AI-Assisted Verification for Student Loan Repayment Assistance

Eligibility & Public Benefits · Enforcement

What it collects that can identify you

Sensitive personal information

Identifiable data

Borrower-declared application data including Social Insurance Number, date of birth, first and last name, gross income, marital status, and number of dependants. Spousal or common-law partner information (SIN, name, date of birth, income) is also collected where applicable, with signed consent.

Sensitive personal information

Identifiable data

CRA taxpayer information returned via secure file transfer, including Line 15000 total income, marital status, number of dependants, and the corresponding SIN, name, date of birth, and tax year. Classified as Protected B under Government of Canada security standards.

Also collects operational data, which is anonymized data.

Run by: Employment and Social Development Canada (ESDC)
Where: No fixed location
Kept: Retained Governed by ESDC and CRA retention schedules under the Canada Student Financial Assistance Program personal information banks (ESDC PPU 030 and ESDC PPU 709) and applicable Treasury Board directives
Shared with: Accountable organization
Your copy: You cannot see the data it holds about you. What you can do

What it is for

Eligibility & Public Benefits

Enforcement

This system automatically checks the information that Canada Student Loan borrowers declare on their Repayment Assistance Plan (RAP) application against tax records held by the Canada Revenue Agency. Using pre-established business rules and risk-based sampling, it flags applications where declared income, family size, or marital status may not match CRA data and, if so, asks the borrower to provide supporting documentation before a final eligibility decision is made. Humans at the National Student Loans Service Centre review any flagged cases, and borrowers can request reconsideration or re-adjudication if they disagree with the outcome.

What it collects and what happens to it

Data taken in

Sensitive personal information

Identifiable data

Borrower-declared application data including Social Insurance Number, date of birth, first and last name, gross income, marital status, and number of dependants. Spousal or common-law partner information (SIN, name, date of birth, income) is also collected where applicable, with signed consent.

Sensitive personal information

Identifiable data

CRA taxpayer information returned via secure file transfer, including Line 15000 total income, marital status, number of dependants, and the corresponding SIN, name, date of birth, and tax year. Classified as Protected B under Government of Canada security standards.

Operational data

Anonymized data

Historical RAP application data used to develop the risk-based sampling methodology, including statistical analysis of previous cases conducted in collaboration with ESDC's Integrity Services Branch, to identify high-risk groups such as borrowers with inconsistent family size changes, borrowers claiming zero income, and borrowers reporting income just under the RAP zero-payment threshold.

Processing

Classification & Prediction

Pre-established business rules classify borrowers into risk groups using statistical patterns from historical cases (e.g., inconsistent family size changes, zero income claims, income just below the zero-payment threshold). A second set of rules then compares RAP application data to CRA tax data and classifies the result as matching, discrepant beyond a tolerance threshold, or requiring no further validation.

What it does

Deciding (Analytical AI)

Human decides

Applies pre-established business rules to classify RAP applications as matching or discrepant when compared to CRA tax data, and scores borrowers as high-risk for misrepresentation using a risk-based sampling methodology. The system determines whether additional documentation is required; a human agent makes the final eligibility and approval decision when discrepancies are found.

Outputs

A decision about you

Identifiable data

The system determines whether a borrower's RAP application requires additional supporting documentation (triggering a letter to the borrower) or can proceed directly to RAP eligibility adjudication. The final RAP approval or refusal decision, including calculation of the Affordable Payment amount, is the binding output of the overall process.

A recommendation or prediction

Identifiable data

When a discrepancy is identified beyond the tolerance threshold, the system generates a recommendation to request specific supporting documentation from the borrower (e.g., proof of income, proof of family size or marital status). This recommendation is reviewed by an NSLSC agent before the final adjudication.

Run by

Employment and Social Development Canada (ESDC)

ESDC's Canada Student Financial Assistance (CSFA) Program is responsible for the Repayment Assistance Plan and owns the RAP-EVM system. It sets the eligibility rules, business logic, and risk-sampling methodology, and oversees the third-party Service Provider (National Student Loans Service Centre) that operates the system.

RAP-EVM AIA — Project Details

Built by

National Student Loans Service Centre

The NSLSC is ESDC's contracted third-party Service Provider that operates the RAP application and verification system, runs the RAP-EVM business rules, performs the secure data exchange with CRA, and has back-office agents who review discrepancy cases and contact borrowers for additional documentation.

RAP-EVM AIA — Project Description

Kept for

Retained Governed by ESDC and CRA retention schedules under the Canada Student Financial Assistance Program personal information banks (ESDC PPU 030 and ESDC PPU 709) and applicable Treasury Board directives

Personal information collected and used for RAP-EVM is safeguarded under ESDC's and CRA's legal authorities. Borrowers' personal data are not permitted to be stored on local hard drives of PCs, laptops, or portable devices. CRA taxpayer data accessed under the Memorandum of Understanding is subject to the confidentiality provisions of sections 241 and 239 of the Income Tax Act.
Duration: Governed by ESDC and CRA retention schedules under the Canada Student Financial Assistance Program personal information banks (ESDC PPU 030 and ESDC PPU 709) and applicable Treasury Board directives

Shared with

Not available to me

Borrowers do not have direct access to the CRA taxpayer data used to compare against their RAP application, nor to the risk-group classification that determines whether they are selected for enhanced verification. They are informed of the outcome (match or discrepancy) and can submit documentation to address any discrepancies identified.

