2023 Management Action Plan, Evaluator’s Recommendations - Investigations Program evaluation, phase II

The Office of the Information Commissioner of Canada (OIC) would like to thank Samson and Associates (“the evaluator”) for the independent evaluation that was conducted on the Investigations program. The focus of the evaluation was on the effectiveness of the Investigations Program processes to achieve its intended results from the perspective of institutions and senior investigations officers. The evaluation assessed the investigation process from the time a file is assigned to an investigator to the end of an investigation. The evaluation relied on the findings from interviews with Program personnel and external institutions that the OIC works with. This evaluation did not include interviews with complainants. There is a plan to conduct additional work in which complainants will be consulted for their perspective on the effectiveness of the Program.

Overall, both internal and external clients appear to be satisfied with the Investigations program. The evaluator made some observations that will serve to strengthen the OIC’s Investigations function and enable greater efficiencies.

With this context in mind, a work plan was created to outline how the OIC intends to capitalize on these opportunities. The Management Action Plan provides clear commitments, timelines and deliverables to address each recommendation.

Management Action Plan – Evaluator’s Recommendations
Evaluator’s recommendationOIC commitmentsAction itemLeadTarget dateProgress
1. The Investigations Program should develop and communicate information to explain the Program processes to institutions and other stakeholders.

1. Develop and make readily available updated information about investigation processes on its web site.

2. Communicate the information more effectively to institutions.

- Build on existing portfolio approach to identify communication gaps and opportunities by audience (complainants, institutions, other stakeholders).

- Re-purpose existing tools whenever possible (i.e. standard language, processes, internal guidance).

- Prioritize development of new communications products.

- Identify best communication vehicle (i.e. website, social media, special report, other)

- Present findings and recommendations to Commissioner.

- Draft new communications products based on priority.

Investigations and Governance

Ongoing

Spring 2023

Summer 2023

Complete

- The Commissioner prioritized updates to the OIC’s website. The following additions and updates were made.

Rewrote the following:

- FAQ

- Complaint form instructions

- PDF and online complaint form

Updated the following:

- Timeframe for submitting a complaint

- Documents and information relevant to investigations

- Types of complaints & What the OIC Registry does

- Notices of intention to investigate sent to institutions

- Initial requests for documents sent to institutions

- Information Commissioner’s guidance page

Added the following:

- When and how institutions are to respond to access requests

- Standard Language page

- Making representations during investigations

- How the OIC processes and investigates complaints

- Exemption from disclosure: advice, accounts, positions and plans

2. The Investigations Program should formalize approaches leading to frequent contact between investigations personnel and institutions. 3. Provide additional clarity to institutions while maintaining flexibility in the OIC’s investigative processes. 

- Establish a plan for portfolio management to communicate at least each quarter with every institution having more than 20 pending complaints in its inventory.

  • Plan may include providing updated reports on pending and closed complaints to institutions, links to new guidance published, in-person and virtual meetings, etc.

- Present findings and recommendations to Commissioner.

- Implement approved plan.

 

Investigations and Governance

Spring 2023

Summer 2023

Complete

- The Senior Director meets once per month with institutions. Managers and Investigators meet on an ad-hoc basis.

- Pending and closed complaint reports are provided in advance of meetings.

- Discussions and follow-up communications with institutions include links to new guidance, published final reports, and other relevant information. 

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