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Annual Report to Parliament on the Privacy Act 2013–2014

April 1, 2013 to March 31, 2014

Table of Contents


Introduction

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 2013-2014 fiscal year. This report is tabled in Parliament in accordance with section 72 of the Act.

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.

Delegation of Authority

For the purpose of the Act, the Deputy Minister/President of the School delegated full authority to the Senior Director of the Marketing and Communications Division and the Vice-President of the Strategic Directions, Program Development and Marketing Branch. A copy of the signed delegation instrument for the Act is included in Appendix B.

Organizational Structure of the ATIP Office and its Responsibilities

The Access to Information and Privacy (ATIP) Office is part of the Strategic Directions, Program Development and Marketing Branch. It is composed of one senior director, who acts as the ATIP Coordinator for the School, and two ATIP advisors. In an effort to comply with the requirements of the Privacy Act, one junior ATIP advisor was assigned to the ATIP Office to support privacy related activities, as well as temporary personnel.

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;
  • 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.

Interpretation of the Privacy Act Statistical Report 2013-2014

Requests Received under the Act

Between April 1, 2013 and March 31, 2014, the School received 15 requests for personal information under the Privacy Act. The School also had 5 outstanding requests from the previous reporting period. 19 requests were completed during the current year, and 1 was carried forward to the following year. The School did not receive any consultations from other government institutions or organizations.

Disposition of Completed Requests

  • Disclosed in full – 3
  • Disclosed in part – 15
  • No records exist – 1

Completion Time and Extensions

  • Completed between 1 to 15 days – 4
  • Completed between 16 to 30 days – 9
  • Completed between 31 to 60 days – 2
  • Completed between 61 to 120 days – 3
  • Completed between 121 to 180 days – 1

Section 15 of the Privacy Act provides for the extension of the statutory time limits for a maximum of 30 days if meeting the original time limit would unreasonably interfere with the operations of the government institution or if consultations are necessary to comply with the request that cannot reasonably be completed within the original time limit.

Of the 19 requests closed during this reporting year, 14 were completed within allowable time limits. In 4 instances, the School found it necessary to seek extensions of between 16 and 30 days to the prescribed time limits because of interference with operations or the need for consultations.

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 exemptions under section 26 (personal information) 15 times, paragraph 22(1) (b) (law enforcement and investigation) twice, section 22.3 (Public Servants Disclosure Protection Act) once and section 27 (solicitor-client privilege) twice.

Exclusions were not invoked in 2013-2014.

Format of Information Released

12 requests were released on paper, and 6 requests were released in electronic format.

Relevant Pages Disclosed

A total of 131 pages were disclosed in full, and a total of 7,632 pages were disclosed in part, for a total of 7,763 pages, in comparison to 33,149 pages released in 2012-2013.

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

Overview of Requests Received under the Privacy Act since 2011-2012. Select a fiscal year from the first column and then read across the row to the right for the number of requests received, the number of requests complete, the number of pages processed and the number of pages released.
Fiscal year Requests received Requests completed Endnotes* Number of pages processed Number of pages released
2013-2014 20 19 12,253 7,763
2012-2013 15 13 33,537 33,149
2011-2012 9 6 1,431 1,362

Costs

Salary costs related to the administration of the Privacy Act incurred by the ATIP Office are estimated at $112,887. Overhead and Maintenance costs are estimated at $56,141, for a total of $169,028.

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 2013-2014.

New Procedures, Guidelines and Directives

During the reporting year, the School developed a privacy breach protocol in response to the Office of the Privacy Commissioner's recommendations. A simplified version was also developed as a quick reference guide.

Training and Awareness

Training and awareness on the new privacy breach protocol was provided by the following means:

  • a presentation to the School's management team where 38 employees were present;
  • two ATIP workshops sessions held in November, in which 30 employees participated;
  • informal consultation when advice and guidance was needed; and
  • the School's internal newsletter.

Employees also received further information about their roles and responsibilities in the management and protection of information though the internal newsletter.

A dedicated section on the School's intranet site provides School employees and ATIP liaison officers with key information on ATIP and reiterates employee accountability for ensuring that personal information is handled discreetly and professionally.

The ATIP office continually works to inform and guide employees and requesters regarding the requirements of the Privacy Act by means of ongoing dialogue and informal discussions. During the reporting period, the employees of the ATIP office responded to inquiries from employees and management, providing advice and guidance on various subjects pertaining to the Act.

Complaints

One outstanding complaint (OPC file # 7100-012789) from fiscal year 2012-2013 is now closed. The complaint was considered well-founded. The requester alleged that the School improperly disclosed personal information about him/her to other individuals.

Three complaints were filed against the School in 2013-2014. In OPC file # PA-031687 and # PA-031771, the requester complained about the delay in responding to the request for personal information. In OPC file # PA-031686, the requester complained about the use of exemptions in processing the request for personal information. Investigations of all three complaints are ongoing with the Office of the Privacy Commission.

