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Appendix A

Status Update from Treasury Board of Canada Secretariat on Systemic Issues as of December 2009

Information Commissioner’s Recommendations (December 23, 2008) Response of the Treasury Board Secretariat (Secretary, January 23, 2009) Status

Information Management

Recommendation 1

That the Treasury Board Secretariat in collaboration with the relevant institutions

  1. conduct an assessment of information management practices in federal institutions;
  2. develop an action plan to address deficiencies in information management in federal institutions;
  3. measure the federal institutions’ performance on the use of effective information practices on an ongoing basis; and
  4. ensure that federal institutions are properly resourced to develop and sustain effective information management practices.

Recommendation 2

That the Treasury Board Secretariat develop and maintain state of the art training on information management practices and tailor such training to the needs of the Access to Information regime.

Response to recommendation 1 and 2

The Treasury Board Secretariat acknowledges the importance of the management of government information in its vision statement:

“In the Government of Canada, information is safeguarded as a public trust and managed as a strategic asset to maximize its value in the service of Canadians.”

In 2007, the Secretariat developed the Framework for the Management of Information in the Government of Canada to achieve this vision. With the framework as a foundation, the Secretariat launched the Government of Canada’s Information Management Strategy and Action Plan in 2008, which identifies a series of specific, concrete deliverables to be developed each year to support improved information management across the Government of Canada.

The Secretariat’s activities in support of the Strategy and Action Plan include the launch, in June 2008, of an inventory of initiatives and best practices, as well as the ongoing development of an Outreach and Engagement Plan to raise employee awareness of their information management responsibilities and the value of information management in improving the delivery of service in the Government of Canada. The Secretariat recently completed the Information Management Competency Standards which will be published by the Canadian General Standards Board in the coming months. The Secretariat is working closely with the Canada School of the Public Service to develop an action plan to facilitate the Canada School’s review of information management course materials to incorporate best practices and emphasize responsibilities related to access to information and privacy (ATIP).

In addition, the Secretariat obtains data on information management practices within individual departments through the annual Management Accountability Framework (MAF) assessment process. The MAF process is used to monitor departments’ compliance with the Policy on Information Management and the Directive on Information Management Roles and Responsibilities. Departments are required to demonstrate that they have an information management strategy in place to reduce complexity and duplication, promote alignment, interoperability and information sharing, and optimize service delivery within the organization and across the Government of Canada. Furthermore, departments need to demonstrate that they are making progress on the implementation of that strategy. The Secretariat is developing a roadmap for MAF that will establish the evolving approach to measure compliance with the Policy on Information Management for the next five fiscal years. As we move forward, an assessment of the progress made by institutions on the implementation of the Directive on Recordkeeping, which is currently under development, will be key for MAF.

Furthermore, the Secretariat developed an Information Management Internal Services Profile that will allow institutions to assess the relative effort required and their capacity to support information management as an internal service and will lead to the development of service standards and key performance indicators associated with information management as an internal service. The Secretariat has also initiated the development of a framework for measuring information management performance in departments subject to the Policy on Information Management, both at the departmental level and government-wide.

Finally, in the summer of 2008, the Secretariat established the Resourcing Working Group. Composed of Assistant Deputy Ministers, the mandate of the working group is to explore options, such as reallocation of funds and establishing shared services, for resourcing ongoing improvement in information management capacity across government. An Information Management Resourcing Framework is currently in development.

Significant progress has been made on the implementation of the Government of Canada’s Information Management Strategy (GCIM Strategy) and Action Plan. Activities in support of the GCIM Strategy over the last two years have included the development of over 40 horizontal IM initiatives across government, endorsed by the Committee on Information Management in Business (CIMB) which consists of CIOs from departments across government.

Key to the GCIM Strategy, new policy instruments under the Policy on Information Management were issued in 2009, including the Directive on Recordkeeping, the Standard on Geospatial Data, and the Information Management Basics guideline for GC employees.

