The Cybertip.ca website (the “Website”), is to facilitate reports to and provide the public with information about Canada’s national tipline for the reporting of online child sexual exploitation. It is owned and operated by the Canadian Centre for Child Protection Inc. (the “C3P” or “we”). C3P is a registered Canadian charity dedicated to the personal safety of all children. The goal of C3P is to reduce child victimization by providing programs and services to the Canadian public. One of C3P’s programs are the services offered through this Website, namely receiving and addressing reports of child sexual abuse material (“CSAM”), referred to as “child pornography” in the Criminal Code (Canada), online luring, travelling to sexually exploit a child, trafficking a child, commercial sexual exploitation (children sexually exploited through prostitution), making sexually explicit material available to a child, and making an agreement or arrangement to commit a sexual offence against a child.
Federal privacy legislation in Canada, currently the Personal Information Protection and Electronic Documents Act (PIPEDA), applies to Personal Information that is collected, used and disclosed in the course of commercial activities. This Website is not operated in the course of commercial activities; it is not operated for commercial purposes; and C3P does not consider the collection, use and disclosure of Personal Information obtained through the Website to be a commercial activity. C3P nonetheless believes that maintaining the privacy of your Personal Information is of the utmost importance and accordingly it adheres to the spirit of PIPEDA (or any subsequent law passed to replace PIPEDA) in its operation of this Website.
This Policy applies to activities carried on by C3P in relation to this Website. This Policy applies to visitors of the Cybertip.ca website only.
C3P may update this Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.
Definition of Personal Information
Personal Information is any identifiable information about an individual, including: name, email address, mailing address, and telephone number. Personal Information does not include aggregated or anonymized information that cannot be associated with a specific individual, directly or indirectly.
What information we collect
The Personal Information collected by C3P through this Website may include name, email address, or other contact information and information related to the sexual abuse or exploitation of a child. In addition to the foregoing we collect information from the device used to access the Website, such as web browser details, time zone or any other information to gather broad, aggregated demographic information (such as geographical, domain and ISP information). Once the demographic information is obtained, the IP address is deleted unless C3P detects an attempt to compromise the security or availability of the Website, where reporting patterns indicate that the reporting process or features are being abused; where we have reasonable grounds to believe that a user has intentionally supplied false or misleading information; or a user is or may be involved in unlawful activities involving the sexual exploitation of children; or a child(ren) may be at risk.
We collect Personal Information from an individual reporting or providing the information through the reporting form and using the following technologies: “Cookies”, which are data files that are placed on your device or computer and often include an anonymous unique identifier. Session Cookies are used to gather some of the information and some of the information is delivered automatically by your computer. Where a session Cookie is used, it only provides information about the visit to our Website. Statistics Cookies (also known as performance cookies) are used to collect information about how visitors to the Website use the Website, like which pages visitors visit and which links visitors click on. Statistics Cookies cannot be used to identify you as the system used to collect website analytics data discards IP address information, and is not correlated to information submitted through the report form. Their purpose of collecting such information is to improve the Website and how it functions.
How we use the information we collect
C3P collects Personal Information to:
- process, and forward reports of online child sexual exploitation to law enforcement, child welfare and organizations acting in the public interest against child sexual abuse, such as the National Center for Missing and Exploited Children (who may then facilitate reporting to law enforcement in their jurisdictions), consistent with our role as the national tipline for the reporting of online child sexual exploitation, and our role as the designated agency under the Child Pornography Reporting Regulation (Manitoba) and the Internet Child Pornography Reporting Regulations (Canada);
- provide the Canadian public with accessible information, education and resources on the issue of online child sexual exploitation and the protection of children, and receive request for and provide supports to Canadians concerned about online child sexual exploitation and the protection of children;
- if a user signs up for C3P’s mailing list, communicate updates to the content posted on Cybertip.ca, media releases, Cybertip.ca Alerts, and other information that C3P believes may be of interest;
- receive requests for, and provide supports to, Manitobans under The Intimate Image Protection Act (Manitoba);
- understand user requirements and make information readily accessible and available to users;
- perform research and generate statistical reports on the online sexual exploitation of children or related issues; and
- meet legal and regulatory requirements.
Storage and Data Retention
All electronic files related to this Website are stored on C3P owned servers located in Canada and operated by C3P.
When an individual makes a report on the Website, we will maintain the individual’s Personal Information (if provided) and the information in the report for our records for as long as is reasonably necessary to fulfil our role as the national tipline for the reporting of online child sexual exploitation and the protection of children.
C3P has processes in place ensuring the security of the Personal Information, which include:
- Collecting information that is necessary for C3P to fulfill its obligations under federal and provincial legislation.
- Only disclosing Personal Information to C3P personnel who have a need to access the Personal Information and ensure that all such personnel are bound by confidentiality obligations.
- Disclosing Personal Information received as a Cybertip report to law enforcement or child welfare when applicable.
- Maintaining and installing appropriate physical, organizational, and technical controls designed to ensure the security, integrity and confidentiality of Personal Information accessed, collected, used, stored, or transmitted to or by C3P and to protect against unauthorized or unlawful disclosures, transfers, breaches, access to or processing of the Personal Information and against accidental loss or destruction.
- Other technical processes and procedures that are necessary to ensure the privacy and security of all Personal Information stored on C3P’s system.
From time to time, anonymized or de-identified report information may also be disclosed to trusted third parties who are bound by contractual obligations to use such information solely for the purpose of analysis and research, typically in aggregated format.
Knowledge and Consent
All Personal Information is collected as set out in this Policy and only for the purposes set out in How we use the information we collect above.
