibilities, the Canada Border Services Agency (CBSA) is exploring ways to provide self-service options for travellers to facilitate the free flow of persons and goods through the international border clearance process. This will contribute to a low-touch air travel ecosystem that supports the recovery of travel and tourism industries and promotes the economic prosperity and health of Canadians while continuing to support national security and public safety.

As part of planning for Traveller Modernization, the CBSA is moving towards a risk-based compliance model using technology and intelligence to provide the information needed to expedite the flow of legitimate goods and people. High-touch and manual processes often create long delays and congestion in Customs Halls for travellers and, at the same time, irregular migration, international organized crime, and terrorism continue to dominate the global landscape.

The Chain of Trust (CoT) pilot project tests innovative technology solutions to assess their effectiveness in automating the collection and verification of traveller information and the authentication of travel documents while reducing physical touch-points in the border clearance process. To eliminate the need for physical handling of documents or interaction with a kiosk upon arrival at an airport, volunteer participants provide their information electronically in advance of their arrival using a mobile app. This is expected to reduce congestion in primary inspection lines (PIL) and minimize the risks of virus transmission, particularly in airports where volumes could exceed capacity. Furthermore, CoT enables a more flexible and dynamic operational model for BSOs facilitating the border clearance process.

From 2018 to 2021, the CBSA worked in collaboration with the Canadian Safety and Security Program (CSSP), private partners and airport authorities to create a CoT prototype. The goal was to develop a solution entirely for demonstrative purposes and test it in a staged environment that could explore the end-to-end processes and technologies that are necessary to enable a low-touch self-service option for travellers. It was also designed to enhance the quality of risk assessments, with the purpose of identifying low-risk travellers and facilitating their “low-touch” movement through the international arrival process at an airport.

In March 2021, CoT was successfully tested over four days as an initial minimum viable product (MVP) in a live operational setting at Toronto Pearson International Airport’s (TPIA) Terminal One (T1) to complete real transactions for a small number of volunteers. A CoT pilot was deployed in September 2021, building on the functionality of the first MVP. Additional technology, functionality and user experience improvements were introduced in November 2021.

121 volunteer participants, returning Canadian Citizens who are Air Canada crew members, enrolled in the CoT pilot between March 2021 and February 2022. The project is set to end live testing on March 11, 2022, when all CoT technology will be removed from the production environment.

If the project is successful, the CBSA will explore the feasibility of using proven production-ready concepts and technology tested through CoT for future deployment of CBSA initiatives to ports of entry in any mode (Air, Land, Rail or Marine) where operational requirements permit.

Protecting Personal Information

The following personal information elements are being collected from travellers participating in the CoT pilot project:

Traveller Profile

• Full name
• Gender
• Date of birth

Digital Travel Credential (DTC)

• Citizenship country
• Country and province of residence
• Identification/travel document
  • Document type
  • Issuing authority or office
  • Document number
  • Document expiry date
  • Document photo (biometric data)
• Facial photo taken at time of DTC creation (biometric data)

Trip Details

• Flight information
  • Airport of arrival
  • Trip origin
  • Flight number
  • Arrival date
  • Scheduled arrival time

Customs Declaration

• Duration of absence from Canada
• Value of goods purchased or received abroad
• Exceed Personal Exemption
• Cannabis Goods
• Food, Plant or Animals
• Currency or Monetary instrument > = $10,000
• Visited a farm and will visit a farm in Canada
• Firearms or other weapons
• Additional dynamic questions asked on behalf of other government departments (OGD) (e.g. COVID-19 screening)

Travellers participating in the CoT pilot are provided access to an app through which they submit their identity and travel information electronically to the CBSA in advance of their scheduled arrival

date/time. The recommended advance submission is up to 72 hours before arrival. Collecting information from travellers prior to their arrival assists the CBSA with scheduling of BSOs at certain checkpoints such as primary and egress.

Traveller information is made available to BSOs through an internal CBSA app accessible through the use of a smartphone. This app will provide BSOs with the ability to view a traveller’s recommendation and update it as necessary, re-directing them to the appropriate area in the border clearance process (i.e., payment of duties and taxes, referral for secondary examination, etc.).

In addition to the BSO app, a web-based Command Centre application is made available to CoT trained Superintendents an/or officers, to provide a high-level overview of the movement of CoT participants. The Command Centre maximizes efficiencies in traveller processing and enhances operational oversight by providing a holistic view of the status of travellers. Information is retained in the Command Centre for 24 hours after a traveller is released, after which all personal information is deleted from the application. Some information elements of a traveller’s passage will be retained in the CBSA’s passage history databases in accordance with existing retention policies.

Right of Access

While CoT introduces a new means of capturing information from travellers, the data to be collected is considered ‘customs information’, as defined under section 107 of the Customs Act, and is already collected by the CBSA. All data elements currently collected as part of a traveller’s passage history will be retained in CBSA databases and used for the purpose of establishing travel history information in compliance with the Privacy Act, Sections 4, 6, 7 and subsection 8(2). Additional information elements, including the traveller’s DTC, will be used to verify traveller identities and facilitate touchless processing upon arrival in Canada. This information will be stored temporarily in the CBSA Protected B cloud for 24 hours, during which time it may be used or disclosed to assist the CBSA's enforcement program or for program evaluation. Biometric information collected from Canadian travellers will not be shared with OGDs or international partners at any time. The traveller’s data will be deleted from the cloud database after this time period.

In accordance with the current legal framework, travellers participating in the CoT pilot are required to provide their informed consent for the collection, use, retention and disposition of their personal information through the mobile app.

Travellers participating in the CoT pilot project may formally request access to personal information, or access to corporate records related to or created by the project, by contacting the Information Sharing, Access to Information and Chief Privacy (ISATICP) Office.

Accountability

If a participant has concerns about the collection, use, disclosure or retention of their personal information, they may issue a complaint to the ISATICP Office of the CBSA. Complaints should be made in writing, and include the traveller’s first and last name, contact information, and a brief description of their concerns.