The IM Initiatives Inventory (IMII) currently houses data on nearly 700 information management initiatives from over 100 different organizations ( and supports departments in identifying best practices for their own IM activities.

As planned, the Competencies of the Federal Government Information Management Community (CGSB-192.2) was published in March 2009. This work will provide the foundation for development of an IM Certification Program for information management functional specialists.

In addition, revised content on IM policies to support IM curriculum has been provided to the Canada School of Public Service (CSPS), with updates to be completed by end of the current fiscal year.

To support TBS capacity to monitor and assess departmental IM activities, the methodology for Management Accountability Framework (MAF) Round VII in 2009–10 introduced a new line of evidence focusing on information management practices by individual departments to measure compliance with the new Directive on Recordkeeping.

In addition, a Five-Year Roadmap for the IM Area of Management under MAF has been developed and aligned with the implementation plan for the Directive on Recordkeeping. This document will be updated based on the results of the current TBS-wide review of MAF assessment methodologies.

Furthermore, a framework for measuring IM performance in departments is to be completed by the end of the current fiscal year. Ongoing in 2010-11, planned activities include development of evaluation instruments to allow departments to assess their capacities in the context of the new IM Services profiles.

Recent work has focused on the definition of standardized IM services consisting of a normalized set of common activities. Costing tools are being developed to help departments more accurately define their resource requirements for IM against these IM services (Note: departments have experienced difficulty in accurately assessing the cost of effective IM within their organization as expenses associated with these IM services are spread across multiple responsibility centres within their organizations.)

Work to complete the IM Resourcing Framework will be completed by the end of the fiscal year. This work has been directly supported by the parallel activity of the Internal Service Strategy Development Councils (including the IM Council) which draws together ADMs from across government to focus on developing a framework for making decisions regarding the management and delivery of internal services within the Government of Canada.

Collection of Statistics

Recommendation 3

That the Treasury Board Secretariat collects the following additional annual statistics, starting in fiscal year 2010-2011:

  1. the number of pages reviewed for requests: in total and on average per request;
  2. the number of pages reviewed for incoming consultations requests: in total and on average per consultation request;
  3. the number of pages disclosed in part or in total;
  4. the number of requests completed within statutory timelines;
  5. the average time to complete a request.

Recommendation 4

That the Treasury Board Secretariat clarify the methodology for reporting on time extensions and, starting in 2010-2011, break down the reporting requirements of extensions into the following categories:

  1. number of requests extended pursuant to section 9;
  2. for each reason for the extension (searching, consultations, third party), the length of the extension:
    1. less than 30 days;
    2. 30 – 60 days;
    3. 61 – 90 days;
    4. 91 – 120 days;
    5. 121 – 150 days;
    6. 151 – 180 days;
    7. 181 – 210 days;
    8. 211 – 250 days;
    9. above 250, by units of 50 days.

  3. for each reason for the extension (searching, consultations, third party), the average actual time it took to receive a response.

Recommendation 5

That the Treasury Board Secretariat collects annual statistics, starting in fiscal year 2010–2011, on consultations pursuant to paragraphs 9(1)(b) and 9(l)(c):

  1. For consultation requests sent to other federal institutions:
    1. number of consultation requests sent;
    2. number of mandatory consultation requests sent pursuant to:
      1. section 15;
      2. section 16;
      3. section 69;
    3. number of pages sent for review;
    4. average time to receive a response;
      1. overall;
      2. for mandatory consultations;

  2. For consultation requests received from other federal institutions:
    1. number of consultation requests received;
    2. number of pages reviewed;
    3. average time to respond;

  3. For consultation requests sent to third parties (pursuant to paragraphs 9(l)(b) and 9(1)(c):
    1. number of consultation requests sent;
    2. average time to receive a response.

