TRAPIACanadaComplianceGovernment

TRA vs PIA — What's the Difference and When Do You Need Both?

SecuritComply·June 3, 2026

The Short Answer

A TRA (Threat & Risk Assessment) looks at security risks to your system.

A PIA (Privacy Impact Assessment) looks at privacy risks to personal information.

They are different documents, serve different purposes, and are often both required — especially when selling to government or healthcare in Canada.

What is a TRA?

A Threat & Risk Assessment is a structured analysis of the security threats and vulnerabilities that could affect an IT system, application, or service. It identifies what could go wrong from a security perspective, how likely it is, and what the impact would be.

A TRA typically covers:

  • Asset inventory — what systems, data, and infrastructure are in scope
  • Threat identification — what threats exist (ransomware, insider threats, unauthorized access, etc.)
  • Vulnerability assessment — what weaknesses could be exploited
  • Risk scoring — likelihood × impact for each threat
  • Safeguards — existing and recommended controls to mitigate risk
  • Residual risk — risk that remains after safeguards are applied
  • Risk acceptance — documented decision to accept remaining risk

TRAs are required by the Government of Canada for any IT system that handles government information. The framework is based on the Harmonized Threat and Risk Assessment (HaTRA) methodology and references the IT Security Risk Management: A Lifecycle Approach (ITSG-33) guidelines from the Communications Security Establishment (CSE).

What is a PIA?

A Privacy Impact Assessment is a structured analysis of how a system, program, or service collects, uses, stores, and discloses personal information — and whether it does so in compliance with applicable privacy laws.

A PIA typically covers:

  • System description — what the system does and why
  • Data flows — what personal information is collected, from whom, and how it moves
  • Legal authority — what law authorizes the collection of this information
  • Privacy risks — potential harms to individuals from how their data is handled
  • Safeguards — technical and administrative controls protecting the data
  • Data residency — where the data is stored and processed
  • Retention and disposal — how long data is kept and how it is destroyed
  • Third parties — any vendors or partners who access the data

PIAs are required under PIPEDA (Personal Information Protection and Electronic Documents Act) for any organization that collects personal information in the course of commercial activity. They are also required under PHIPA (Personal Health Information Protection Act) in Ontario for systems handling health information.

Key Differences at a Glance

| | TRA | PIA |

|---|---|---|

| Focus | Security risks to the system | Privacy risks to individuals |

| Asks | Could this system be attacked or compromised? | Could this system harm people's privacy? |

| Driven by | IT security frameworks (ITSG-33, HaTRA) | Privacy legislation (PIPEDA, PHIPA) |

| Who reviews it | IT security officers, CTO, CISO | Privacy officers, legal team |

| Required by | Government IT contracts, DND, PSPC | PIPEDA, PHIPA, Treasury Board policy |

| Output | Risk register + safeguard recommendations | Privacy compliance statement + risk mitigation plan |

When Do You Need Both?

You almost always need both when:

  • Selling IT services to a federal government department — Treasury Board Secretariat policy requires both a TRA and PIA for any system handling government data
  • Building a system for a hospital or health authority in Ontario — PHIPA requires a PIA; the hospital's IT team will require a TRA
  • Handling personal health information — both security and privacy assessments are mandatory
  • Bidding on a federal RFP — most solicitations for IT services now explicitly list TRA and PIA as deliverables

You may only need one if:

  • Your system handles no personal information (TRA only)
  • You are a pure software vendor with no government data flowing through your system (PIA may be lighter)

A Common Mistake: Treating Them as the Same Document

Many startups make the mistake of submitting a single document and calling it a "TRA/PIA." Government reviewers will reject this. They are separate assessments with different methodologies, different reviewers, and different sign-off requirements. A privacy officer reviewing your PIA is not looking at the same things a security officer reviewing your TRA is looking for.

Always produce two separate documents.

How Detailed Do They Need to Be?

This depends on the sensitivity of the data and the classification of the system.

Protected A / Low sensitivity: A lighter-weight assessment is acceptable. Focus on the most likely threats and key privacy risks.

Protected B / Medium sensitivity: A more thorough assessment is required. This is the most common level for systems handling personal information in government contexts.

Protected C / High sensitivity / Secret: Full-scale assessments are required, often with CSE involvement. Very few commercial vendors operate at this level.

For most startups selling to government, Protected B is the relevant level.

The Process: What to Expect

Step 1 — Scope definition

Define what system, data, and processes are in scope. Both the TRA and PIA start here.

Step 2 — Data flow mapping

Map exactly where data comes from, where it goes, who touches it, and where it is stored. This feeds both documents.

Step 3 — TRA threat identification

List all plausible threats to the system. Use a structured methodology like HaTRA or STRIDE.

Step 4 — PIA privacy analysis

Map each data element to its legal authority, retention period, and sharing arrangements.

Step 5 — Risk scoring

For TRA: likelihood × impact for each threat. For PIA: severity × likelihood of privacy harm.

Step 6 — Safeguards

Document existing controls and recommend new ones.

Step 7 — Review and sign-off

Government clients will review both documents. Expect questions and revision requests.

How Long Does It Take?

TRA: 2–6 weeks for a typical cloud-based SaaS application.

PIA: 2–4 weeks depending on complexity of data flows.

Doing them in parallel is recommended — they share a lot of foundational information (system description, data flows, asset inventory).

How SecuritComply Helps

SecuritComply has built-in modules for both:

  • TRA module — structured threat identification, risk scoring matrix, safeguard documentation, residual risk tracking, PDF export
  • PIA module — PIPEDA and PHIPA compliant privacy assessments, data flow documentation, legal authority mapping, recommendations tracking
  • Canadian data residency — your assessment data never leaves Canada, which is itself a requirement for many government contracts
  • Audit trail — every change is logged so you can demonstrate due diligence to reviewers

Most startups spend weeks trying to build these documents in Word and Excel. SecuritComply gives you a structured guided workflow that produces government-ready output significantly faster.

Bottom Line

If you are selling to the Government of Canada or Canadian healthcare institutions, assume you need both a TRA and a PIA. Start early — these documents take time and government reviewers will ask for revisions. The cost of not having them ready is losing the contract.

The good news: once you have done your first TRA and PIA, subsequent ones for similar systems are much faster.

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