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Privacy Act Annual Report to Parliament 2010–2011
April 1, 2010 to March 31, 2011
Table of Contents
Preface
The Privacy Act (Revised Statutes of Canada, Chapter A-1, 1985) was proclaimed on July 1, 1983.
The Privacy Act (the Act) extends to individuals the right of access to information about themselves held by the government, subject to specific and limited exceptions. The Act also protects the individual's privacy by preventing others from having access to personal information and gives individuals substantial control over its collection, use and disclosure.
Section 72 of the Act requires the head of every government institution to prepare an annual report to Parliament on the administration of the Act. This annual report describes how the Canada School of Public Service (the School) administered its responsibilities under the Act during the 2010-2011 fiscal year.
Mandate of the Canada School of Public Service
The School is part of the Treasury Board portfolio. The School's enabling legislation is the Canada School of Public Service Act, under which it has the following mandate:
- encourage pride and excellence in the Public Service;
- foster a common sense of purpose, values and traditions in the Public Service;
- support of the growth and development of public servants;
- help ensure that public servants have the knowledge, skills and competencies they need to do their jobs effectively;
- support deputy heads in meeting the learning needs of their organizations; and
- pursue excellence in public management and administration.
The School has a single strategic outcome: "Public Servants have the common knowledge and the leadership and management competencies they require to fulfil their responsibilities in serving Canadians." This strategic outcome is supported by four program activities: Foundational Learning, Organizational Leadership Development, Public Sector Management Innovation, and Internal Services.
Organization and Implementation
Privacy Act Activities
The Access to Information and Privacy (ATIP) Office is part of the Strategic Directions, Innovation and Program Development Directorate within the Strategic Directions, Program Development and Marketing Branch. It comprises one Director, who acts as the ATIP Coordinator for the School, and one ATIP Advisor.
The ATIP Coordinator is responsible for daily activities related to the administration of the Act.
The responsibilities of the School's ATIP Office include:
- processing requests for information submitted under the Act in accordance with legislation, regulations and Treasury Board Secretariat (TBS) policies and guidelines;
- promoting awareness of the Act within the organization and developing efficient internal procedures;
- responding to consultations received from external organizations;
- applying all discretionary and mandatory exemptions under the Act;
- providing advice and guidance to employees, management and requesters on the application of the Act;
- responding to access-related matters in the Management Accountability Framework (MAF);
- assisting the Office of the Information Commissioner (OIC) in all access to information related matters, including complaints;
- reviewing departmental documents, such as audit and evaluation reports, prior to their proactive disclosure on the institution's website;
- coordinating of the annual Info Source update and its submission to TBS;
- preparing the statistical and annual Privacy Act report to Parliament;
- participating in ATIP community activities, such as the Canadian Access and Privacy Association, the TBS ATIP community meetings and working groups.
Delegation of Authority
For the purpose of the Privacy Act, the Deputy Minister/President of the School delegated full authority to the Director/Coordinator of the ATIP Office.
The School's Policy and Guide to Access to Information and Privacy
The Policy and Guide to Access to Information and Privacy was developed to provide answers to questions about access to information and privacy from managers and employees of the School. The guide provides an overview of:
- the Access to Information Act, the Privacy Act and accompanying regulations;
- the policy at the School with respect to the Access to Information Act and the Privacy Act;
- the roles and responsibilities for ATIP within the School; and
- ATIP process and procedures.
In March 2010, the ATIP office created new internal processes. The School intends to review and update its 2008 guide by also making it accessible to all employees through the School's intranet, in the coming year.
Training and Awareness
In 2010-2011, there were two mandatory training sessions for the employees of the Human Resources Directorate, which were attended by 45 people. The School also offers a series of courses that provide an overview of ATIP; 117 School employees attended at least one of these courses during this reporting year.
Two Information Management (IM) Awareness presentations, which also provided an overview of ATIP, were given in November and December of 2010. The first presentation and workshop was with regional managers as part of a professional development meeting and the second was made to the regional executive assistants as part of a larger training session.
IM Awareness Sessions are currently delivered on an ad-hoc basis to the business units as requests for assistance are received and when a group is being prepared to receive the official School Information Classification Structure for records. ATIP is discussed during these sessions from the perspective of why it is important to manage information properly. The IM group also offers Welcome Sessions for all new employees that include a discussion of ATIP. IM communications often refer to ATIP when stressing the importance of cleaning up email and shared drives. Planned communications regarding the roll out of the GC Docs Electronic Document and Records Management System will also refer to ATIP in the context of the requirement for better management of information.
