New Storage Model for the Management of CRA Records

November 7, 2012

Ms. Jennifer Stoddart
Privacy Commissioner
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville, Tower B, 3rd Floor
Ottawa ON  K1A 1H3

RE:   New Storage Model for the Management of CRA Records


Dear Ms. Stoddart,

I write to you as National President of the Union of Taxation Employees-PSAC (UTE), a Component of the Public Service Alliance of Canada. UTE represents approximately 26,000 members, all of whom are employed by the Canada Revenue Agency (CRA).

Recently, the CRA announced that as a result of Library and Archives Canada’s (LAC) decision to suspend record storage operations for 70% of CRA records, it will move to a new storage model whereby the CRA will eliminate the current requirement to store records on-site and will move towards utilizing the services of an external service provider. As a result, the CRA will discontinue the storage of paper records in CRA sites located in eleven cities across Canada dedicated to the management of paper tax and information returns and removes paper holdings from six LAC facilities.

In order to meet LAC’s cessation of services dates, a request for proposal has been posted and the contract to an external service provider will be awarded by the end of the 2013 calendar year. Once the contract is awarded, the CRA intends to move its paper holdings out of the CRA regional facilities to the external service provider by April 2014 and out of the LAC facilities and the CRA’s Headquarters facilities by June 2014.

The Union of Taxation Employees is deeply concerned (as I am as a private citizen) with this decision of the CRA. We submit that this is a devastatingly short-sighted move and one that is certainly not free from grave concern for the security of confidential and sensitive information. In an era of increased identity theft and selling of vital information, we suggest that this move to privatize the storage of confidential tax information will jeopardize the security and privacy of this information and will seriously erode the public’s confidence in the integrity of the tax system and its faith that their personal information is being safeguarded. Relatedly, this decision has been made without even letting the Canadian public know that their private and personal information will now be in the hands of a private, profit-driven firm.

For these reasons, the Union of Taxation Employees respectfully requests your intervention in this matter with a view to determining whether this initiative is offensive to the spirit, principles and provisions of the Privacy Act. I would welcome an opportunity to meet with you to further discuss this matter.

In Solidarity,
Robert Campbell's signature  

Robert Campbell
National President

c.c.    The Honorable Gail Shea
         Mr. Alexandre Boulerice
         Mr. Rodger Cuzner
         Mr. Hoang Mai
         The Honorable Scott Brison
         Mr. William Jones
         Ms. Robyn Benson