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Canada Post Corporation

Part A: Requests carried over from the prior fiscal year (2008-2009)

1. Number of requests carried over: 73
2. Requests carried over from the prior fiscal year— in a deemed-refusal situation on the first day of the new fiscal year 57

Part B: New Requests received in fiscal year 2009-2010— Exclude requests included in Part A

3. Number of requests received during the fiscal period 78
4.A How many were completed during fiscal year 2009-2010withinthe statutory 30-day time limit? 21
4.B How many were completed during fiscal year 2009-2010 beyond the statutory 30-day time limitwhere no extension was claimed ? 15
4.C How long after the expiry of the statutory 30-day timelimit did it take to complete the requestwhere no extension was claimed ?  
  1-30 days: 6
  31-60 days: 4
  61-90 days: 3
  Over 91 days: 2
5. How many were extended pursuant to section 9? 2
6.A How many were completed during fiscal year 2009-2010withinthe extended time limit? 0
6.B How many were completed during fiscal year 2009-2010 after exceeding the extended time limit? 2
6.C How long after the expiry of the extended deadline did it take to respond?  
  1-30 days: 0
  31-60 days: 0
  61-90 days: 0
  Over 91 days: 2
7. Number of requests received in 2009-2010 that were carried over to 2010-2011? 40
8. As of April 1 st , 2010, how many requests which were received in 2009-2010 are in a deemed-refusal situation? 37

Part C: Workload

9. What is the number of pages reviewed for requests completed in 2009-2010? 9815
10. What is the number of consultations requests received in 2009-2010? 14

Part D: Contributing Factors


Please describe the most significant issues that affected your institution’s ability to respond to access to information requests in a timely manner (within 30 days and/or statutory timelines) since becoming subject to the Act. These may include:

  • Requests for large volume of records
  • Approval process of access requests
  • Difficulties to retrieve records (OPIs turnaround time)
  • Staff shortages
  • Requests filed in bulk
  • Consultations with other institutions
  • Others

Canada Post has been subject to the Act since September 1, 2007. The administration of the ATIA at Canada Post is a complex and challenging task given the size of the Corporation and the reality of the business context in which it operates. Canada Post has navigated a steep learning curve as it dealt with the complexities of being subject to the Act in a multifaceted commercial environment, which impacted the timeliness of our request processing in a number of ways.

Canada Post operates one of the country’s largest transportation and retail networks with more than 23,000 delivery routes and 6,500 post offices nationwide. This expansive network provides Canadians in every community with delivery, logistics and communications services. The Canada Post Group of Companies employs 72,000 Canadians and connects millions of individuals, communities and companies to each other and the world.

We have the exclusive privilege of collecting, transmitting and delivering letters up to 500 grams within Canada. More than half of Canada Post’s revenues are derived from our parcels and direct marketing lines of business, which operate in competitive markets. Each business day, we process more than 45 million pieces of mail to nearly 15 million residential and business addresses. Our delivery network continues to grow by about 200,000 addresses a year.

Parliament, in enacting the Canada Post Corporation Act, requires that Canada Post operate a postal service which provides a standard of service that meets the needs of the people of Canada and to conduct its operations on a self-sustaining financial basis without government appropriations for operating purposes. We are expected to earn a return on equity and pay dividends to the Government.  

Canada Post generates approximately 7 billion dollars a year in revenue and is more than double the size of all other federal Crown Corporations combined. In meeting our legislated commercial mandate, we face increasing competition from alternate means of communication and the explosive growth of technological advances, such as email, online and telephone banking services. In the parcel and courier market, Canada Post operates in a fiercely competitive marketplace vying for market share and revenue. We face competition from large private-sector domestic companies as well as well-capitalized global companies that have expanded aggressively into Canada such as FedEx, UPS and DHL.

Adding to an already challenging business environment, globally, postal administrations have suffered the impact of the economic downturn. Most postal administrations are experiencing decreasing mail volumes, increasing points of call, and demands from customers for increasingly sophisticated services. Canada Post is no exception. As we work to remain relevant in today’s marketplace, we tend to operate more like a private business than a government institution. We must continually be aware of competitors that encroach on our market share as we seek to gain ground in competitive markets such as e-commerce.

Readying the Corporation for ATI was a significant challenge that we took very seriously. Much time and effort was focused on communication, education and awareness with a view to bringing about culture change. These initiatives are outlined in Part E, 13.