Monitoring Time of Process

Since the School is a small institution with a relatively low number of requests in comparison to other institutions, the Vice-President of the Strategic Directions, Program Development and Marketing Branch is kept informed of the time taken to process personal information requests through ongoing verbal briefings.

Material Privacy Breaches

No material privacy breaches occurred during the reporting year.

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.

Appendix A – Statistical Report

Name of institution: Canada School of Public Service

Reporting period: 01/04/2013 to 31/03/2014

PART 1 – Requests under the Privacy Act

Number of requests

Received during reporting period: 15

Outstanding from previous reporting period:5

Total: 20

Closed during reporting period: 19

Carried over to next reporting period: 1

Part 2 – Requests closed during the reporting period

2.1 Disposition and completion time

Disposition and completion time. Read down the first column to the type of disposition that interests you. Read across the row to the right for the number of dispositions per completion time: 1 to 15 days, 16 to 30 days, 31 to 60 days, 61 to 120 days, 121 to 180 days, 181 to 365 days, and more than 365 days. Totals are provided in the last column and last row of the table.
Completion time
Disposition of requests 1 to 15 days 16 to 30 days 31 to 60 days 61 to 120 days 121 to 180 days 181 to 365 days More than
365 days
Total
2 0 1 0 0 0 0 3
Disclosed in part 1 9 1 3 1 0 0 15
All exempted 0 0 0 0 0 0 0 0
All excluded 0 0 0 0 0 0 0 0
No records exist 1 0 0 0 0 0 0 1
Request abandoned 0 0 0 0 0 0 0 0
Total 4 9 2 3 1 0 0 19

2.2 Exemptions

18(2): 0

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

20: 0

21: 0

22(1)(a)(i): 0
22(1)(a)(ii): 0
22(1)(a)(iii): 0
22(1)(b): 2
22(1)(c): 0
22(2): 0
22.1: 0
22.2: 0
22.3: 2

23(a): 1
23(b): 0

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

25: 0

26: 15

27: 2

28: 0

2.3 Exclusions

69(1)(a): 0
69(1)(b): 0
69.1: 0

70(1)(a): 0
70(1)(b): 0
70(1)(c): 0
70(1)(d): 0
70(1)(e): 0
70(1)(f): 0
70.1: 0

2.4 Format of information released

All disclosed:

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

Disclosed in part:

  • Paper: 10
  • Electronic: 5
  • Other formats: 0

Total:

  • Paper: 12
  • Electronic: 6
  • Other formats: 0

2.5 Complexity

2.5.1 Relevant pages processed and disclosed
Relevant pages processed and disclosed. Read down the first column to the type of disposition that interests you. Read across the row to the right for the number of pages processed, number of pages disclosed and number of requests.
Disposition of requests Number of pages processed Number of pages disclosed Number of requests
All disclosed 131 131 3
Disclosed in part 12,122 7,632 15
All exempted 0 0 0
All excluded 0 0 0
Request abandoned 0 0 0
2.5.2 Relevant pages processed and disclosed by size of requests
Relevant pages processed and disclosed by size of requests. Read down the first column to the type of disposition that interests you. Read across the row to the right for the number of requests and the number of pages disclosed for the following five categories: less than 100 pages processed, 101-500 pages processed, 501-1000 pages processed, 1001-5000 pages processed and more than 5000 pages processed. There are two columns for each category: the first column presents the number of requests and the second column presents the number of pages disclosed. Totals are provided in the last row of the table.
Disposition Less than 100
pages processed
101-500
pages processed
501-1,000
pages processed
1,001-5,000
pages processed
More than 5,000
pages processed
Number of requests Pages disclosed Number of requests Pages disclosed Number of requests Pages disclosed Number of requests Pages disclosed Number of requests Pages disclosed
All disclosed 2 7 1 124 0 0 0 0 0 0
Disclosed in part 4 70 6 655 1 849 4 6,058 0 0
All exempted 0 0 0 0 0 0 0 0 0 0
All excluded 0 0 0 0 0 0 0 0 0 0
Abandoned 0 0 0 0 0 0 0 0 0 0
Total 6 77 7 779 1 849 4 6,058 0 0
2.5.3 Other complexities
Other complexities. Read down the first column to the type of disposition that interests you. Read across the row to the right for the number of dispositions in these categories: consultation required, legal advice sought, interwoven information and other. Totals are provided in the last column and last row of the table.
Disposition Consultation required Legal advice sought Interwoven information Other Total
All disclosed 0 1 0 0 1
Disclosed in part 2 2 5 1 10
All exempted 0 0 0 0 0
All excluded 0 0 0 0 0
Abandoned 0 0 0 0 0
Total 2 3 5 1 11

