Survey classification and privacy notification

Surveys have the potential to collect the personal information and/or the personal health information of those who are participating in the survey, whether or not that was the intent of the survey creator/owner. This depends on how the surveys are set up.

Step 1: Determine if your survey is confidential or anonymous

To determine whether or not your survey is anonymous, review the Survey Classification: Confidential vs. Anonymous (PDF) decision tree.

If your survey is classified as Confidential, it means that you may be collecting personal, identifiable information about your participants and a Privacy Notification Statement is required. Continue to Step 2: Determine the type of privacy notification statement required.

If your survey is classified as Anonymous, it means that you will not be able to identify any of your participants through their responses to the survey. Nothing further is required.

Step 2: Determine the type of privacy notification statement required

To determine the type of privacy notification statement that is required for your survey, review the Notification Statement Decision Tree for Confidential Surveys (PDF).

Important note regarding the use of market research firms

If a third party market research firm is hired to manage your survey and the survey is classified as Confidential and/or collects contact information for a draw, then the notification statement used for the survey and/or the ballot form for the draw will need to include the fact that the participant's responses and personal information is being disclosed to that particular firm. This will need to be used in the "disclosure" sentence of the notification statement.

Anonymizing surveys

Are surveys anonymous?

A common misconception is that a survey can be considered anonymous simply by not asking for direct identifiers, such as a participant's name, email address, or student/staff number. The reality is that participants can potentially be identified through the collection of indirect identifiers, such as demographic information; the participant's IP or email address; or open-text answer fields in which the participants have the ability to enter free text.

Once a participant can be identified through indirect (or direct) identifiers, all of their responses to the main body of the survey becomes identifiable personal information, as an individual's opinion is defined as their personal information under The Freedom of Information and Protection of Privacy Act (FIPPA). Therefore, if your survey is not truly anonymous, all of the responses collected through your survey would be considered the participants’ personal information.

How to make your survey anonymous

If your survey was classified as Confidential but you want to anonymize the survey, or you are in the development stage of your survey and are planning on creating an anonymous survey, please review the following guidelines:

Survey privacy settings - IP addresses, email addresses

Regardless of which platform you select to carry out your survey, you will need to check a variety of settings to see if the responses you collect will truly be anonymous. For example, survey platforms may have default settings that collect the IP address and/or email address of each participant.

There are circumstances in which the collection of IP or email addresses would be appropriate, such as giving the participants the option of saving their work and coming back to the survey at a later date to finish entering their responses; to control the participant audience (i.e. surveys that only allow participants with specific email domains); or to ensure that the survey is not filled out multiple times by the same participant. If you require that level of control for your survey, it will be classified as Confidential, not Anonymous.

However, if you want to create a truly anonymous survey these settings need to be disabled.

Important note: selecting the appropriate settings to create an anonymous survey usually needs to be completed during the development of your survey and not after the survey invitations have been sent out.

Contact your service provider for details on how to make your survey responses anonymous or view their website for articles or how-to videos.

Demographic information collection

The collection of demographic information can be a vital component of your research as the results will evaluate whether or not your pool of participants reflect the demographics of your target community, or to compare responses across specific demographics.

Under FIPPA, the collection of personal information (demographics) must be kept to the minimum amount that is required to meet an authorized purpose. Therefore, it is recommended that the amount of demographic information collected in your survey is kept to only the demographics in which you have a business purpose to collect. Collecting additional demographic information beyond what is required for your study would be considered a breach of the participants' personal information under FIPPA.

The collection of demographic information does not instantly classify your survey as Confidential. To determine the classification of your survey, consider the size of the target audience, as well as the known demographics of your audience.

For example, if your target audience is large (i.e. the entire university student body), collecting demographic information such as age, gender identity, citizenship, etc., would likely not provide you with enough information to identify any of your participants. Therefore, your survey would be classified as Anonymous.

However, if your target audience is comprised of a high percentage of individuals identifying as one gender, and the size of the audience is small and/or familiar to you (such as students within a specific program), collecting demographic information, such as gender identity, will significantly increase the likelihood that some of your participants would be identifiable. Therefore, all of the survey responses belonging to the participants who are identifiable become personal information under FIPPA, and the survey would be classified as Confidential.