Prior to becoming subject to the ATIA the Corporation established the ATI Directorate and after much consideration, staffed the Directorate with internal candidates and an experienced Coordinator with federal government ATI experience to lead the team. Overall responsibility of management of the ATI team was given to an executive level role. Knowledge of the Corporation and our business was considered to be essential for identifying responsive records and determining the accurate application of exemptions in Canada Post’s unique commercial environment. The combination of knowledge of the Corporation and ATI expertise was thought to be the best model. The learning curve was steep for the ATI Directorate in this first year of operation. The Directorate worked hard to master the request process, develop a strong and viable ATI network within the Corporation, improve performance and establish good working relationships with requesters. From September to December 2007, Canada Post received 74 requests, which were all a significant challenge for a newly formed ATI Directorate and the Corporation as a whole.

A network of almost 200 Offices of Primary Interest (OPI) and Liaison Officers (LO) was created to assist the ATI Directorate in retrieving records in response to requests. Though much communication and training was provided, organizational culture is much more difficult to change. Consequently, this network struggled to navigate the learning curve along with the rest of the Corporation, which sometimes led to delays as business areas came to terms with their obligations under the Act and the significant commercial risk associated with the release of their records. The Directorate and OPI’s worked together to overcome challenges in locating, retrieving and releasing records to the Directorate. Each request required that the ATI Directorate have an in-depth understanding of the unique business issues and commercial sensitivities of each request, so that records could be processed appropriately. As many OPI’s have yet to receive a request for their business area, we expect these challenges will likely continue for some time.

It became clear in 2007 that the majority of requests received by Canada Post are quite complex and involve a large number of records, this remains the case today. Due to our size, the diversity of our business, many business partners and our unique status as a competitive crown corporation, many requests involve complex, sensitive business issues and generate large volumes of information for review. This review often involves consultation with multiple internal and external stakeholders, which can take time.

Given that over 50% of Canada Post’s revenues are earned in a competitive market and that Canada Post operates on a self sustaining basis, it is critical that certain information not be disclosed due to commercial sensitivity. The Corporation is committed to protecting information received from its partners, suppliers and customers and believes that it is of paramount importance to balance the requesters’ right of access with the protection of commercially-sensitive, corporate and third-party information. This commitment is fundamental to customer relationships and the trust customers have in the Corporation.

Another significant challenge experienced by the ATI Directorate is ensuring that requesters understand the Corporation well enough to identify what they are truly looking for. The operations of a commercial Crown Corporation are very different in nature from the operating structure of federal government departments. In this regard, the ATI Directorate takes its “duty to assist” obligations under s.4 (2.1) of the ATIA very seriously and works extensively with each requester to help them understand how CPC operates and how information is created and managed.

The ATI Directorate has experienced significant change in its short 36 month existence and with it, many challenges. Like most ATI and Privacy teams staffing issues and workload have been a challenge. The original team of 10, who processed only ATI requests, has experienced turnover, position reductions, long term absences and the departure of an experienced Coordinator. The existing team of 9 works hard to continue to develop their expertise and balance competing priorities such as: maintaining current ATI requests on time, eliminating the backlog, processing privacy requests, meeting OIC commitment dates and working with the OIC.

In July 2009, the ATI Directorate merged with the Privacy team, forming the Privacy and ATI Directorate. In October of 2009, the ATI Directorate leveraged its existing technology and expertise to process both ATI and Privacy access requests. In late 2009, the Privacy and ATI Directorate merged with the greater compliance team, some of whom are situated across the country, which includes functions such as Official Languages, Anti-Money Laundering, Employment Equity and Human Rights. This merger allows the compliance functions to effectively realize synergies and leverage common expertise. In terms of workload, these changes have added complementary, but additional responsibilities to the ATI Directorate. The Directorate is now responsible for processing ATI and privacy requests, meeting Treasury Board requirements such as Infosource, the development and maintenance of ATI and privacy request processing policy, process and monitoring, delivering training and handling formal and informal complaints.

Canada Post has received 380 requests since becoming subject to the Act and 54 consultations from other government institutions. As a result of the time pressures created by the challenges outlined above, the Directorate has accumulated a significant backlog of requests and pages to review. For example, the Directorate currently has over 42, 000 pages in the queue for review from requests received in 2008, 2009 and 2010. Over 14,000 of these pages were received as a consultation from another government department and pertain to complex business matters that are currently subject to litigation.

These challenges have also generated a number of formal complaints to the OIC. Canada Post has enjoyed a positive and collaborative working relationship with the OIC, but as the investigation process is still relatively new to us and Canada Post is relatively new to the OIC, the time and workload demands of each investigation can be onerous and unfortunately divert resources away from the timely processing of requests. Over the last 36 months, we have worked with the OIC on closing 74 complaints. So far in 2010, Canada Post has dealt with 15 different investigators from the OIC on complaints that remain active. There may be an opportunity to explore a more streamlined process involving fewer investigators on Canada Post files, so that we can develop stronger working relationships and knowledge of each other’s processes.

