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ARCHIVED - Horizontal Internal Audit of Electronic Recordkeeping in Large Departments and Agencies, December 2011

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Detailed Findings and Recommendations

Finding 1: Policy and Strategic Direction

While strategic direction for electronic recordkeeping is established in LDAs, implementation is in the early stages.

We reviewed the Secretariat's strategic guidance provided to LDAs to coordinate IM activities government-wide. We examined the progress of implementation of the Government of Canada Information Management Strategy in LDAs, including departmental policies, plans, organization charts and committee terms of reference. Finally, we assessed how IM practitioners are monitoring the progress of the implementation of their plans.

Common strategic direction across all departments ensures that the government is consistent in its approach to electronic recordkeeping. IM strategies ensure that IM practitioners have an established direction for IM activities in delivering departmental requirements of the IM policy suite. Performance measurement and monitoring assist senior management in determining whether IM plans are being implemented to meet management's objectives.

The strategic direction of IM is being coordinated government-wide.

The Secretariat is leading efforts to strengthen electronic recordkeeping activities government-wide. The Secretariat led the development of the Government of Canada Information Management Strategy—in partnership with LAC and committee members from various LDAs—which provides the strategic direction for electronic recordkeeping government-wide. The strategy identified government-wide risks and centrally led activities required to mitigate those risks. An action plan with established timelines was developed to implement the strategy, and multiple guidance documents have been produced to assist IM practitioners and departmental staff. The Secretariat's strategies and guidance are complemented with outreach activities that reach all LDAs. Through this coordination of efforts, LDAs are in a position to leverage each other's knowledge and experience.

Most LDAs have developed IM plans that incorporate IM policy suite requirements.

Most LDAs have begun implementing their plans with departmental IM policies that address the government-wide electronic recordkeeping strategy. LDAs have also established champions or IM practitioners who are in positions to inform senior management of risks to IM activities. Management of electronic information has been recognized government-wide as a risk to operational efficiency, and LDAs have recognized the growing risk of insufficient electronic recordkeeping practices. IM requirements and risks are formally discussed by senior management. As significant IM priorities arise that require additional resources, it will be important for LDAs to incorporate these requirements into overall departmental planning activities.

IM practitioners are not monitoring the implementation of their plans.

Most LDAs have not yet developed performance indicators to measure and monitor the progress of implementation in relation to their IM plans. While overall objectives for strategy implementation have been identified in most LDAs, activities that have established timelines have yet to be elaborated. As a result, IM practitioners are not able to assess the effectiveness of their activities, nor can they demonstrate their effectiveness to senior management.

An example of a performance indicator is the completion of identification of information that has business value within each departmental unit and the resulting retention and disposition processes. This could be measured as a percentage of completion of developing formal processes and could be compared across business units within a department.

  1. LDAs should develop performance indicators to assist in monitoring the implementation of their IM plans.

Finding 2: Retaining Information That Has Business Value

Most LDAs have not yet developed a framework for identifying and managing information of business value.

We examined methodologies that LDAs use to identify the business value of the information they generate. We examined the guidance provided to all departmental staff to ensure they understood how to identify business value and the resulting retention and disposition processes. Finally, we examined the methodology that LAC is using to issue disposition authorities to departments that have demonstrated their ability to track and retain information that has business value, thereby reducing the risk of disposing of information that has long-term benefit to the Government of Canada and to Canada's national interest.

In the absence of identifying information of business value, LDAs could overburden their systems with information that has no long-term value for the operations of their department. This also increases the complexity of finding information of business value when it is needed to support decision making or respond to information requests from Canadians. After determining the effectiveness of departmental processes for retention and disposition of information, LAC grants records disposition authorities to departments that allow LDAs to dispose of information that has no business value through an established process. This increases the efficiency of disposition and reduces long-term costs in maintaining information that has no long-term value.

Most LDAs have not yet defined information of business value.

Most LDAs have yet to define business value as it relates to IM needs in their organization, and most provide little to no guidance for departmental staff. Most LDAs identify only specific products or documents (e.g., Memoranda to Cabinet) but no further guidance that can be interpreted for departmental staff to apply to other documents generated on a daily basis. Most LDAs still classify records based on security and/or access restrictions; business value is not addressed. As a result, LDAs are potentially spending resources tracking, maintaining and archiving information of no long-term business value to the Government of Canada.

Most LDAs do not have elaborated retention and disposition processes or guidance for departmental staff.

Disposition of electronic records is performed mostly on an ad hoc basis by departmental staff, as most retention and disposition strategies were developed for paper-based recordkeeping. Because the number of electronic records generated by departmental staff is exponentially greater than that of paper records, LDAs are increasingly challenged by disposing and archiving their electronic records; existing retention and disposition processes are not suitable for electronic records. In theory, departmental staff could be deleting information that is important for decision makers; conversely, storage capacity could be burdened by electronic records that are unnecessarily retained.

Some LDAs have addressed this challenge by creating a handful of record types; when the record is created, its life cycle is predefined based on its record type. These LDAs also provide one-on-one guidance for departmental staff if the record is not clearly linked to a record type.

LAC has begun implementing a standardized methodology for issuing records disposition authorities.

LAC's methodology in issuing records disposition authorities was launched in May 2011. It includes an assessment of a department's ability to track and retain information of business value, thereby reducing the risk of disposing of information that may have long-term benefits to the Government of Canada and to Canada's national interest. Prior to this, the process for issuing disposition authorities was performed on an ad hoc basis and often had long delays. The new methodology gives LAC the opportunity to streamline the process and increase efficiency. It will be important for LAC to monitor the progress of its new methodology and continue to improve the process in order to optimize the efficiency of electronic recordkeeping disposition government-wide.