Collection of statistics

Response to recommendations 3, 4 and 5

Since the coming into force of the Access to Information Act in 1983, the Treasury Board Secretariat has been collecting statistical information through institutional annual reporting, which it then publishes on a yearly basis in the Info Source Bulletin. More recently, the Federal Accountability Act broadened the mandate of the President of the Treasury Board with respect to statistics. In this regard, the Treasury Board Secretariat is in the process of reviewing the collection of statistics to ensure that they are useful and provide a comprehensive picture of the government’s access to information and privacy (ATIP) program. The Secretariat is striving to achieve a balanced approach that will encourage sound practices within institutions to foster quality and timeliness.

As an initial step in this project, the Secretariat reviewed provincial and international jurisdictions with similar access to information and privacy regimes to examine approaches and the collection of statistical information. It was found that the Canadian Government is at the forefront in the area of reporting on its overall performance. The Secretariat also consulted the ATIP community, the Office of the Privacy Commissioner and your office to determine what data would be most useful to all parties, while at the same time ensuring that an undue administrative burden is not placed on government institutions.

Next, the expertise of Statistics Canada was sought to assist in a review of the proposed data collection and the content of the new statistical reporting forms. In addition, the Secretariat is chairing a working group that provides ongoing feedback and will participate in a pilot project to test the feasibility of the proposed collection. At this time, the Treasury Board Secretariat is considering the collection of additional data related to delays, consultations and extensions, among others.

As next steps, consultations will be undertaken with software providers to ensure that the proposed collection is achievable. The Secretariat will continue to consult our office and the Office of the Privacy Commissioner.

It is expected that the collection of additional statistics will begin in 2010-2011. The Secretariat will then be in a better position to assess the compliance of government institutions with the provisions of the Act and the Regulations.


The Secretariat issued additional guidelines on the use of extensions in September 1999 in its Implementation Report No. 67. In addition, detailed guidance is provided in the training session on extensions offered to the ATIP Community by the Treasury Board Secretariat. Also, as part of the Policy Suite Renewal initiative, the Secretariat is in the process of reviewing all guidance documents. It will further revise the guidance on extensions during that exercise. Moreover, as part of its project on the collection of statistics, the Secretariat will develop a user’s guide on the methodology for reporting all data elements.

Significant progress has also been made in the last year to expand on the statistical data collected by the Treasury Board Secretariat. While the review of statistical data collection was initially launched as a result of amendments introduced in the Federal Accountability Act, much attention has been given to the elements recommended by the Office of the Information Commissioner (OIC).

Equally important to the data collection itself, is the manner by which it is collected. To that end, TBS officials met with ATIP software providers to present the proposed statistical data and to assess any implementation challenges.

TBS also maintained an open dialogue with the OIC and met with OIC officials to discuss the proposed statistical data elements. TBS followed up with a formal consultation with the Information Commissioner in October 2009.

Further, TBS presented the proposed statistical data elements to the ATIP Community to identify and resolve any remaining operational issues. The Secretariat also maintained ongoing communications with Department of Justice officials on the proposed statistical elements.

The President of the Treasury Board has formally approved the statistical data elements that are to be included in a revised access to information statistics collection form. With this approval, TBS officials are proceeding to finalize this form as well as the associated training and guidance documents to assist the 250 government institutions subject to the Access to Information Act with their new reporting requirements during this transition phase.

Recommendation 6

That the Treasury Board Secretariat, together with relevant institutions, assess the magnitude of the consultations between federal institutions including mandatory consultations pursuant to sections 15, 16 and 69 of the Act, and their impact on the workload of these institutions with a view to allocate resources to this function.

Response to recommendation 6

It is recognized that the consultative process is an important part of the work conducted by institutions to respond to requests made under the Access to Information Act. It is for this reason that the Secretariat is taking a careful look at including consultations in its revised statistical requirements. The data will help identify areas requiring greater attention. Ultimately, the head of each government institution is responsible for the administration of the Access to Information Act within his or her institution.

TBS specifically examined this issue as part of its statistics review project and recognizes the importance of timeliness in the consultation process as a key issue in ensuring the effective administration and processing of access to information requests. The new statistical data elements will be instrumental in tracking volume of consultation from federal institutions and as such, will assist in identifying workload issues associated with consultations.