Despite the challenges of the last 36 months, Canada Post is pleased with what is has accomplished. We have successfully managed an extensive change management, communication, education and culture change initiative, built the ATI Directorate and OPI network from the ground up with predominantly internal expertise, while at the same time completing 339 requests and consultations and reviewing almost 17,000 complex, commercially sensitive pages for release. Canada Post has made significant investments and has laid the groundwork critical for our compliance with the Act. This groundwork will facilitate our improved compliance in the future.

Please describe any practices or policies developed/undertaken by your institution to improve the timely delivery of your access to information program since becoming subject to the Act and where possible, indicate how successful these practices/policies have been. These may include:Informal treatment of requestsStreamlined approval processPartial release of recordsFast track process for common requestsOthers
The following activities have contributed to Canada Post’s ability to respond to requests on-time since becoming subject to the Act:  
  • Canada Post considers ongoing training an important part of building its internal expertise and enhancing its level of compliance to the Act. To better understand the legislation and build a network within which to exchange best practices, Canada Post regularly participates in the following activities:
  • Quarterly Canada Post ATI Community Meetings with all members of the ATI Community, including the regions via teleconferencing. These meetings are aimed at sharing information, best practices, discussing issues and concerns and conducting case studies.
  • Participation in Treasury Board seminars to improve the ATI Directorate’s knowledge and expertise.
  • Regular attendance at Treasury Board’s monthly Community Meetings.
  • Regular attendance at an Inter-crown working group to discuss best practices.
  • Representation of Canada Post’s ATI Directorate at various ATI conferences and events such as the CAPA and University of Alberta conferences.
  • As the Directorate gained experience and leveraged learning opportunities such as those outlined above, productivity has increased as the team has became increasingly skilled with request processing and more proficient in the application of the Act. In 2009, the Directorate reviewed 9,183 pages as compared to 6,815 in 2008, a 35% increase. The Directorate released 7,876 pages in 2009, as compared to 5,063 in 2008, a 55% increase. The team was also able to eliminate a backlog of complex and lengthy files that were received in 2007.
  • As the majority of requests received by Canada Post are complex and generate a large number of pages, we have experienced a great deal of success by working with requesters to help them better understand our business and in this way, providing a win-win solution. Not only do we assist the requester in locating the records that they are truly looking for, we also limit the amount of material that we need to process. In part due to working with requesters to assist them, we reduced the backlog of pages to review from 37,730 in 2008 to 17,074 in 2009.
  • In order to refresh the skills of our liaison officer network and to train those new to the role, we recently developed and delivered a training session. These training materials can be leveraged for future sessions as turnover takes place in our network. The goal of the session was to ensure that our obligations under the ATIA are well understood by our network of colleagues throughout the organization and to ensure that the ATI community has the skills required to play a meaningful and timely role in the process.
Despite its challenges, the Directorate continues to master and refine the request process, developing a strong and viable ATI network within the Corporation, improving performance and establishing good working relationships with requesters. Our objective in 2010 is to enhance our compliance to the Act by improving the on-time closure percentage, eliminating the backlog of requests received in 2008 and strengthening the engagement of the OPI and LO communities through continued training and communication initiatives. We also plan to review and update our delegation order with a view to streamlining our approval processes.  

