Annual report to Parliament on the application of the Privacy Act 2024–25

Place du Centre, 4th floor
200, promenade du Portage
Gatineau QC  K1A 1K8

October 07, 2025

The Honourable Dominic LeBlanc, P.C., M.P.
Minister of Internal Trade
President of the King’s Privy Council for Canada
Minister responsible for Canada–U.S. Trade, Intergovernmental Affairs and One Canadian Economy
House of Commons
Ottawa, Ontario  K1A 0A6

Dear Minister:

In accordance with section 72 of the Privacy Act, the Transportation Safety Board of Canada is pleased to submit to Parliament this report on its activities relating to the administration of the Act for the period 1 April 2024 to 31 March 2025.

Sincerely,

Original signed by
Yoan Marier
Chair

1. Introduction

The Transportation Safety Board of Canada (TSB) is pleased to table in Parliament this report on its activities relating to the administration of the Privacy Act (PA) in keeping with section 72 of the Act. The report covers the period from 1 April 2024 to 31 March 2025.

The Privacy Act protects the privacy of individuals with respect to personal information about themselves held by government institutions such as the TSB, by defining the requirements for the collection, retention, disposition, use and disclosure of personal information. The Act provides individuals and their authorized representatives with a right to access, correct or add a notation to their information.

The Canadian Transportation Accident Investigation and Safety Board Act provides the legal framework that governs the TSB’s activities. Our mandate is to advance transportation safety in the air, marine, pipeline and rail modes of transportation by:

• conducting independent investigations, including public inquiries when necessary, into selected transportation occurrences in order to make findings as to their causes and contributing factors;
• identifying safety deficiencies, as evidenced by transportation occurrences;
• making recommendations designed to eliminate or reduce any such safety deficiencies; and
• reporting publicly on our investigations and on the findings in relation thereto.

More information on the TSB is available at tsb.gc.ca.

The TSB fulfills its obligations regarding the administration of Access to Information and Privacy (ATIP) by following the principle that government information should be available to the public with only specific and limited exceptions, in keeping with established Government of Canada principles. Furthermore, the TSB treats personal information in compliance with the code of fair information practices expressed in the Privacy Act.

Both English and French versions of this report have been submitted and tabled to Parliament.

2. Organizational Structure

The Director General of the Corporate Services Branch holds the responsibilities of the ATIP Coordinator, and is also the Chief Information Officer (CIO), the Chief Privacy Officer (CPO), and the Open Government Coordinator (OGC).

The ATIP Office reports to the Director General of the Corporate Services Branch and includes one (1) intake officer, three (3) ATIP analysts and 1 (one) ATIP manager. Temporary help was provided by a consultant.

The ATIP Office ensures that the TSB meets the requirements under the Access to Information Act and the Privacy Act by:

• centrally administering both formal requests made pursuant to the Act and informal requests,
• providing functional advice and guidance to employees concerning the managing of information and protection of privacy under the TSB’s control,
• conducting and responding to consultations with requesters, third parties, TSB employees, and representatives of the Offices of the Information and Privacy Commissioners,
• delivering ATIP training and awareness,
• conducting privacy impact assessments (PIAs),
• documenting and managing privacy breaches,
• communicating with the Treasury Board of Canada Secretariat and the offices of the information and privacy commissioners of Canada about policy and legislative requirements, complaints, and investigations.

The ATIP employees require considerable expertise in the processing of requests, and they are responsible for centrally reviewing and severing all records to uphold the integrity of TSB investigations while balancing the need to comply with the ATIA and Privacy Act. The analysts remain current with the investigation operations of the various transportation modes and their activities, and maintain good working relationships with the investigators and a multitude of stakeholders.

3. Designation Order

The head of the institution as defined in section 3 of the Act is the Chair of the TSB. The delegation of authority was updated in April 2024.

The Chair delegated under section 73 of the Privacy Act, full powers to the ATIP Coordinator and some powers to the ATIP Manager for the effective administration of the Act. These employees ensure that the TSB meets all its obligations fairly and consistently. A copy of the Delegation Order is attached at Appendix A.

4. Performance 2024–25

Privacy requests received by the TSB are mainly from Canadian airline pilots inquiring as to whether they are named in any occurrences reported to the TSB. The reason for this is that certain international airlines request this information as a pre-employment requirement. As well, some employees request access to their personal information.

Completed formal requests and their trends

The ATIP office received thirty-two (32) new requests under the Privacy Act in the 2024–25 reporting period and one (1) request was outstanding from the previous reporting period. In comparison, during the 2023–24 reporting period, the ATIP office received twenty-five (25) formal requests for personal information, compared to fourteen (14) formal requests in the 2022–23 reporting period, ten (10) in 2021–22, and twenty-two (22) in 2020–21.

Active formal requests

One (1) request was active at the end of the 2024–25 reporting period and was carried over to next fiscal year. The request was processed within the legislated timeline.

Complaints on formal requests

The Office of the Privacy Commissioner of Canada has not notified the TSB about any complaints on its files under the Privacy Act.

Extensions of formal requests

The ATIP Office has not extended any of the processed files under section 15 of the Act.