Implementation
All formal access requests received by the School are forwarded to the ATIP Office, where they are reviewed for clarity and conformity with the legislation. Each request is then assigned to the office(s) of primary interest, which become(s) responsible for locating and retrieving the records containing the relevant information. The ATIP Office tracks the progress of requests as they are distributed from and returned to the ATIP Office. The records are then analyzed and, if necessary, exemptions are applied.
Governance
The School's knowledge and activities related to ATIP are informed by a strong departmental commitment to IM. As part of this commitment, the IM Committee was established in 2008-2009 and became fully operational in 2009-2010. In addition to ensuring that department-wide information management practices and systems contribute to the achievement of the School's business objectives, the IM Committee provides guidance on the management of ATIP-related records. The ATIP Coordinator is the Co-chair of the Committee, thereby helping to build organizational awareness of ATIP issues and link these issues to IM strategies.
The IM Committee ensures focused attention on IM activities, particularly with regards to the assessment received by the School in the MAF for Area of Management 12 (Information Management).
More generally, in accordance with MAF, IM is an organization-wide priority and a responsibility of senior executives and managers. The School also participates in government-wide approaches to developing, implementing and sharing of IM policies and practices.
During 2010-2011, the School continued to focus on the implementation of its IM strategy and ensuring that its implementation plan remains up to date.
In March 2011, in accordance to the School's new governance structure, the IM and Information Technology (IT) committees were merged into the IM/IT Working Group, reporting to the Vice President and Director General level Information Services Committee. This working group is jointly chaired by the Director of Client Portfolio Management and Infrastructure and the Director of IM.
Activities Undertaken in Response to Recommendations from the Office of the Information Commissioner (OIC)
The OIC released a Special Report in February 2009 entitled "Systemic Issues Affecting Access to Information in Canada." The School implemented several government-wide learning activities in response to the recommendations of this report. These initiatives continue to support the learning needs of managers and federal public servants involved in responding to privacy requests.
Access to Information and Privacy Course
The School now offers as part of its curriculum a three-day ATIP course. Developed in collaboration with TBS in 2009-2010, this course provides an overview of the ATIP function as well as the roles and responsibilities of the various stakeholders involved.
The course was delivered on 14 occasions during the fiscal year with a total of 235 participants. Offerings were held in the National Capital Region, British Columbia, Quebec and the Atlantic Region.
Curriculum Update
The School has updated all references to ATIP in its IM curriculum and Authority Delegation Training (ADT) courses to ensure their completeness, accuracy and relevance. This initiative will ensure consistent messaging to all course participants. In addition, the updating of policy references in ADT course documentation will ensure that current information is delivered to newly appointed supervisors, managers and senior leaders. Over 8,800 managers and executives participated in this training in 2010-2011.
Armchair Discussions
The School's Armchair Discussion program provides a forum for discussion of programs and activities of interest. In October 2010, the Privacy Commissioner, Jennifer Stoddard, led a discussion regarding current privacy risks as well as measures to strengthen safeguards around the personal information of all Canadians. This event proved successful and raised the profile of privacy issues with public service participants.
Integrated Learning Strategy
In cooperation with the office of the Chief Information Officer and under the guidance of the Committee of Information Management in Business, the School completed work on an Integrated Learning Strategy for ATIP and IM specialists and generalists.
The Integrated Learning Strategy includes a series of recommendations that will guide efforts to develop, maintain, and enhance the skills and knowledge of the IM and ATIP communities across the federal Public Service over the next three years.
Complaints Received
No complaints were filed against the School during this reporting year.
Reading Room
Section 71 of the Access to Information Act requires government institutions to provide facilities where the public may inspect manuals used by employees of the institution in administering or carrying out programs or activities. In accordance with this section, the School has a library, designated as a public reading room. It is made available to the public upon request. The library is located at the following address:
Asticou Campus
241 Cité-des-Jeunes Boulevard, Room 1359
Gatineau, Quebec
K1N 6Z2
Privacy Impact Assessments and Data Matching/Sharing
During the reporting period, the School did not conduct any Preliminary Privacy Impact Assessments or Privacy Impact Assessments.
No data matching or data sharing activities were undertaken. The School made no disclosures of personal information pursuant to paragraphs 8(2)(e), (f), (g) or (m) of the Privacy Act.
Interpretation of the Privacy Act Statistical Report 2010-2011
Requests Received under the Act
Between April 1, 2010, and March 31, 2011, the School received three requests for personal information under the Privacy Act.
The requests were completed as follows:
- two requests were disclosed in full;
- one request was disclosed in part.
