Annual Report to Parliament on the Privacy Act 2012–2013

April 1, 2012 to March 31, 2013

Table of Contents

• Preface
• Mandate of the Canada School of Public Service
• Privacy Act Activities
• Delegation of Authority
• Privacy Breach Protocol
• Training and Awareness
• Governance
• Complaints Received
• Reading Room
• Privacy Impact Assessments
• Interpretation of the Privacy Act Statistical Report 2012-2013
• Appendices
  • Statistical Report
  • Completed Privacy Impact Assessments (PIAs)
  • Delegation Orders

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.

This annual report describes how the Canada School of Public Service (the School) administered its responsibilities under the Act during the 2012-2013 fiscal year. This report is tabled in Parliament in accordance with section 72 of the Act.

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.

Privacy Act Activities

The Access to Information and Privacy (ATIP) Office is part of 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 School experienced an increase in the number of requests during this reporting year. In an effort to comply with the requirements of the Privacy Act, one additional advisor was assigned to the ATIP Office to support privacy-related activities.

During the last quarter of this reporting year, the ATIP Coordinator's responsibilities were transferred to the Director General of the Marketing and Communications Division as a result of organizational changes undertaken in 2012-2013.

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 personal 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 government institutions and organizations;
• providing advice and guidance to requesters on the application of the Act as well as awareness and training to School employees;
• responding to access-related matters in the Management Accountability Framework (MAF);
• assisting the Office of the Privacy Commissioner in the resolution of complaints;
• reviewing departmental documents prior to their proactive disclosure on the School's Web site;
• ensuring that the School's personal information holdings are published in Info Source;
• preparing the statistical report (included in Appendix A of this report) and the annual Privacy Act report to Parliament; and
• participating in ATIP community activities, such as the TBS ATIP practitioners' community meetings and working groups.

Delegation of Authority

For the purpose of the Act, the Deputy Minister/President of the School delegated full authority to the Director General, Marketing and Communications Division, and the Vice-President, Strategic Directions, Program Development and Marketing Branch. Copies of the signed delegation instrument for the Act are included in the Appendices.

Privacy Breach Protocol

The School is developing a privacy breach protocol to respond to any unauthorized access to, or collection, use, or disclosure of, personal information.

Training and Awareness

Between October 2012 and February 2013, the School's ATIP Office organized and delivered four training and awareness sessions on the Access to Information Act and the Privacy Act.

A total of 86 School employees participated in the training and awareness sessions.

In 2012, a new section devoted to ATIP was developed on the School's intranet Web site. The section includes a link to the Privacy Act, answers to frequently asked questions and a handbook for ATIP liaison officers.

The handbook was developed by the ATIP Office to introduce the ATIP legislation and regulations, 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.

As a result of the ATIP Office's workload, no policies, guidelines and procedures related to privacy were updated or implemented during this reporting year.

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 has continued to take steps to inform applicants of the principles surrounding the School's obligations under the "Duty to Assist" provisions of the Privacy Act.

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 MAF; however, this Area of Management was not assessed during this reporting year.

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

During this reporting year, one complaint was filed under the Privacy Act with the Office of the Privacy Commissioner. The investigation was not yet completed as of March 31, 2013.

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

During this reporting period, the School did not initiate or complete any Privacy Impact Assessments.

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

Interpretation of the Privacy Act Statistical Report 2012-2013

Requests Received under the Act

Between April 1, 2012 and March 31, 2013, the School received 15 requests for personal information under the Privacy Act. The School also had 3 outstanding requests from the previous reporting period. The School completed 13 requests during the reporting period; 5 were carried forward to the next reporting period.

In addition, the School received one consultation request under the Act from another department with eight pages to review and recommended that the records be disclosed in part.

Disposition of Completed Requests

• Disclosed in full – 2
• Disclosed in part – 9
• All exempted – 0
• All excluded – 0
• No records exist – 1
• Request abandoned – 1

Completion Time and Extensions

• Completed between 1 to 15 days – 1
• Completed between 16 to 30 days – 2
• Completed between 31 to 60 days – 7
• Completed between 61 to 120 days – 3

Of the 13 requests closed during this reporting year, 7 were completed within allowable time limits. In 9 instances, the School found it necessary to seek extensions of between 16 to 30 days to the prescribed time limits because of interference with operations and translation.

Exemptions and Exclusions

This section of the Statistical Report is intended to identify the number of requests in which specific exemptions or exclusions were invoked. If the same exemption or exclusion is claimed several times for the same request, it is reported only once.

The School invoked exemption section 26 (personal information) 9 times and section 27 (solicitor-client privilege) once.

Exclusions were not invoked in 2012-2013.

Format of Information Released

One request was released on paper, nine requests were released by electronic format and one request was released by way of another format.

Relevant Pages Disclosed

There was a significant increase in the number of pages processed and released from that of the previous year.

A total of 21,796 pages were disclosed in full, and a total of 11,353 pages were disclosed in part, for a total of 33,149 pages, in comparison to 1,362 pages released in 2011-2012.

Overview of Requests Received under the Privacy Act Since 2011-2012

Deemed Refusals

Four requests were completed after the statutory deadline due to the number of pages the ATIP Office had to process for requests under the Access to Information Act and the Privacy Act.

Costs

Salary costs related to the administration of the Privacy Act incurred by the ATIP Office are estimated at $134,002, with Overhead and Maintenance costs at $2,009, for a total of $136,011. The dedicated resources for 2012-2013 were fixed at three part-time employees.

Disclosures under Paragraph 8(2)(m) of the Privacy Act

Paragraph 8(2)(m) of the Act allows for the disclosure of personal information when the public interest clearly outweighs any invasion of privacy or when the disclosure would benefit the individual. There were no disclosures pursuant to paragraph 8(2)(m) for the period of 2012-2013.

Appendices

Statistical Report

Name of institution: Canada School of Public Service

Reporting period: April 1, 2012 to March 31, 2013

Part 1 – Requests under the Privacy Act

Number of requests
Received during the reporting period: 15
Outstanding from previous reporting period: 3
Total: 18
Closed during reporting period: 13
Carried over to next reporting period: 5

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: 9

Section 27: 1

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: 1
• Electronic: 0
• Other formats: 1

Disclosed in part:

• Paper: 0
• Electronic: 9
• Other formats: 0

Total:

• Paper: 1
• Electronic: 9
• Other formats: 1

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: 4

Principal Reason:

• Workload: 4
• External consultation: 0
• Internal consultation: 0
• Other: 0

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: $134,002
• Overtime: $0
• Goods and Services: $2,009
  • Contracts for privacy impact assessments: $0
  • Professional services contracts: $0
  • Other: $2,009
• Total: $136,011

8.2 Human Resources

Completed Privacy Impact Assessments (PIAs)

Institution: Canada School of Public Service

Number of completed PIAs: Nil

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 13, 2012

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
March 10, 2013

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