Available to the accountable organization

ESDC and NSLSC (SP) personnel with Reliability Security Screening Clearance and who occupy positions requiring access are authorized to access borrower personal information and CRA taxpayer data under the MOU. Access is controlled via unique user identifiers, permission settings, and defined user roles within the system.

Stored

Stored locally

RAP application adjudication takes place in a closed environment following data exchange. The data exchange between the SP and CRA uses a secure Managed Secure File Transfer. The system does not connect to the Internet or external IT systems during adjudication, and all processing occurs within the Government of Canada jurisdiction.
Duration: Governed by ESDC and CRA retention schedules under applicable personal information banks and Treasury Board directives

How to read the colours

Can it identify you?

Anonymized data: Data about people with the link to who is broken. Stripped of identifiers, blurred, aggregated, or noised so this system can’t reasonably tie a record back to an individual.
Pseudonymous data: Each person’s data is tied to a token (hash, ID, template) that lets this system recognise the same person across events, but the token itself doesn’t reveal a name. Reidentification is possible with extra information.
Identifiable data: The data either contains a direct identifier (name, address, account name, recognisable face or voice, plate number) or carries a token this system uses to look up legal identity during processing.

Who completes the loop?

Human decides: This mode suggests; a person decides what to do next. The AI is always advisory — a human is in the loop on every decision. Example: a triage tool ranks cases for a clinician who chooses which to see first.
Human executes: This mode decides; a person carries out the result. Example: an optimizer plans the day’s trash-collection routes, and drivers run them.
Autonomous: This mode decides and acts on its own. No person reviews each decision or carries out the resulting action.

Definitions from the DTPR standard. Amber is about your data, violet about who decides. The fuller the shape and the deeper the colour, the more identifying the data or the less a person is involved.

What you can do

Ask about this system

Questions go to the Helpful Places, not the vendor.

Your rights

Right to Be Informed of AI UseBorrowers are informed on their RAP application that their data may be shared with the Canada Revenue Agency for verification purposes. Signed consent from the borrower (and spouse/common-law partner, if applicable) is required before any data exchange takes place. The existence of RAP-EVM is publicly disclosed through the Algorithmic Impact Assessment published on the Government of Canada Open Government Portal.
Right to ContestBorrowers who are refused RAP may request reconsideration if unforeseen and unavoidable circumstances caused exceptional expenses preventing them from meeting repayment obligations. Borrowers approved for RAP with a monthly Affordable Payment may request re-adjudication if their gross monthly income drops significantly. Contact the National Student Loans Service Centre (NSLSC) to initiate either process.
Right to a Human ReviewWhen a discrepancy is identified between a borrower's RAP application data and CRA tax data, an NSLSC agent directly contacts the borrower, reviews the submitted documentation, and makes the final approval or refusal decision. Borrowers whose applications are flagged will always have a human review their case before a final decision is rendered. Human override of automated system decisions is enabled and all overrides are logged.
Right to Algorithmic TransparencyA plain-language explanation of how RAP-EVM works — including the role of the system in the decision-making process, the data it uses, the criteria applied, and the possible outputs — is publicly available through the Algorithmic Impact Assessment published on the Government of Canada Open Government Portal at https://open.canada.ca/data/en/dataset/d24ae2dd-8399-4b49-8441-3e0318aaf69a.
Right to an Explanation of a DecisionBorrowers who receive a request for additional documentation or a RAP refusal are informed of the reasons for that outcome and the supporting documentation required. The audit trail is designed to support generation of decision notifications. Contact the NSLSC for an explanation of a specific decision made about your RAP application.

Risks and safeguards

Financial & business harmBorrowers flagged as discrepant may experience delays in RAP approval or temporary inability to afford loan repayments, creating financial stress, particularly for vulnerable borrowers. A false positive (incorrect flag) could unjustly burden an eligible borrower.Safeguard: The system only requires additional documentation when a discrepancy exceeds an established tolerance threshold; RAP approval periods are six months, making impacts time-limited; borrowers can request re-adjudication if their income drops significantly; and agents at the NSLSC review flagged cases before final decisions. Human override of system decisions is enabled and logged.
Civil liberties harmThe risk-based sampling methodology uses statistical patterns from historical cases to identify high-risk groups, which could embed and amplify past biases — for example, disproportionately flagging borrowers from groups that historically under-report income due to informal employment, or borrowers with disabilities whose income and family circumstances change frequently. This raises due-process and potential disparate-impact concerns.Safeguard: ESDC has documented processes to test datasets against biases; the selection criteria were developed collaboratively with ESDC's Integrity Services Branch; a Privacy Impact Assessment was completed and reviewed by the Office of the Privacy Commissioner; the system does not change RAP eligibility criteria; and human agents review all discrepancy cases. However, no Gender-Based Analysis Plus of the data was undertaken, which is a noted gap.
Loss of autonomyBorrowers selected for enhanced verification have their data compared to a third-party (CRA) authoritative source without the ability to opt out of the process, as consent to share data with CRA is a condition of the RAP application. Borrowers cannot choose which verification method applies to them.Safeguard: Borrowers are informed on the RAP application form that their data may be exchanged with CRA; signed consent is required from both borrower and spouse before any data exchange; borrowers retain the right to submit supporting documentation, request reconsideration, and seek re-adjudication; and the system does not change RAP eligibility criteria.