Virtual Trade Commissioner
Executive Summary
The Trade Commissioner Service of the Department of Foreign Affairs and International Trade (DFAIT) provides “In Market Assistance” to experienced exporters and Canadian companies who have researched and targeted their markets. The Trade Commissioner Service’s role is to promote the economic interests of Canada abroad through activities such as export market development, foreign direct investment in Canada, science and technology networking and international research and development (R&D) collaboration.
To promote the economic interests of Canada in the global marketplace, Trade Commissioners play a key role in providing market intelligence and building key relationships between Canadian clients and foreign contacts and networks. Trade Commissioners may best be described as “relationship builders and knowledge brokers”. Participation in the Virtual Trade Commissioner is voluntary. Information such as company name, address and contact information is collected in order to facilitate client access to market reports and other services of the Virtual Trade Commissioner, assist Canadian companies in developing their business abroad, assist international business to invest in Canada and find alliances with local business, and to conduct surveys and produce invitations to events organized by the Department.
The Virtual Trade Commissioner is a customizable, online tool, which provides access to business leads, sectoral news, timely market and sectoral information, contacts and services according to a Canadian company’s specific international needs. This free tool is a single–service window to personalized export services 24 hours a day, 7 days a week.
The Virtual Trade Commissioner provides direct access to over 900 Trade commissioners in Canada and abroad. Companies can register online at
A Privacy Impact Assessment (PIA) was developed for the Virtual Trade Commissioner (VTC) service provided by the eServices Division of Trade Commissioner Services (TCS), Department of Foreign Affairs and International Trade (DFAIT). The PIA was designed to:
- Describe and document what personal information is collected on the Virtual Trade Commissioner (VTC), how it is collected, the use, management and stewardship, disclosure, and measures taken to protect the personal information.
- Identify and assess the privacy risks associated with the VTC service and to related risk mitigation measures.
- The privacy assessment found two minor privacy issues that the VTC needs to take under consideration for long–term treatment of personal information:
- Canadian Trade Commissioners receive non–Canadian business contact information through in–person meetings. The information is collected with consent of the individuals in order to promote their business and investment in Canada. While the non–Canadian businesses are not provided access to VTC, DFAIT maintains this information in a segregated database (TRIO) in which the Department strictly enforces the Privacy laws and policies of Canada, including appropriate retention and disposition procedures.
- Internal Departmental tools provided to Trade Commissioners using the VTC are unable to maintain an extensive audit trail. DFAIT is investigating the cost and feasibility of implementing an audit trail for information accessed by internal employees and Federal Government partners. While there is no short–term solution to implementing such a mechanism, the Department has undertaken privacy awareness training for those employees who use the system to provide service to Canadian and non–Canadian businesses.
Privacy Risk Mitigation
This section summarizes the specific privacy risks that have been identified through the PIA process, and lists the mechanisms to mitigate these risks. Although a number of mitigation strategies are discussed, they are alternatives, and implementation of all strategies is not necessarily required to address specific privacy risks. The nature and extent of any residual risks following implementation of mitigation strategies cannot be determined at this stage, as it unknown how and to what extent mitigating mechanisms may be deployed.
- Accountability
No risks were identified. - Collection of Personal Information
Canadian Trade Commissioners receive non–Canadian business contact information through in–person meetings. The information is collected with consent of the individuals in order to promote their business and investment in Canada. While the non–Canadian businesses are not provided access to VTC, DFAIT maintains this information in a segregated database (TRIO) in which the Department strictly enforces the Privacy laws and policies of Canada, including conformity with the appropriate retention and disposition procedures.
The Department has undertaken privacy awareness training for the Trade Commissioners and the Locally Engaged Staff who provide service to Canadian and non–Canadian businesses.
The eService Division is currently conducting a study on the feasibility of generating an automated e–mail acknowledgement to non–Canadian audiences in 50+ different languages, supported by local trade commissioners and locally engaged staff every time a non–Canadian company is registered with VTC TRIO.
Pending the outcome of the study, the Trade Commissioner Services (TCS) may seek a legal opinion regarding the obligations of the Department with respect to maintaining company information, including contact names of non–Canadian business contacts that have provided their information with consent, for the purposes of maintaining a relationship and contact with the Department.
- Consent
No risks were identified. - Use of Personal In formation
No risks were identified. - Disclosure and Retention of Personal Information
No risks were identified. - Accuracy
No risks were identified, - Safeguards
Internal Departmental tools provided to Trade Commissioners using the VTC are unable to maintain an extensive audit trail. DFAIT is investigating the cost and feasibility of implementing an audit trail for information accessed by internal employees and Federal Government partners.
While there is no short–term solution to implementing such a mechanism, the Department has undertaken privacy awareness training for those employees who use the system to provide service to Canadian and non–Canadian businesses.
- Openness
No risks were identified. - Individual Access
No risks were identified. - Challenging Compliance
No risks were identified.
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