2023 Management Action Plan, Evaluator’s Recommendations - Investigations Program evaluation, phase I, Final Report
The Office of the Information Commissioner of Canada (OIC) developed this Management Action Plan (MAP) following receipt of Samson’s final evaluation report on the OIC’s registry function. During the evaluation, Samson made some key observations on specific issues and the OIC is committed to take the necessary actions to address each one.
Auditor’s observations | OIC commitments | Action item | Lead | Target date | Progress | Follow up / update |
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1. Improving the Registry’s electronic tools (i.e., Intrac) would increase its efficiency | 1.1 Update the Registry’s electronic tools and automate functions where feasible. | 1.1.1 Identify business needs and evaluate the feasibility (technical & operational) of potential options. 1.1.2 Present findings and recommendations to SMC. 1.1.3 Implement approved changes. | Corporate Services Sector | Ongoing December 21, 2021 Q1 2022-23 | Completed | Following a major update to Intrac in May 2022, a complete reworking of the Investigations module, and further 41 improvements to various modules and automated functions, CRM Dynamics now uses a more automated and efficient task-based process. Multiple improvements to the automated approval processes for notices, reports, forms and templates increased overall efficiency. While action is closed, the OIC remains committed to the further advancement in this area. |
2. Providing more information on the grounds of complaint in the OIC’s notice of investigations could allow institutions to respond quicker and more accurately to requests for documents. | 2.1 Provide additional clarity to institutions while maintaining flexibility in the OIC’s investigative processes. | 2.1.1 Identify opportunities and challenges for more targeted communications from the Registry. 2.1.2 Present findings and recommendations to SMC. 2.1.3 Implement approved changes. | Investigations Sector | Ongoing December 1, 2022 Revised date Q4 2022-23 | Completed | The new notice of investigation providing additional details to institutions on complaints was implemented on April 1, 2023, as well as the updated initial request for documents the Registry sends to institutions at the outset of the investigation. |
3. Time frames for responding to requests for documentation are too short, and extensions have become the norm. | 3.1 Provide reasonable deadlines for institutions to provide documents to the Registry | 3.1.1 Review deadlines and rates of compliance with deadlines related to the provision of documents from institutions. 3.1.2 Present findings and recommendations to SMC. 3.1.3 Implement approved changes. | Investigations Sector | Ongoing December 1, 2022 Q4 2022-23 | Completed | The timeline for institutions to provide documents in response to the updated initial request for documents was adjusted. |
4. Using the same documents for multiple related complaints could reduce redundancies. | 4.1 Explore opportunities for using the same documents for multiple complaints. | 4.1.1 Determine the feasibility (operational & legal) of using the same documents for multiple related complaints. 4.1.2 Present findings and recommendations to SMC. 4.1.3 Implement approved changes. | Investigations Sector & Legal Services | Q4 2021-2022 Q1 2022-2023 Q2 2022-2023 | No longer relevant | We examined the issue, and determined that this commitment is no longer relevant. When documents are re-requested from institutions, it is to obtain an updated copy. We do not generally ask more than once for the same documents. |
5. Monthly status reports would help institutions coordinate activities in their own departments on an ongoing basis. | 5.1 Increase transparency by providing monthly status reports to all institutions | 5.1.1 Develop a plan to share monthly status updates from Intrac to institutions. | Q4 2021-2022 | |||
5.1.2 Present findings and recommendations to SMC. 5.1.3 Implement approved solution. | Investigations Sector | Q1 2022-2023 Q2 2022-2023 | Completed | The Directors agreed that status reports would be managed and generated by each team for the institutions within their respective portfolios. These reports are provided on a regular basis, according to the needs of each institution. |