Consultations from other institutions on formal requests

The ATIP Office did not receive any consultations from other institutions on formal requests submitted under the Privacy Act in the 2024–25 reporting period.

Disposition of formal requests

Of the thirty-two (32) requests closed in 2024–25, the TSB fully disclosed records in three (3) cases (9.5%), disclosed records in part in three (3) cases (9.5%), records did not exist in twenty-five (25) cases (78%), and one (1) case (3%) was abandoned. Of the requests closed during the reporting period, the ATIP Office completed thirty-one (31) within 1 to 15 days and one (1) within 16 to 30 days.

During this period, the ATIP Office was involved in the search, processing, and review of one hundred and thirty-nine (139) pages of information and disclosed one hundred and thirty-nine (139) pages with some redacted portions under section 26, as personal information of other individuals. In 2023–24, the ATIP Office reviewed eighty-six (86) pages of information, and disclosed seventy-six (76). In 2022–23 eleven (11) pages were reviewed and all eleven (11) pages were released. In 2021–22, seven hundred eighty-four pages (784) were reviewed and two hundred ninety-two (292) pages were released. The variation in the number of pages reviewed between years is due to the different type of requests received and if requests are from employees requesting access to their personal information.

Other performance information

The ATIP Office makes every reasonable effort to process requests within the 30-day time limit as required by legislation. The ATIP Office succeeded in completing one hundred percent (100%) of the requests within the timelines required by law in 2024–25.

The TSB allows disclosing informally personal information to its employees without filing formal requests under the Privacy Act. The TSB Human Resources employees handle these requests as part of their duties. The TSB remains vigilant in meeting requirements under the Privacy Act to protect personal information under its control. This is achieved by ensuring that TSB Human Resources employees are cognizant of their responsibility to protect personal information they handle in the course of their duties and by respecting the code of fair information practice enshrined in the legislation.

5. Training and Awareness

The TSB has an orientation program in place for new employees, which includes training on ATIP awareness. The ATIP manager delivers comprehensive ATIP training sessions at the TSB that are mandatory for all staff. During the 2024–25 fiscal year, the ATIP manager updated the training on access to information and privacy at the TSB to add a new training module to reflect the current ATIP legislation and policy instruments. In addition, new TSB employees are required to take the course “Access to Information and Privacy Fundamentals” offered by the Canada School of Public Service (CSPS) as a prerequisite for the ATIP training session delivered by the ATIP manager.

Twenty-eight (28) people took the CSPS courses related to ATIP and the ATIP manager delivered three (3) training sessions on ATIP in the 2024–25. Two sessions, one in English and one in French, were for the new employees (17 participants) and one bilingual session was for branch employees (23 participants) tailored to their needs. In addition to this, the ATIP employees provided informal training and advice to TSB employees, as needed.

6. Policies, Guidelines, and Procedures

In the 2024–25, the TSB created a new internal web page dedicated to access to information and privacy. This new web page consolidates all of the ATIP related information needed by TSB employees including processes for handling requests, making a request for their own personal information, roles and responsibilities in requests for information, privacy at the TSB, training on ATIP and all related links to legislation, policy instruments, oversight Commissioners and other links.

The ATIP Office also created additional procedures related to privacy breaches, third-party consultations, employees’ personal information in ATIP files, ATIP repositories, publishing of the ATI summaries on Open Government, and the organization of records. These instruments guide the ATIP Office analysts in processing the files and ensures consistency.

7. Initiatives and Projects to Improve Privacy

During the 2024–25 reporting period, the TSB continued using and refining its new tracking system, ATIP Xpress (AX), previously adopted. All the 2024–25 ATIP requests were processed using the new tracking system.

Other initiatives to improve access to information include conducting a comprehensive review of guides and templates with input from internal stakeholders and the TSB Legal team.

8. Summary of Key Issues and Actions Taken on Complaints

No complaints were received by the Privacy Commissioner in 2024–25 related to the TSB’s privacy requests.

9. Material Privacy Breaches

The TSB did not have any material privacy breaches during the 2024–25 reporting period.

10. Privacy Impact Assessments (PIA)

The TSB initiated a Privacy Impact Assessment (PIA) during the 2023–24 reporting period to update its original 2005 assessment. Advances in technology, changes to information management systems, and revised policy instruments prompted the need for this update. The revised PIA aims to identify and mitigate privacy risks associated with the TSB’s investigation program.

11. Public interest disclosures

The TSB did not disclose any personal information in the public interest pursuant to paragraph 8(2)(m) of the Privacy Act during the 2024–25 reporting period.

12. Monitoring Compliance

The TSB monitors the access to information program through weekly bilateral meetings between the ATIP Coordinator and the ATIP Manager. During these meetings, the ATIP Manager regularly debriefs the ATIP Coordinator on the status of the outstanding requests, any issues related to ATIP, and also seeks the approval of the completed files. The ATIP Coordinator then debriefs the Chief Operating Officer on any significant issues. The ATIP Manager meets regularly with each ATIP analyst regarding the ongoing processing of requests.

The statistics required by the Treasury Board Secretariat are found at Appendices B and C.