Important note: You do not have to be able to identify all of your participants in order for your survey to be classified as Confidential. If there is the potential to identify at least one participant, your survey would be classified as Confidential.

Response fields

In order to create a survey classified as Anonymous, the response fields in the survey need to be closed from participant input. If any of the response fields include open-text fields that allow the participants to enter their response to the questions being asked, then the survey cannot be classified as Anonymous as the open-text fields provide the participants with the opportunity to enter personal information about themselves (either direct or indirect identifiers).

In order to create a truly anonymous survey, keep all response fields to drop-down lists, buttons or check boxes, or a variation of the likert scale. And make sure that any "Other" response choices do not allow for the input of data from the participant.

Draws in surveys

Some surveys offer draws or prizes as an incentive to participate. In order to award the draw or prize, a limited amount of the participants’ contact information needs to be collected (i.e. name, email address, phone number). If the draw is not set up properly, the contact information of your participants could be linked with their responses to your survey, resulting in all of their survey responses becoming personal information (even if the survey was set up to be anonymous).

In order to provide a draw to your participants while also ensuring that their responses to your survey are not associated with their identity, you will need to create two separate surveys:

  1. The primary survey that you have developed in order to gather responses relevant to your research or program, or event, etc.; and
  2. A secondary survey that collects only the contact information required for the draw (a virtual ballot).

Once you have created both surveys, insert the URL of the secondary survey (ballot for the draw) at the end of your primary survey. If someone chooses to enter the draw, they can click the link embedded in the primary survey, which will bring them to the secondary survey. This way, the responses to the primary and secondary surveys will not be linked.

Don't forget: your secondary survey (ballot for the draw) will need a privacy notification statement, even if your primary survey is classified as Anonymous. Visit Contests/Draws/Prizes notification statement the appropriate notification statement.

Glossary of terms

Anonymous survey
A survey that has been developed in such a way that it would not be possible to identify any of the participants who complete the survey based on their responses. Anonymous surveys:
  • Do not collect participant’s IP or email addresses
  • Only use broad demographic questions (if any)
  • Do not include any open text fields
Confidential survey
A survey that has the potential to collect identifying information about a participant, or all of the participants. This occurs when participant’s IP or email address are collected; demographic questions are too narrow; when a small pool of participants is the target audience; and/or when open text fields are used to collect responses from participants.
Direct identifiers
Elements of an individual’s personal information that is directly associated with them, such as their name, social insurance number, or personal health identification number.
Indirect identifiers
Elements of an individual’s personal information that can be used in combination with each other to positively identify an individual, even without the use of any direct identifiers. Examples of indirect identifiers include date of birth, physical characteristics or partial address.
An individual who actively participates in a survey by responding to some or all of the questions posed within the survey.
Personal information
Recorded information about an identifiable individual, including:
  1. the individual's name,
  2. the individual's home address, or home telephone, facsimile or e-mail number,
  3. information about the individual's age, sex, sexual orientation, marital or family status,
  4. information about the individual's ancestry, race, colour, nationality, or national or ethnic origin,
  5. information about the individual's religion or creed, or religious belief, association or activity,
  6. personal health information about the individual,
  7. the individual's blood type, fingerprints or other hereditary characteristics,
  8. information about the individual's political belief, association or activity,
  9. information about the individual's education, employment or occupation, or educational, employment or occupational history,
  10. information about the individual's source of income or financial circumstances, activities or history,
  11. information about the individual's criminal history, including regulatory offences,
  12. the individual's own personal views or opinions, except if they are about another person,
  13. the views or opinions expressed about the individual by another person, and
  14. an identifying number, symbol or other particular assigned to the individual.
Primary survey
The main survey that was developed for an authorized business purpose at the University of Manitoba. This may include, but not be limited to, the collection of data in relation to a university approved research study; feedback regarding a university program or event; or the collection of information that will inform future programs, events, or services at the University of Manitoba.
Secondary survey
An independent survey, separate from the Primary Survey, which is used to collect a limited amount of personal information from the Participants of the Primary Survey. The purpose of the Secondary Survey may include, but not be limited to, the drawing of a prize for participating in the Primary Survey (a virtual ballot); to disseminate the results of the Primary Survey to the Participants; or to send future communications or invitations to participate in future studies or surveys.