Annual Report to Parliament on the Privacy Act 2011–2012

April 1, 2011 to March 31, 2012

Table of Contents

• Preface
• Mandate of the Canada School of Public Service
• Organization and implementation
  • Privacy Act activities
  • Delegation of Authority
  • The School's Access to Information and Privacy Handbook
  • Training and awareness
  • Implementation
  • Governance
  • Complaints received
  • Reading room
• Privacy impact assessments and data matching/sharing
• Interpretation of the Privacy Act Statistical Report
• Appendix A - Statistical Report
• Appendix B - Supplementary reporting requirements
• Delegation Order

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 2011-2012 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 is mandated to:

• encourage pride and excellence in the Public Service;
• foster a common sense of purpose, values and traditions in the Public Service;
• support 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;
• assist deputy heads in meeting the learning needs of their organizations; and
• pursue excellence in public management and administration.

This mandate is delivered through four program activities: Foundational Learning, Organizational Leadership Development, Public Sector Management Innovation and Internal Services.

The School ensures that public servants have the common knowledge and the leadership and management competencies they require to fulfil their responsibilities in serving Canadians.

Organization and implementation

Privacy Act activities

The Access to Information and Privacy (ATIP) Office is part of the Strategic Directions and Governance Division within the Strategic Directions, Program Development and Marketing Branch. It is comprised of 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 Privacy 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 of Canada Secretariat (TBS) policies and guidelines;
• responding to consultations received from other 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;
• assisting the Office of the Privacy Commissioner in responding to all questions related to privacy, including complaints;
• reviewing departmental documents, such as audit and evaluation reports, prior to their proactive disclosure on the institution's Web site;
• coordinating the annual Info Source update and submission to TBS;
• preparing the statistical and annual Privacy Act report to Parliament; and
• 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 President of the School delegated full authority to the Director/Coordinator of the ATIP Office. A copy of the signed delegation instrument for the Act is included.

The School's Access to Information and Privacy Handbook

A handbook has been developed by the ATIP Office to introduce the legislation and regulations to ATIP liaison officers, outline the roles and responsibilities of the School's ATIP stakeholders, identify the standards for processing requests, inform ATIP liaison officers of the procedures associated with record retrieval and identify reference material available to ATIP liaison officers. The Handbook is available online on the School's intranet site and will be updated on a regular basis.

Training and awareness

In December 2011 and January 2012, the School's ATIP Office organized six training and awareness sessions on the Access to Information Act and the Privacy Act with a School instructor. Two other sessions were offered by the ATIP Coordinator in February 2012. Employees in regional offices were able to participate in one English session via Webcast and one French session via videoconference.

A total of 193 School employees participated in the training and awareness sessions.

Two sessions (one bilingual session and one in English) were recorded and made available to employees in the National Capital Region; copies have also been sent to each regional office. Awareness sessions on both Acts will be offered to employees on a regular basis.

In the last few months, a new section devoted to ATIP has been developed on the School's intranet site. The section includes the Handbook, a link to both Acts and useful FAQs. An "ATIP Tips" section is currently under development.

As part of the Open Government initiative, the posting of monthly summaries of completed Access to Information requests became mandatory. The School has been posting summaries on its Internet site since October 2011.

Over the coming months, a new section devoted to ATIP will be added to an orientation guide for new employees of the School. 

Implementation

All formal access requests received by the School are forwarded to the ATIP Office, where they are reviewed for clarity and compliance 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 information sought and assisting in determining the costs and fees for processing the request. The ATIP Office tracks the progress of requests with each office of primary interest.

Governance

The School's activities related to privacy are informed by a strong departmental commitment to information management. The ATIP Office provides guidance on the management of privacy-related records and the ATIP Coordinator builds organizational awareness of ATIP issues and links these issues to information management strategies.

In April 2010, a new TBS directive was established that included new provisions regarding the duty to assist requesters. In keeping with this directive, the ATIP Office took steps to inform applicants of the principles surrounding the School's obligations under the "Duty to Assist" provisions of the Access to Information Act. 

New standards and procedures have been developed by the ATIP Office with regards to:

• communicating with applicants to clarify requests;
• ensuring that the identity of applicants is not shared beyond the ATIP Office;
• respecting the nature of the Act's exemption provisions;
• informing applicants of their right to complain to the Information Commissioner of Canada and advising them on how to avail themselves of this right; 
• evaluating the training and awareness sessions;
• avoiding/preventing privacy breaches;
• improving the processing of requests.

The ATIP Office and its governance structure effectively support the organization's administration of access to information and privacy. Training is an integral part of this effective management. The ATIP Office is also responsible for items 12.4, 12.5 and 12.6 of the Area of Management on Information Management under the Management Accountability Framework (MAF). 

In accordance with MAF, information management 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 information management policies and practices.

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 de la Cité-des-Jeunes Boulevard, Room 1359
Gatineau, Quebec
K1N 6Z2

Privacy impact assessments and data matching/sharing

During the reporting period, the School conducted one Preliminary Privacy Impact Assessment and no Privacy Impact Assessments.

No data matching or data sharing activities were undertaken. Additionally, during the reporting period, the School made no disclosures of personal information pursuant to paragraphs 8(2)(e), (f), (g) or (m) of the Privacy Act.

The Department continues to update and review its personal information banks to ensure consistency with TBS requirements.