All three requests were completed within 30 days of receipt.
Text version
Trends in Privacy Requests for 2007-2008, 2008-2009, 2009-2010 and 2010-2011.
Exemptions and Exclusions
The School did not invoke any exemptions or cite any exclusions.
Costs
Total salary costs associated with the Privacy Act are estimated at $3,298, while the associated employee resources required are fixed at 0.05 full time equivalents.
Permissible Disclosure of Personal Information
Personal information collected by the School in the course of its programs and activities is disclosed only for the purpose for which it was collected, in accordance with paragraph 8(2)(a) of the Privacy Act. During 2010-2011, the School did not disclose personal information for any other purposes as outlined in paragraphs 8(2)(b) through (m).
Statistical Report
Institution: Canada School of Public Service
Reporting period: April 1, 2010 to March 31, 2011
I. Requests under the Privacy Act
Received during reporting period: 3
Outstanding from previous period: 0
TOTAL: 3
Completed during reporting period: 3
Carried forward: 0
II. Disposition of requests completed
- All disclosed: 2
- Disclosed in part: 1
- Nothing disclosed (excluded): 0
- Nothing disclosed (exempt): 0
- Unable to process: 0
- Abandoned by applicant: 0
- Transferred: 0
TOTAL: 3
III. Exemptions invoked
Subsection 18(2):
Paragraph 19(1)(a):
Paragraph 19(1)(b):
Paragraph 19(1)(c):
Paragraph 19(1)(d):
Section 20:
Section 21:
Paragraph 22(1)(a):
Paragraph 22(1)(b):
Paragraph 22(1)(c):
Subsection 22(2):
Paragraph 23(a):
Paragraph 23(b):
Section 24:
Section 25:
Section 26:
Section 27:
Section 28:
IV. Exclusions cited
Paragraph 69(1)(a):
Paragraph 69(1)(b):
Paragraph 70(1)(a):
Paragraph 70(1)(b):
Paragraph 70(1)(c):
Paragraph 70(1)(d):
Paragraph 70(1)(e):
Paragraph 70(1)(f):
V. Completion time
30 days or under: 3
31 to 60 days: 0
61 to 120 days: 0
121 days or over: 0
VI. Extensions
Interference with operations:
- 30 days or under:
- 31 days or over:
Consultation:
- 30 days or under:
- 31 days or over;
Translation:
- 30 days or under:
- 31 days or over:
TOTAL:
VII. Translations
Translations requested: 0
Translations prepared:
- English to French: 0
- French to English: 0
VIII. Method of access
Copies given: 3
Examination: 0
Copies and examination: 0
IX. Corrections and notation
Corrections requested: 0
Corrections made: 0
Notation attached: 0
X. Costs
Financial (all reasons):
- Salary: $3,225
- Administration (O and M): $73
TOTAL: $3,298
Person year utilization (all reasons):
- Person year (decimal format): 0.05
Supplemental Reporting Requirements
TBS is monitoring compliance with the Privacy Impact Assessment (PIA) Policy (which came into effect on May 2, 2002) and the Directive on Privacy Impact Assessment (which takes effect April 1, 2010) through a variety of means. Institutions are therefore required to report the following information for this reporting period. Note that because some institutions are using the Core PIA as outlined in the Directive in advance of the implementation deadline, they will not have Preliminary PIAs to report.
The Canada School of Public Service did not undertake any of the activities noted below during the reporting year of April 1, 2010 to March 31, 2011.
- Preliminary Privacy Impact Assessments initiated
- Preliminary Privacy Impact Assessments completed
- Privacy Impact Assessments initiated
- Privacy Impact Assessments completed
- Privacy Impact Assessments forwarded to the Office of the Privacy Commissioner
The Canada School of Public Service did not invoke any of the exemptions or exclusions noted below during the reporting period of April 1, 2010 to March 31, 2011.
Part III - Exemptions invoked
Paragraph 19(1)(e)
Paragraph 19(1)(f)
Section 22.1
Section 22.2
Section 22.3
Part IV - Exclusions cited
Section 69.1
Section 70.1
Delegation Order
Privacy Act
I, the undersigned President of the Canada School of Public Service, pursuant to section 73 of the Privacy Act, hereby authorize the Access to Information and Privacy Coordinator to exercise signing authorities or perform any of the President's powers, duties or functions vested in him by the Privacy Act.
Original signed by:
Michele Brenning for
Guy Mc Kenzie
Deputy Minister/President
Canada School of Public Service
Ottawa, Ontario
December 9, 2010
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