2.6 Deemed refusals

2.6.1 Reasons for not meeting statutory deadline

Number of requests closed past the statutory deadline: 5

Principal Reason:

  • Workload: 3
  • External consultation: 1
  • Internal consultation: 1
  • Other: 0
2.6.2 Number of days past deadline
Number of days past deadline. Read down the first column to the number of days past deadline that interests you. Read across the row to the right for the number of requests past deadline where no extension was taken and the number of requests past deadline where an extension was taken. Totals are also provided in the last column and last row of the table.
Number of days past deadline Number of requests past deadline where no extension was taken Number of requests past deadline where an extension was taken Total
1 to 15 days 1 1 2
16 to 30 days 0 0 0
31 to 60 days 0 1 1
61 to 120 days 0 1 1
121 to 180 days 1 0 1
181 to 365 days 0 0 0
More than 365 days 0 0 0
Total 2 3 5

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

Part 5 – Extensions

5.1 Reasons for extensions and disposition of requests

Reasons for extensions and disposition of requests. Read down the first column to the type of disposition where an extension was taken that interests you. Read across the row to the right for the number of extensions for each of the following three reasons: 15(a)(i) - Interference with operations, 15(a)(ii) - Consultation and 15(b) - Translation or conversion. 15(a)(ii) - Consultation is split into two columns: the first column presents section 70 and the second column is other. Totals are provided in the last row of the table.
Disposition of requests where an extension was taken 15(a)(i)
Interference with
operations
15(a)(ii)
Consultation
15(b)
Translation or
conversion
Section 70 Other
All disclosed 0 0 0 0
Disclosed in part 2 0 2 0
All exempted 0 0 0 0
All excluded 0 0 0 0
No records exist 0 0 0 0
Request abandoned 0 0 0 0
Total 2 0 2 0

5.2 Length of extensions

Length of extensions. Read down the first column to the length of extension that interests you. Read across the row to the right for the number of extensions for each of the following reasons: 15(a)(i) - Interference with operations, 15(a)(ii) - Consultation and 15(b) - Translation or conversion. 15(a)(ii) - Consultation is split into two columns: the first column presents section 70 and the second column is other. Totals are provided in the last row of the table.
Length of extensions 15(a)(i)
Interference with
operations
15(a)(ii)
Consultation
15(b)
Translation
purposes
Section 70 Other
1 to 15 days 0 0 0 0
16 to 30 days 2 0 2 0
Total 2 0 2 0

Part 6 – Consultations received from other institutions and organizations

6.1 Consultations received from other government institutions and organizations

Consultations received from other government institutions and organizations. Read down the first column to the consultation status that interests you. Read across the row to the right for the number of consultations with other government institutions and the number of pages to review in columns two and three, and the number of consultations with other organizations and the number of pages to review in columns four and five. Totals are provided in the third row of the table.
Consultations Other government institutions Number of pages to review Other organizations Number of pages to review
Received during the reporting period 0 0 0 0
Outstanding from the previous reporting period 0 0 0 0
Total 0 0 0 0
Closed during the reporting period 0 0 0 0
Pending at the end of the reporting period 0 0 0 0

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

Recommendations and completion time for consultations received from other organizations. Read down the first column to the recommendation that interests you. Read across the row to the right for the number of days required to complete the consultation requests: 1 to 15 days, 16 to 30 days, 31 to 60 days, 61 to 120 days, 121 to 180 days, 181 to 365 days and more than 365 days. Totals are provided in the last column and last row of the table.
Recommendation Number of days required to complete consultation requests
1 to 15 days 16 to 30 days 31 to 60 days 61 to 120 days 121 to 180 days 181 to 365 days More than 365 days Total
Disclose entirely 0 0 0 0 0 0 0 0
Disclose in part 0 0 0 0 0 0 0 0
Exempt entirely 0 0 0 0 0 0 0 0
Exclude entirely 0 0 0 0 0 0 0 0
Consult other institution 0 0 0 0 0 0 0 0
Other 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0

6.3 Recommendations and completion time for consultations received from other organizations

Recommendations and completion time for consultations received from other government institutions. Read down the first column to the recommendation that interests you. Read across the row to the right for the number of days required to complete the consultation requests: 1 to 15 days, 16 to 30 days, 31 to 60 days, 61 to 120 days, 121 to 180 days, 181 to 365 days and more than 365 days. Totals are provided in the last column and last row of the table.
Recommendation Number of days required to complete consultation requests
1 to 15 days 16 to 30 days 31 to 60 days 61 to 120 days 121 to 180 days 181 to 365 days More than 365 days Total
Disclose entirely 0 0 0 0 0 0 0 0
Disclose in part 0 0 0 0 0 0 0 0
Exempt entirely 0 0 0 0 0 0 0 0
Exclude entirely 0 0 0 0 0 0 0 0
Consult other institution 0 0 0 0 0 0 0 0
Other 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0