Reports made to Cybertip.ca may be anonymous or users can choose to include their Personal Information, such as contact information. If a report is provided over the phone, all information that the caller provides to the analyst is entered by the analyst into the same type of report form that a visitor to the Website would use. The phone line that is set up to receive public reports does not collect or receive caller identification information.
Sharing your Personal Information
If Personal Information (such as contact information) is contained in a report, we may share that Personal Information with law enforcement, child welfare, a designated hotline or other third parties where applicable (for example, if we have grounds to believe an individual may be at risk, we may share Personal Information with emergency services). Personal Information shared as part of a report, forms part of the report, and may be shared along with the report sent to appropriate law enforcement, child welfare or a designated hotline. The reason contact information is disclosed to law enforcement and child welfare is so that the reporting person can be contacted by the appropriate law enforcement or child welfare agency for more information if needed. The reason contact information is disclosed to a designated hotline is so that hotline can fulfill its role in providing report information to law enforcement or child welfare in its own jurisdiction.
The appropriate law enforcement or child welfare agency is any agency that has jurisdiction or authority to investigate the matter (for example, because the alleged suspect, victim or apparent host of the content/provider of the communication platform, is reasonably believed to be within their jurisdiction). A designated hotline means a hotline in any foreign country that has the mandate within that country to accept, process and forward reports of online child sexual exploitation to the appropriate authorities within their jurisdiction. A designated hotline may receive a report where the alleged suspect, victim, or content/platform of concern is believed to be located within their jurisdiction.
In addition, for security purposes and to ensure this service remains available to all users, we may disclose information to the appropriate law enforcement or child welfare agency(ies) where we detect an attempt to compromise the security or availability of our website, where reporting patterns indicate that the reporting process may be or is being abused by a user; and whenever we have reasonable grounds to believe that a user has intentionally supplied false or misleading information; a user is or may be involved in unlawful activities involving the sexual exploitation of children; or a child or children may be at risk.
With respect to research activities, most research is performed internally; however on occasion C3P may either a) engage external experts to assist or conduct research on C3P’s behalf; or b) provide external researchers with access to de-identified or anonymized data. This occurs only after reasonable contractual and technical safeguards are put in place to protect the information from unauthorized access, use and disclosure. Any such information shared is limited to that which is reasonably necessary to accomplish the research objective.
Statistical information about the use of the Website and the reports submitted to the Website may be anonymized, aggregated and included in public reports issued by C3P, however personally identifying information will not be shared in any public report or research report.
A report number is displayed to a user once a report has been submitted and the user can record and retain that number to establish to a third party that he or she submitted a report if needed.
If a reporting person included his or her contact information within a report and thereafter contacts C3P with a report number, C3P may be able, after verifying the reporting person, to confirm that a report bearing that number was received and confirm the date and time that such report was received. However, to protect the integrity of the reporting process, to guard against the release of information about where illegal content may be found, and to ensure that any potential investigation into the matter reported is not jeopardized, C3P will not divulge any other details about the report. For example, information such as what information the report contained, whether the report was forwarded to law enforcement or child welfare, or whether the website or other information reported did or did not contain illegal images is not provided to any person other than law enforcement, child welfare, or a court of competent jurisdiction that orders the release of such information. Exceptions may be made in limited circumstances upon consultation with the appropriate law enforcement or child welfare agency.
You may request removal from our email mailing list at any time by contacting us through the Contact Us page accessible from https://www.cybertip.ca/en/contact with the subject line “remove from mailing list”. Instructions for removal from the mailing list will also be set out in each email communication you receive from us.
Residents Outside of Canada
Cybertip.ca operates within Canada, and is geared to a Canadian audience. It accepts reports regarding potential online child sexual abuse or exploitation from the Canadian public, assess if such reports pertain to activity that is illegal and if so, forwards the reports to the entity or entities with jurisdiction to take action, which often means law enforcement — see above for details.
The vast majority of reports to Cybertip.ca pertain to online child sexual abuse material (CSAM), which is illegal to access, possess, produce, distribute and make available in Canada. In most instances, C3P does not know the identities of the children depicted in CSAM, and does not know the country within which such individual(s) may reside. C3P does not offer services to residents outside of Canada either through Cybertip.ca or otherwise, but acknowledges that a non-Canadian resident may be depicted in CSAM assessed by Cybertip.ca, that persons from outside Canada may from time to time visit the websites of C3P, and that organizations acting in the public interest against child sexual abuse and law enforcement outside Canada may receive information from the operation of Cybertip.ca. Accordingly, to the extent any information processed through the Cybertip.ca program may be considered Personal Information about an individual outside Canada:
- the purpose for collecting and processing such information, and sharing it with law enforcement and organizations acting in the public interest against child sexual abuse when needed is to safeguard a particular child or children generally, reduce and prevent the online sexual exploitation of children, and reduce the public availability of CSAM, activities that C3P believes are in the interest of vulnerable and abused children, is a legitimate interest pursued by C3P, and is in the public interest.
- the information processed includes CSAM and related information such as hash values pertaining to said CSAM; information that may be included by a reporting person in a report submitted to Cybertip.ca; and information generated as a result of processing such report.
- data collected, stored or processed through Cybertip.ca is stored on C3P owned servers in Canada.
Technical and security safeguards are set out above.
Questions and Concerns
If you have any questions or concerns about our privacy practices, please send a letter outlining your concerns to:Privacy Officer
Canadian Centre for Child Protection Inc.
615 Academy Road, Winnipeg, Manitoba R3N 0E7
You may also submit your question by contacting us through the Contact Us page accessible from https://www.protectchildren.ca/en/privacy-policy/privacy-contact/.