Hello All - I just submitted my online citizenship application today and I just noticed that, in the online application, it seems that the authorization question to give consent to IRCC to access CBSA records is not included in the application forms. Did I miss anything?! Is it somehow included / integrated as part of the application already? Thank you!
CBSA consent
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Another Edit to Note there are significant errors in this post . . . see later post (assuming I post soon).
Sometime ago there were changes in policy and practice, and some of the underlying law, which allows IRCC to directly access certain types of personal information held by other agencies without permission from the individual. The change included access to personal travel history information in databases maintained by CBSA.
That is, IRCC no longer asks applicants to give permission to access the CBSA travel history information because IRCC can directly access it without an individual's permission.
I do not recall when precisely, nor the particular details, including what the particular changes in the underlying law were. This is something I ordinarily research before posting about (doing that research, the "homework," to verify before commenting even when I quite clearly recall such details), but this is so commonly understood now I will leave that to you if you are that interested.
Moreover, in regards to CBSA travel history in particular, IRCC previously had access to that information without the client's permission subject to some level of establishing a need for it; here too I do not recall the details, but what it amounted to was either citizenship applicants gave permission or IRCC processing agents (maybe it required an officer) took the administrative steps necessary to justify a request for that information/data.
It is clear that verification of the travel history reported by the applicant with the information maintained by CBSA has been a major part of "processing" citizenship applications for a long time, and that this has had an increasingly larger role, having more importance, given two major changes along the way:
A Bit of Speculation:
I suspect, almost to the degree of believing it is how things currently work, that part of the electronic/digital processing of applications now includes (or at least soon will) automated analysis of the travel history reported by applicants (in their physical presence calculation) compared to CBSA travel history entry records. I am not sure if or when this might expand to exit records as well, but those records are significantly more complicated given they are largely derivative (based on data from airlines, flight departure data, or are derived from U.S. records of land-border entries into the United States). This automated processing is likely geared to flagging applicants for more extensive physical presence screening. For many, many applicants, the processing agent probably does not put eyes on the CBSA travel history. Hard, very hard, to figure out the extent to which flagged applications (flagged in the automated screening process) go into non-routine processing streams, and of course some will be referred to CBSA for its NSSD to investigate the applicant's travel history and physical presence.
Note: the relevant, underlying law is about protecting the privacy of individuals -- just because some branch of the government has personal information does not give other branches of the government access to that information. A legitimate need for the information is one of the exceptions the law has long allowed. Changes in the last decade plus some have expanded the extent to which information can otherwise be shared within the government; in a sense this is about legislatively acknowledging the need so that a government agency is not required to establish the need in particular contexts . . . including, now, no need for IRCC to establish a personal need to obtain access to CBSA travel history when there is a citizenship application in process.
Edit to Add:
In terms of when the change to eliminate the request for permission took place, that happened in 2018.
As best I can determine, the 2017 version of the citizenship application, CIT 0002 (06-2017), still included requests for the applicant's permission to "collect the history of entries into Canada from the CBSA," and, by the way, similar permission regarding sharing information to and from CRA (regarding tax filings). Neither of these were included in the 2018 version CIT 0002 (06-2018), or later versions.
The request for permission to access CBSA travel history was not mandatory (not giving that permission probably triggered non-routine processing and getting it anyway by documenting a need for it). In contrast, checking the [no] box in regards to sharing with CRA resulted in the application being returned as incomplete.
Sometime ago there were changes in policy and practice, and some of the underlying law, which allows IRCC to directly access certain types of personal information held by other agencies without permission from the individual. The change included access to personal travel history information in databases maintained by CBSA.
That is, IRCC no longer asks applicants to give permission to access the CBSA travel history information because IRCC can directly access it without an individual's permission.
I do not recall when precisely, nor the particular details, including what the particular changes in the underlying law were. This is something I ordinarily research before posting about (doing that research, the "homework," to verify before commenting even when I quite clearly recall such details), but this is so commonly understood now I will leave that to you if you are that interested.
Moreover, in regards to CBSA travel history in particular, IRCC previously had access to that information without the client's permission subject to some level of establishing a need for it; here too I do not recall the details, but what it amounted to was either citizenship applicants gave permission or IRCC processing agents (maybe it required an officer) took the administrative steps necessary to justify a request for that information/data.