Interpretation of the Privacy Act Statistical Report

Requests received under the Privacy Act

Between April 1, 2011 and March 31, 2012, the School received nine requests for personal information under the Privacy Act. The School closed six of these requests during the reporting period; three were carried over to the next reporting period. 

The requests were completed as follows:

• three requests were disclosed in part;
• three requests were abandoned.

Of the three requests completed, two were completed within 30 days and one between 31 and 60 days.   

Exemptions and exclusions

The School invoked, as an exemption, section 26 of the Privacy Act three times. The School did not cite any exclusions. 

Method of access

All records were released on paper and compact disc to the requesters.

Costs

Total salary costs associated with the Privacy Act are estimated at $91,052, while the associated employee resources required are fixed at 1.5 dedicated part-time or full-time employees. 

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 2011-2012, the School did not disclose personal information for any other purposes as outlined in paragraphs 8(2)(b) through (m) inclusively.

Appendix A - Statistical Report

Name of institution: Canada School of Public Service

Reporting period: April 1, 2011 to March 31, 2012

Part 1 - Requests under the Privacy Act

Number of requests
Received during the reporting period: 9
Outstanding from previous reporting period: 0
Total: 9
Closed during reporting period: 6
Carried over to next reporting period: 3

Part 2 - Requests closed during the reporting period

2.1 Disposition and completion time

2.2 Exemptions

Subsection 18(2): 0

Paragraph 19(1)(a): 0
Paragraph 19(1)(b): 0
Paragraph 19(1)(c): 0
Paragraph 19(1)(d): 0
Paragraph 19(1)(e): 0
Paragraph 19(1)(f): 0

Section 20: 0

Section 21: 0

Subparagraph 22(1)(a)(i): 0
Subparagraph 22(1)(a)(ii): 0
Subparagraph 22(1)(a)(iii): 0
Paragraph 22(1)(b): 0
Paragraph 22(1)(c): 0

Subsection 22(2): 0

Section 22.1: 0

Section 22.2: 0

Section 22.3: 0

Paragraph 23(a): 0
Paragraph 23(b): 0

Paragraph 24(a): 0
Paragraph 24(b): 0

Section 25: 0

Section 26: 3

Section 27: 0

Section 28: 0

2.3 Exclusions

Paragraph 69(1)(a): 0
Paragraph 69(1)(b): 0

Section 69.1: 0

Paragraph 70(1)(a): 0
Paragraph 70(1)(b): 0
Paragraph 70(1)(c): 0
Paragraph 70(1)(d): 0
Paragraph 70(1)(e): 0
Paragraph 70(1)(f): 0

Section 70.1: 0

2.4 Format of information released

All disclosed:

• Paper: 0
• Electronic: 0
• Other formats: 0

Disclosed in part:

• Paper: 2
• Electronic: 1
• Other formats: 0

2.5 Complexity

2.5.1 Relevant pages processed and disclosed

2.5.2 Relevant pages processed and disclosed by size of requests

2.5.3 Other complexities

2.6 Deemed refusals

2.6.1 Reasons for not meeting statutory deadline

Number of requests closed past the statutory deadline: 2

Principal Reason:

• Workload: 0
• External consultation: 1
• Internal consultation: 0
• Other: 1

2.6.2 Number of days past deadline

2.7 Requests for translation

English to French:

• Accepted: 0
• Refused: 0
• Total: 0

French to English:

• Accepted: 0
• Refused: 0
• Total: 0

Part 3 - Disclosures under subsection 8(2)

Paragraph 8(2)(e): 0
Paragraph 8(2)(m): 0
Total: 0

Part 4 - Requests for correction of personal information and notations

Requests for correction received: 0
Requests for correction accepted: 0
Requests for correction refused: 0
Notations attached: 0

Partie 5 - Extensions

5.1 Reasons for extensions and disposition of requests

5.2 Length of extensions

Part 6 - Consultations received from other institutions and organizations

6.1 Consultations received from other government institutions and organizations

6.2 Recommendations and completion time for consultations received from other government institutions

6.3 Recommendations and completion time for consultations received from other organizations

Part 7 - Completion time of consultations on Cabinet confidences

Part 8 - Resources related to the Privacy Act

8.1 Costs

Expenditures:

• Salaries: $91,052
• Overtime: $408
• Goods and Services: $632
  • Contracts for privacy impact assessments: $0
  • Professional services contracts: $0
  • Other: $632
• Total: $92,092

8.2 Human Resources

Appendix B - Supplemental reporting requirements

The Treasury Board of Canada Secretariat is monitoring compliance with the Directive on Privacy Impact Assessment (which came into 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 undertook these activities noted below during the reporting year of April 1, 2011 to March 31, 2012.

• Preliminary Privacy Impact Assessments initiated
• Preliminary Privacy Impact Assessments completed

The Canada School of Public Service did not undertake any of the activities noted below during the reporting year of April 1, 2011 to March 31, 2012.

• Privacy Impact Assessments initiated
• Privacy Impact Assessments completed
• Privacy Impact Assessments forwarded to the Office of the Privacy Commissioner

As well, the Canada School of Public Service invoked exemptions under section 26 and did not cite any exclusions during the reporting period of April 1, 2011 to March 31, 2012.

Part III - Exemptions invoked

Section 26

Part IV - Exclusions cited

None

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.

Ottawa, Ontario
December 9, 2010

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