Management Response/Action Plan – Auditor’s Recommendations

The Office of the Information Commissioner of Canada (OIC) developed the following response plan based on opportunities for improvement identified in Moving Forward section of the report*

*Considering that the recommendations raised in this monitoring report were mainly administrative in nature, the Human Resources Directorate was able to conclude that several good practices were already implemented within OIC.

As part of a continuous improvement process, the OIC's Human Resources Directorate is committed to maintaining its good practices, but also to following up on the recommendations made in this summary report. Specifically, by implementing the following actions:

Updating some of its tools such as essential forms and documents required for various staffing actions, including file checklists;
Providing the team members, consisting of administrative staff and human resources advisors, with an information session to make them aware of the various administrative requirements raised in this report;
Review all of its human resources policies to ensure consistency and to facilitate their interpretation.

These actions, which should be implemented over the next year, will allow the Human Resources Directorate to provide its team members with the tools they need to better support managers in fulfilling their human resources responsibilities as well to ensure compliance with the related policies and legislation.

Auditor’s Recommendations
Auditor’s recommendations	OIC response	OIC commitment (action items)	Lead	Target date	Progress
1. In accordance with paragraph 2 of the PSC’s Appointment Policy, OIC must respect all requirements to administer priority entitlements appropriately, as set out in the PSC’s Priority Administration Directive.	The HR Directorate is committed to take in consideration all the recommendations formulated in this staffing evaluation exercise. Furthermore, OIC will report to Senior Management Committee (SMC) on its progress and through Innovations in addition to the official reporting at the OIC Audit and Evaluation Committee. We are committed to adjust our immediate operations and invest in the realignment of our processes and policies structure while maintaining a high quality of services while having the objectives of efficiency, effectiveness and being innovative.	1. Meet with the Public Service Commission (PSC) representative to get feedback on the OIC Evaluation Cycle. 2. Provide the HR team members with an information/training session to make them aware of the various administrative requirements raised by this Staffing File Monitoring Exercise. 3. A strategic planning session will be held with HR team members to determine the objectives and priorities for our group while addressing the recommendations of this audit. 4. Create a working group (IT/Finances) to develop innovative tools and processes to reduce administrative burden (e.g. electronic HR request + electronic internal control).* 5. Update some of the HR tools (e.g. file checklists). 6. Update OIC HR Policy suite (e.g. Delegation Instrument of Human Resources Authorities, HR Plan, Area of selection, Guide on the Choice of Appointment Process and Articulation of the Selection Decision). 7. Work in collaboration with classification consultant to develop guidelines/tools for assessing the security level/language profile required for a position.	Human Resources Directorate, Operations and Corporate Policy	March 2023	1.1 Completed 1.2 Not started 1.3 In Progress 1.4 Partly completed * Request to prioritize enhancements have been done in January 2022. List of priorities to be develop 5.0 Not started 6.0 In progress 7.0 Not started
2. In accordance with paragraph 15 of the PSC’s Appointment Policy, OIC must ensure that persons to be appointed meet each essential qualification established for the position being staffed.
3. In compliance with section 48 of the Public Service Employment Act, OIC must ensure that the notification process is used appropriately in internal appointment processes only when an appointment is being made or proposed.
4. OIC must ensure that the oath or solemn affirmation is administered appropriately, where required, in compliance with section 54 of the Public Service Employment Act.
Response for the fact findings (administrative nature): Inconsistencies and potential perception: in the security and/or language requirements indicated in such documents as the work description, priority clearance request, poster, and/or letter of offer.	In the Strategic Planning (EC-06) file, the condition of employment for the security requirement was changed between the time the position was posted and the appointment of the employee. This may have created the perception the security was change to fit a particular individual's profile. However, management confirms that these changes were made to reflect the position the business needs of the organization. Considering that this position was created as a new position for the organization in response to new business needs, it was therefore difficult to evaluate the accurately of the security requirement. In the Financial Advisor (FI-03) file, the application of the condition of employment for the security requirement was inconsistency manipulated creating an administrative error. As the request to downgraded (reliability) that security requirements was completed prior to the launch of the process, the nomination itself was done using the previous security requirements (secret). This does not remove the fact that an administrative error occurred however; it had no impact related to security, as the employee had a higher security clearance than requested. The Human Resources Directorate is committed to adjust their process to avoid potential situation in the future. As part of our strategies, we are planning to development in collaboration with the IT and financial group an electronic HR request (Intrac) that would include a classification section in getting the manager confirmation that the work description, security requirement and language requirements are given considerations prior to any staffing actions. In addition, the Human Resources Directorate will add to its existing internal control measures by requiring its operations advisors to ensure the consistency of the various documents/information included in a staffing file. This will ensure a better review of files and limit the number of administrative errors.