  1. LDAs should define information of business value for their organization and develop methods to ensure that it is tracked and stored in an effective manner.
  2. LDAs, in collaboration with LAC, should develop formal retention and disposition processes that can be followed by all departmental staff.

Finding 3: Learning and Awareness

LDAs are addressing training requirements for their IM practitioners but not for all departmental staff.

We examined the Secretariat's functional guidance for IM practitioners and courses developed for the IM community. We examined IM mandatory training that LDAs provide for their IM practitioners. Finally, we also examined IM training provided to all LDA staff outside the IM function, and whether IM practitioners are able to determine if current training is sufficient to help implement the Government of Canada Information Management Strategy.

Working with the Canada School of Public Service, the Secretariat is in a position to coordinate new developments or methods in electronic recordkeeping training and effectively communicate them to all departments in order to promote consistency throughout government. Formal training plans help ensure a professional, well-informed IM function that can help the department deliver the Government of Canada Information Management Strategy. Providing IM training to all departmental staff helps them understand their role in electronic recordkeeping, including understanding how to track and retain information of business value. Since every employee is now considered an electronic record keeper to some extent, it is important that departmental employees have the knowledge and training required to help deliver IM strategic objectives.

The Government of Canada is leading efforts to strengthen training and awareness in departmental IM functions.

The Secretariat and LAC chair multiple interdepartmental committees and working groups in order to better determine training and outreach requirements for the community, and to share new developments uniformly throughout the community. The Secretariat is leading the development of training courses (with the Canada School of Public Service) for IM practitioners. By working directly with IM practitioners in LDAs, the Secretariat and LAC can ensure that centralized guidance is customized to the various working levels that will implement IM strategies. Through committee meetings and interdepartmental working groups, electronic recordkeeping knowledge is shared across the community regularly and effectively.

Training for IM practitioners is planned and coordinated.

Most LDAs have identified learning for IM practitioners as a priority. Most LDAs have developed formal training plans for IM practitioners and track progress against learning objectives. IM practitioners are well positioned to implement further electronic recordkeeping advances for departments.

LDAs are providing some training to departmental staff but have not identified learning requirements.

Most LDAs have not developed IM learning strategies for all departmental staff. Most LDAs have developed one or two training sessions for departmental staff but lack clearly defined learning objectives. Because LDAs are still implementing their IM strategies, they have not yet fully developed electronic recordkeeping learning needs analyses for departmental staff. IM teams cannot ensure that departmental staff understand what is required of them to implement the Government of Canada Information Management Strategy, including the need to track and retrieve information of business value and what training may be required.

  1. LDAs should perform departmental staff training needs analyses and implement any actions required.

Finding 4: Information Management Tools and Applications

Implementation and use of IM tools and applications are not coordinated in LDAs.

We examined activities to promote information sharing by departments that play a central role in the delivery of the IM strategy. We also examined whether tools and applications had been developed or procured by departments that have central roles, and how they were provided to LDAs for common use across government. Finally, we examined enterprise-wide systems used to manage electronic records in LDAs.

Many software solutions are expensive for individual organizations to implement, and LDAs could leverage from each other's learning while making progress toward advancing IM activities. Enterprise-wide systems are the tools used by LDA staff to manage electronic records on a daily basis, and without software solutions to centrally manage large volumes of information, electronic records cannot be managed effectively. While it is possible to effectively manage information of business value outside an enterprise-wide system, this decreases the efficiency of retrieval of this information in a timely manner and impedes the sharing of information government-wide.

Departments that play a central role in IM are providing LDAs with access to common tools and applications.

With the direction and guidance of the Secretariat, PWGSC has procured an enterprise-wide electronic recordkeeping solution. LDAs can, and do, choose to procure and implement their own solutions, as the service provided by PWGSC is optional rather than mandatory. The Secretariat is also working with LDAs to develop common enterprise architecture systems to ensure that electronic recordkeeping systems are designed uniformly throughout government. With standardized structures and tools, along with centralized guidance, LDAs have the opportunity to leverage information sharing with colleagues and improve the efficiency and effectiveness of IM functions.

Electronic recordkeeping systems are inconsistently used by departmental staff.

Usage of enterprise-wide applications for electronic recordkeeping varies in most LDAs from employee to employee. Most LDAs have not made electronic recordkeeping systems mandatory and instead leave usage up to the individual. This results in some electronic records being saved on shared drives, personal drives or portable storage devices, rather than on an enterprise-wide system. Most LDAs are also using multiple enterprise-wide applications for different operational areas, some of which are not interoperable. LDAs have addressed different operational or security requirements for different business functions, which may prevent the adoption of one universal application. Because information exists in LDAs across multiple platforms, information may not be readily accessible to decision makers to deliver program objectives. It is important for LDAs to ensure that interoperability between systems is addressed when implementing their IM strategy.

  1. LDAs should develop strategies to increase the use of enterprise-wide electronic recordkeeping systems by LDA staff.

Management Action Plans

The findings and recommendations of this audit were presented to each of the 19 departments included in the scope of the audit. The Office of the Comptroller General has asked each department that participated in the audit to prepare detailed management action plans and discuss these plans with their respective Departmental Audit Committees.