Part E: Building Capacity

As a newly-subject institution to the Act, please describe the implementation process and measures to build your institution’s capacity to respond to access to information requests. This may include resource allocation, infrastructure, internal support, and/or foundational work such as policy or planning documents.
Overview of the ATI Implementation Project at Canada Post  Canada Post began preparation for Access to Information in the fall of 2006, under the leadership of a Steering Committee composed of the Senior Vice-President and Chief Information Officer, the Vice-President General Counsel and Corporate Secretary, and the Vice-President Government Relations and Policy Framework. A Request for Proposal was issued to recruit both ATI and organizational design expertise.   IT Net and its partner the Privacy Information Agency were awarded the contract in early January 2007 to design, develop and implement an organization to process ATI requests and provide the core ATI expertise to support the operation of an ATI Directorate.   In the absence of a confirmed date of the coming into force of the legislation, time was of the essence and both a project plan and contingency plan became critical for an organization the size and scope of Canada Post. The Corporation’s approach was to implement scalable processes and tools that would support corporate compliance with ATI and encourage buy-in from all employees.  A detailed communication plan was developed and had two major objectives:
  1. Develop and deliver awareness presentations tailored to the needs of various audiences such as the Board of Directors, Senior Executives, Head Office and Regional employees.
  1. Develop and deliver training sessions to key groups: ATI Directorate staff, Offices of Primary Interest and Liaison Officers.
The communication strategy was built on existing and proven bilingual tools: Lunch & Learn sessions, Regional newsletters, Intercom publications, Infopost bulletins and presentations.  
  • From February to September 2007, 27 awareness sessions and 2 Lunch & Learn sessions were conducted for employees at Head Office. 
  • Presentations to the Board of Directors and Senior Management stressed the importance of leadership for the successful implementation of the initiative.
  • From June to September 2007, 19 training sessions were delivered, either on-site, via Teleconferencing or Net meeting, to all General Managers, Liaison Officers and Administrative Assistants.
Finally, in June 2007, the Corporation conducted a practice exercise or ‘Dry Run’ of a request process, involving 16 Offices of Primary Interest. The exercise allowed Canada Post to measure its state of preparedness and identify gaps.   This exercise was well received, as witnessed by the level of senior management and employee participation as well as the interest in understanding the legislation, the underlying principles and potential impact on Canada Post’s business.
  • The Team
The ATI Directorate was staffed predominantly with experienced Canada Post employees from diverse background within the company. An experienced coordinator was recruited from the public sector to lead the team and the overall management of the team was given to an executive level role. In August of 2007, the team received two weeks of training from ITNet and the technology provider.  
  • Tools
A Procedure Manual was developed based on the requirements of the ATIA, its regulations, and related Treasury Board Policy. It became evident that the initial procedures needed to be adjusted for a Corporation the size and complexity of Canada Post.   A significant IT investment was made in Privasoft request processing software to efficiently automate the processing of the Corporation’s requests. An ATIA Web page was created on the Canada Post Web site,, to assist requesters. A customized ATIA Canada Post request form has been included for ease of reference and use.   Canada Post’s InfoSource Chapter was extensively updated as part of ATI readiness.  
  • Service Delivery Model
The Service Delivery Model is the process used by the Corporation to manage ATI requests from receipt of request to final response. The thirty day legislative deadline implies a need to minimize the number of steps and hand-offs in the process. The process is reliant on key individuals, adequately trained to perform their duties. The Directorate has since evolved to take on additional responsibilities which have been outlined in Part D, 11.   Under this model, the ATI Directorate is responsible for the coordination of all ATI requests, managing requester relationships, and liaising with the Office of the Information Commissioner. The position of Vice-President, Compliance was created in June 2007 to oversee the administration of the ATIA as well as the Privacy, Human Rights, Official Languages, Employment Equity,Proceeds of Crime (Money Laundering) Terrorist Financing and the Public Servant Disclosure Protection (PSDP) Acts, and to drive synergies for compliance under these requirements, where available. In addition, the creation of this position is also intended to foster and promote a culture based on corporate values and ethics that recognize compliance as critical to the business success and reputation of Canada Post.  
  • Governance
The Board of Directors and management of Canada Post hold the view that sound governance practices that are dynamic in nature are the bedrock of a quality organization that builds value and is dedicated to its employees and customers. They believe that transparency and corporate governance are essential components to the fulfillment of Canada Post ’s public policy and commercial mandates.   The ATI Advisory Council, made up of senior executives, was created with a mandate to support the ATI Directorate and the Corporation during the ATI start up period. Still today, the Council continues to provide advice and guidance to the Directorate as well as a formal escalation point when necessary.   
  • The Records Management Program
It is the policy of Canada Post to ensure that records are managed both for business information purposes and to provide evidence of business activity. Business processes must include a comprehensive Records Management program. The Records Management Center of Excellence is accountable for providing direction and support to the Corporation on Records Management Policy and Practices.   The Records Management Program, initiated in 2006, was aimed at taking an inventory of records and information environment, conducting risk and process assessments and establishing baselines for improvement.  The ATIA provided a catalyst and focus for the Corporation to invest time and effort in Records Management practices and deliver education and awareness sessions through the Corporate Web site and e-learning course. 

Part F: Completion Time

What is the average completion time for all requests completed in 2009-2010?
190 days

Part G: Statistical Report on the Access to Information Act

15. Please attach your institution’s completed Report on theAccess to Information(Form TBS/SCT 350-62) for 2007-2008, 2008-2009 and 2009-2010. For institutions on a fiscal year other than April 1 st -March 31 st , include any supplemental reports where available.