Privacy Impact Assessment - N-III Police Information Portal (PIP) Component

Executive Summary

Introduction

This report is a Privacy Impact Assessment (PIA) for the Police Information Portal (PIP) component of the National Integrated Interagency Information System (N-III) initiative. The N-III initiative is envisaged as being a national, horizontal gateway, or pipeline, linking individual, autonomous information systems from the public safety and security (PS&S) sector nationally.

The RCMP is the steward of an information technology project with two technology components:

• the PIP which promotes information-sharing nationally among law enforcement agencies; and
• the Integrated Query Tool (IQT) or a system-to-system interface which extends that capability to federal government departments and agencies having a safety and security mandate.

RCMP officials met with representatives of the Office of the Privacy Commissioner on July 5th, 2005 and discussed how the N-III initiative will provide the PS&S sector (comprised of accredited law enforcement agencies and federal institutions with a safety and security mandate) the ability to access and exchange criminal and investigative information. Additionally, the RCMP was invited to attend the Federal, Provincial and Territorial Privacy Commissioners Annual Meeting in Toronto in January 2006 to explain the N-III initiative and respond to inquiries regarding this interagency information-sharing solution.

This PIA also describes the evolution of the requirement for an information-sharing environment for improving safety and security outcomes across Canada. This program information is provided for both clarity and context. The two technical components of the current RCMP project are named and described, however the contents of this report outline the global security and privacy considerations being afforded to the PIP implementation and focus only on the accredited law enforcement agencies that will participate. PS are undertaking an overarching PIA that will describe federal information-sharing solutions created under N-III.

Law enforcement agencies have in the past exchanged information in traditional manners; either over the phone, by fax or through written requests. Processing such requests through other agencies becomes detrimental at times due to both delays in responses as well as the inability to obtain pertinent information from multiple sources. World events such as the terrorist attacks in the United States on September 11th, 2001 as well as the bombings which occurred in Madrid, Spain and London, England have precipitated the need to deliver an interoperable solution to all police partners that will enable controlled sharing and timeliness of information. The ability to create an environment that is conducive to the PS&S sector will aid in the prevention and suppression of crime. The RCMP has, with the consensus of the law enforcement community, committed to develop and deliver sound and secure technological solutions.

Background

The need for an interoperable information-sharing environment evolved out of “systemic weaknesses” which often make it impossible for PS&S institutions from different jurisdictions to share their information, thus affecting their ability to collaborate effectively. With few exceptions, information is not discoverable or accessible electronically, making it difficult and often impossible for PS&S practitioners to have the information they require to make the most informed, timely decisions. With the globalization of crime, emergent asynchronous threats, increased mobility and new criminal alliances, the information-sharing model is outdated.

The need to address the issue evolved into a Government of Canada (GoC) commitment to taking information out of "stovepipes" to make it discoverable, accessible, understandable and useable across the PS&S sector. The idea manifested the concept of the creation of a Canada Public Safety Information Network (CPSIN), which aimed to create an ordered environment in which technology would enable information to be shared electronically in support of PS&S business processes in Canada. This led to the adoption of N-III as a CPSIN initiative for improving collaboration.

The original CPSIN planning assumptions foresaw a further evolution of the original N-III components to extend the building blocks to more partners and to address remaining information gaps and barriers. Future new projects under the umbrella of the N-III initiative will provide richer functionality by incorporating advances in technology, address systemic issues to improve interoperability, optimize exchange arrangements through technical compatibility and address the ever-changing business needs. N-III, as an initiative, remains critical to the plans of the GoC for improving interoperability to bridge the many remaining information gaps and overcoming barriers to information-sharing.

The Police Information Portal (PIP) Component

The implementation of PIP comes out of current technology that has been in use in both British Columbia and Ontario. The Law Enforcement Information Portal (LEIP) allows police agencies in these provinces to access all index information contributed by the participant agencies. With the well-established LEIP in place within these provinces, the ability to adopt this concept and apply it to all Canadian police forces is limited unless a solid infrastructure is built and is sustainable over time. The RCMP has undertaken a lead role to develop the technical solution (PIP) which will replace the current LEIP that currently resides in BC and Ontario.

The LEIP brand name is specific to a vendor and the development of a national police solution should be vendor independent. The Canadian Association of Chiefs of Police have agreed that this is necessary and, as such, identified that this search portal would be renamed PIP from LEIP. Notification to the vendor of this name change was provided. The PIP, as it will now be known, will become the standard CACP police portal name.

The PIP will be utilized by accredited law enforcement agencies (defined as Category I by the Canada Police Information Centre) to access all published information provided by participant agencies. This is based on the authority of their common law police powers. The PIP affords an information-sharing environment in which no one Records Management System (RMS) is directly connected to another. The PIP portal sits among all participants, acting as an information search engine and request broker. Individual agencies decide what information they want to make available to other law enforcement agencies, while retaining ownership of the data. The portal contains only an index of information and not the contents of an electronic record. This ensures that law enforcement agencies must confirm with the originator to verify the accuracy of the information and to obtain consent prior to its use or disclosure.

An agreement is vital to ensure that all law enforcement agencies agree to the principles governing the use of such a system. The Police Information Portal Protocol, which is signed by each agency’s Chief of Police, indicates acceptance of the terms and conditions set out for use of the system. It lays out the policies of information-sharing, responsibilities and the general security rules associated with the system. Furthermore, the signatory agrees to respect all privacy principles regarding the collection, use, disclosure, retention and disposal of personal information as stated in federal and provincial privacy legislations. Furthermore, a PIP Policy and Directives document has been created that contains policies and procedures governing the use of the PIP. Founding principles have been established for the system and will be subject to additions, deletions or modifications as the program evolves.

The primary PIP application and database servers will be located in the RCMP data centres. These facilities meet the RCMP requirement for housing Protected "B" information which includes restricted physical access controls and alarm monitoring. Only RCMP employees and contract staff with RCMP Top Secret security clearance, or individuals being escorted by RCMP employees with Top Secret security clearance are permitted access to this facility. Only staff with a specific and regular requirement to access the data centre are given direct access, staff who require only occasional access must be granted access by data centre staff, and they must sign in and out. A second RCMP data centre in Ottawa will be used to implement a secondary PIP application and a system to support disaster recovery will be put in place.

The PIP uses transaction logs, and thus has an audit trail capability, even though it is not a Records Management System. The PIP transaction log will electronically record user activities on the system and thereby provides the capacity to enable access to information requests (ATIP) to be processed.

The PIP implementation will provide a secure centralized environment sustainable over time and permit efficient nation-wide interagency exchange of information. The creation of a PIP National Governance Committee will oversee the PIP, Participant Agency membership and participation therein. Conditions for the collection, use, disclosure, retention and disposal of personal information are defined in the PIP Protocol. Auditing and quality assurance activities will be implemented into each agency’s business processes. Personnel security will be tightly controlled through the requirement of each user to have an RCMP Enhanced Reliability Status (Operational) or equivalent security clearance. Physical and IT security standards will define an agency's responsibility to protect information from unauthorized access, use or disclosure. The diverse records management systems that are currently in use by law enforcement agencies will become interoperable as participants adapt their RMS to be compatible with the PIP. This approach will preserve the investment that agencies have in their systems and remove barriers to sharing that exist where there is an expectation to change systems. The outcome of the PIP implementation will be a more effective method of sharing criminal and investigation information, thereby effecting a more efficient utilization of resources to detect, prevent and suppress crime. This will benefit Canadians globally.