It is clear that verification of the travel history reported by the applicant with the information maintained by CBSA has been a major part of "processing" citizenship applications for a long time, and that this has had an increasingly larger role, having more importance, given two major changes along the way:
-- change in eligibility requirements from a residency requirement to a physical presence requirement
-- increased capacity of CBSA to capture and maintain travel history data, which in the last several years has expanded to include records of most exits in addition to entry records
A Bit of Speculation:
I suspect, almost to the degree of believing it is how things currently work, that part of the electronic/digital processing of applications now includes (or at least soon will) automated analysis of the travel history reported by applicants (in their physical presence calculation) compared to CBSA travel history entry records. I am not sure if or when this might expand to exit records as well, but those records are significantly more complicated given they are largely derivative (based on data from airlines, flight departure data, or are derived from U.S. records of land-border entries into the United States). This automated processing is likely geared to flagging applicants for more extensive physical presence screening. For many, many applicants, the processing agent probably does not put eyes on the CBSA travel history. Hard, very hard, to figure out the extent to which flagged applications (flagged in the automated screening process) go into non-routine processing streams, and of course some will be referred to CBSA for its NSSD to investigate the applicant's travel history and physical presence.
Note: the relevant, underlying law is about protecting the privacy of individuals -- just because some branch of the government has personal information does not give other branches of the government access to that information. A legitimate need for the information is one of the exceptions the law has long allowed. Changes in the last decade plus some have expanded the extent to which information can otherwise be shared within the government; in a sense this is about legislatively acknowledging the need so that a government agency is not required to establish the need in particular contexts . . . including, now, no need for IRCC to establish a personal need to obtain access to CBSA travel history when there is a citizenship application in process.
Edit to Add:
In terms of when the change to eliminate the request for permission took place, that happened in 2018.
Apologies for doing some homework, that is failing to follow customs and practice in online posting (dominated by undocumented spouting), including very much in this forum . . .
As best I can determine, the 2017 version of the citizenship application, CIT 0002 (06-2017), still included requests for the applicant's permission to "collect the history of entries into Canada from the CBSA," and, by the way, similar permission regarding sharing information to and from CRA (regarding tax filings). Neither of these were included in the 2018 version CIT 0002 (06-2018), or later versions.
The request for permission to access CBSA travel history was not mandatory (not giving that permission probably triggered non-routine processing and getting it anyway by documenting a need for it). In contrast, checking the [no] box in regards to sharing with CRA resulted in the application being returned as incomplete.
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Thank you for all the education! Very insightful and helpful as always. By the way, the request to give consent to access CRA info is still in today’s application. Not sure about the inconsistency here, but I am now staying assured that I did not miss anything.
Thank you for pointing out that consent for CRA information sharing is still required.
Like everyone who breathes, I make mistakes.
Taking a closer look at the various versions of the application for citizenship, from over the years, I see that actually IRCC moved where the applicant gives "consent," separating consent to disclose personal information in processing the application from what was a broader "CONSENT TO DISCLOSE PERSONAL INFORMATION" section of the form (item 9 in the 2017 version), which included both the CRA and CBSA consent requests among other types of consent. As of 2018, when the application was extensively revised, item 17 became where the applicant gave "Consent to Disclose Personal Information after you acquire citizenship," and CRA consent was made part of the item where the applicant gives their tax filing information (item 12 in the March 2025 version of the paper application form).
CBSA Travel History Consent:
So I may be wrong about 2018 being the year that IRCC no longer requested consent to obtain CBSA travel history . . . as previously noted, it was no longer included in the application form itself as of 2018. It is possible that this consent moved to the physical presence calculation but I am not sure of this. That said, the paper version of the physical presence calculation does NOT contain a request for consent to sharing personal information held by CBSA, no request for consent to obtain travel history from CBSA. Generally the paper version should be consistent with the electronic version. The paper version (this is CIT 0407) was last revised in 2019.
In any event, the request for consent to obtain the CBSA entry records was dropped from the application form itself in the 2018 version. CIT 0407 (05-2019) does not contain a request for this consent.
The underlying statutory provisions which control the nature and scope of what personal information can be shared by government agencies, including provisions governing conditions allowing access, the procedures for obtaining more access, include not just provisions in the Citizenship Act (where relevant revisions were part of the several and extensive changes to the Citizenship Act between 2015 and 2018), but also the Access to Information Act and the Privacy Act, all of which are regularly subject to amendment (all three amended just earlier this year, albeit not in major ways like the revisions between 2015 and 2018).
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