Part 7 – Completion time of consultations on Cabinet confidences

Completion time of consultations on Cabinet confidences. Read down the first column to the number of days that interests you. Read across the row to the right for the number responses received and the number of responses received past deadline. Totals are provided in the last row of the table.
Number of days Number of responses received Number of responses
received past deadline
1 to 15 days 0 0
16 to 30 days 0 0
31 to 60 days 0 0
61 to 120 days 0 0
121 to 180 days 0 0
181 to 365 days 0 0
More than 365 days 0 0
Total 0 0

Part 8 – Resources related to the Privacy Act

8.1 Costs

Expenditures:

  • Salaries: $112,887
  • Overtime: $0
  • Goods and services: $56,141
    • Contracts for privacy impact assessments: $0
    • Professional services contracts: $46,620
    • Other: $9,521
  • Total: $169,028

8.2 Human Resources

Human Resources. Read down the first column to the type of resource that interests you. Read across the row to the right for the number dedicated full-time to ATI activities and the number dedicated part-time to ATI activities and total. Totals are provided in the last column and last row of the table.
Resources Dedicated full-time Dedicated part-time Total
Full-time employees 0.52 1.52 2.04
Part-time and casual employees 0.00 0.00 0.00
Regional staff 0.00 0.00 0.00
Consultants and agency personnel 0.34 0.00 0.34
Students 0.00 0.00 0.00
Total 0.86 1.52 2.38

Appendix A – Supplementary Reporting

Institution: Canada School of Public Service

Number of completed PIAs: Nil

The Canada School of Public Service did not process any Cabinet Confidences under the Privacy Act (PA) during the reporting year. It also has not completed any PIAs during that time.

Completion time of consultations on Cabinet Confidences under the PA – requests with Legal Services

Completion time of consultations on Cabinet Confidences under the PA – requests with Legal Services. Read down the first column to the number of days that interests you. Read across the row to the right for the number of requests and the number of pages disclosed for the following five categories: fewer than 100 pages processed, 101-500 pages processed, 501-1,000 pages processed, 1,001-5000 pages processed and more than 5000 pages processed. There are two columns for each category: the first column presents the number of requests and the second column presents the number of pages disclosed. Totals are provided in the last row of the table.
Number of days Fewer than 100
pages processed
101‒500
pages processed
501‒1,000
pages processed
1,001‒5,000
pages processed
More than 5,000
pages processed
Number
of requests
Pages
disclosed
Number of
requests
Pages
disclosed
Number of
requests
Pages
disclosed
Number of
requests
Pages
disclosed
Number of
requests
Pages
disclosed
1 to 15 0 0 0 0 0 0 0 0 0 0
16 to 30 0 0 0 0 0 0 0 0 0 0
31 to 60 0 0 0 0 0 0 0 0 0 0
61 to 120 0 0 0 0 0 0 0 0 0 0
121 to 180 0 0 0 0 0 0 0 0 0 0
181 to 365 0 0 0 0 0 0 0 0 0 0
More than 365 0 0 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0 0 0

Completion time of consultations on Cabinet Confidences under the PA – requests with Privy Council Office

Completion time of consultations on Cabinet Confidences under the PA – requests with Privy Council Office. Read down the first column to the number of days that interests you. Read across the row to the right for the number of requests and the number of pages disclosed for the following five categories: fewer than 100 pages processed, 101-500 pages processed, 501-1,000 pages processed, 1,001-5000 pages processed and more than 5000 pages processed. There are two columns for each category: the first column presents the number of requests and the second column presents the number of pages disclosed. Totals are provided in the last row of the table.
Number of days Fewer than 100
pages processed
101‒500
pages processed
501‒1,000
pages processed
1,001‒5,000
pages processed
More than 5,000
pages processed
Number
of requests
Pages
disclosed
Number of
requests
Pages
disclosed
Number of
requests
Pages
disclosed
Number of
requests
Pages
disclosed
Number of
requests
Pages
disclosed
1 to 15 0 0 0 0 0 0 0 0 0 0
16 to 30 0 0 0 0 0 0 0 0 0 0
31 to 60 0 0 0 0 0 0 0 0 0 0
61 to 120 0 0 0 0 0 0 0 0 0 0
121 to 180 0 0 0 0 0 0 0 0 0 0
181 to 365 0 0 0 0 0 0 0 0 0 0
More than 365 0 0 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0 0 0

Appendix B – Delegation Orders

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:


Linda Lizotte-MacPherson
Deputy Minister/President
Canada School of Public Service

Ottawa, Ontario
December 19, 2013


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::


Linda Lizotte-MacPherson
Deputy Minister/President
Canada School of Public Service

Ottawa, Ontario
March 9, 2013


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