In addition to the work on the statistical data elements, the implementation of the proposed Directive on the Administration of the Access to Information Act will also serve to reinforce the importance of ensuring a timely review when consultations are received from other government institutions.

Recommendation 7

That the Treasury Board Secretariat, in collaboration with relevant institutions and agencies, develop and implement, as a matter of urgency, an integrated human resources action plan to address the current shortage of access to information staff.

Recommendation 8

That the Treasury Board Secretariat accelerate its review, development and implementation of an extensive training program for access to information specialists, and establish certification standards for federal professionals.

Recommendation 9

That the Treasury Board Secretariat in collaboration with the Canada School of Public Service and the Office of the Information Commissioner of Canada develop an integrated learning strategy for all employees of the public service.

Response to recommendations 7, 8 and 9

The Treasury Board Secretariat recognizes the importance of organizing and providing training and development opportunities related to the Access to Information Act. To this end, the Policy on Access to Information contains a requirement for heads of institutions to make their employees aware of the policies, procedures and legal responsibilities under the Act. The Directive on the Administration of the Access to Information Act will contain more specific requirements to increase awareness for all employees and to provide opportunities for officials who have functional responsibility for the administration of the Act to gain greater knowledge of the Act.

The Secretariat has for several years offered a training program to meet the specific needs of the ATIP community, providing on an ongoing basis, free of charge and in both official languages, sessions on a variety of ATIP-related topics. The Secretariat’s commitment to training is evident in its efforts. Since April 1, 2008, 51 sessions have been delivered, with 628 participants attending. Another 26 sessions are planned for this fiscal year, and additional sessions may be added depending on registration. As the common learning provider to public servants, the Canada School of Public Service will assume the responsibility of delivering the ATIP Community training program. In addition, the Canada School, with the expertise of the Treasury Board Secretariat, will undertake the development of new courses to meet the growing needs of the ATIP Community.

Further, the Treasury Board Secretariat conducted a survey of the ATIP community to better understand the challenges it faces assess its strengths and identify its needs. The conclusions drawn from the responses to the survey provided information that will be crucial in terms of the continued improvement of training program and examining how to alleviate difficulties affecting the community. The Secretariat, in collaboration with CSPS, is also examining broader issues related to community development, including competency profile development and, in the longer term, the possible professionalization of all ATIP practitioners within the Government of Canada.

The Canada School and the Treasury Board Secretariat will undertake further work towards identifying federal employee learning needs with respect to Access to Information within the first quarter of the 2009-2010 fiscal year. This should culminate in the establishment of an integrated learning strategy. A cornerstone is the Access to Information and Privacy overview course which is currently under development by the Canada School with the support of the Secretariat. The course, which will be piloted during the summer months, should be available across Canada in both official languages by September 2009. Also, commencing 2009/2010 fiscal year, the Canada School will be reviewing and updating all of its courses which have components related to Access to Information Act and the Privacy Act to ensure they reflect changes brought to the ATIP legislation, recent jurisprudence as well as the new policy instruments. Specifically, the Canada School will be targeting training to ensure a learning continuum that starts with the Orientation of all new public servants, and the four mandatory Authority Delegation Training courses for public service managers. The Canada School maintains attendance records for all authority delegation training courses and is in a position to provide statistical information on the successful completion of the mandatory online assessment tools that aim at confirming the knowledge acquisition through this training.

In addition, the Secretariat prepared an introductory presentation on ATIP for senior officials. The presentation was sent to all Deputy Ministers to assist them in briefing their Ministers’ Offices. The Secretariat also offers individual briefings on access to information and privacy to Governor in Council appointees. Finally, the Secretariat provides strategic advice and support to the ATIP community by issuing guidance documents on emerging issues and by holding regular community meetings. It also offers immediate assistance to ATIP officials on specific issues through its toll-free number or by electronic mail.

The Treasury Board Secretariat plays an active role in supporting and leading the ATIP community. Since 2007, it has worked on renewing seven ATIP mandatory policy instruments. Also, the Secretariat provides ongoing support activities for the ATIP community. On an annual average, TBS:

  • responds to some 2250 enquiries from government institutions;
  • reviews and approves close to 220 personal information banks;
  • reviews 250 government institutions’ descriptions of program activities and related information holdings;
  • issues guidance to the ATIP community; and
  • delivers 60 awareness and learning events to members of the ATIP community.

TBS is also looking to develop competency profiles for the ATIP community which will aid in recruitment and developmental activities. Also, the Secretariat is working collaboratively with the Canada School of Public Service (CSPS) to explore new training opportunities for ATIP community. To this end, discussions are underway regarding the development and delivery by the CSPS of specific courses for ATIP specialists. TBS also revamped the CSPS’s ATIP I-703 Overview Course for the broader Public Service. The course was successfully piloted from June 9 to June 11, 2009 and is now part of CSPS course offerings. TBS and CSPS continue to work collaboratively on the completion of a Five-Year Integrated Learning Development Strategy for IM/ATIP that is being led by CSPS. In addition to the above, TBS also strengthened ATIP governance. In 2009, membership of the Committee on Information Management in Business (CIMB) was expanded to increase the representation of ADMs that hold responsibility for both ATIP and IM. The renewed structure ensures ongoing executive oversight of key ATIP policy and operational issues and allows for leveraging shared interest in terms of community development and training between the Information Management and ATIP communities.

Also, to ensure focus on ATIP specific questions, an ATIP DG Committee was established in September 2009. The purpose of the ATIP DG Committee is to review and provide strategic advice to the Executive Director of the Information and Privacy Policy Division and the Chief Information Officer of Canada on overarching ATIP policy and operational questions. The ATIP DG Committee has specifically identified ATIP community development as one of its main priorities initiatives. As a first step in terms of developing models and standardizing HR practices related to ATIP, TBS has undertaken an analysis of the essential qualifications for ATIP related positions advertised on Publiservice. In addition, the Secretariat will review and assess organizational structures of ATIP offices with a view to developing, in consultation with the ATIP community, various management models for ATIP operations in government institutions.

Recommendation 10

That, as part of the Management Accountability Framework, the Treasury Board Secretariat review current criteria to ensure that they are measuring the overall performance of federal institutions in meeting their obligations under the Access to Information Act.

Response to recommendation 10

Parliament put in place a mechanism to ensure accountability for the administration of the Access to Information Act. Section 72 of the Act requires the head of every government institution to table an annual report on the administration of the Act within their institution before the House of Commons and the Senate. While this legal requirement applies to all 255 institutions subject to the ATIP legislation, only 20% of those institutions are assessed pursuant to the Management Accountability Framework (MAF).

As part of the MAF, activities related to the administration of the Access to Information Act have been assessed since fiscal year 2005–2006. The Treasury Board Secretariat assessed the performance of 53 institutions in the first year and is currently assessing the performance of 49 institutions for fiscal year 2007–2008. This evaluation comprises a review and analysis of the institution’s annual report, its Info Source chapter, Departmental Performance Report, Report on Plans and Priorities, Program Activity Architecture structure and website to determine if the institution is providing complete, comprehensive and up-to-date descriptions of its functions, programs, activities and related information holdings. The annual report of the Information Commissioner is also reviewed to establish if issues specific to an institution were identified.

The methodology used for the assessments is reviewed each year and revised as required. It is anticipated that the ongoing review and refinement of the MAF methodology will continue in the future to ensure alignment with new policies, directives as well as the new statistical data collected. This refinement process will ensure the harmonization of all compliance assessment processes and reduce the administrative burden on institutions.

TBS continues to review the compliance assessment methodology used for MAF on an annual basis. For MAF Round VII (2009–2010 assessment year), 49 institutions have been assessed.

The Secretariat recently launched a project to review the current MAF compliance assessment framework and develop options for assessment methodologies for future MAF rounds and other compliance assessment tools. This will include the use of new ATIP-related statistical data which will be used to refine TBS’s performance monitoring capability.

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