ARCHIVED - RPP 2007-2008
Offices of the Information and Privacy Commissioners of Canada

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Section II: Plans and Priorities

2.1 Factors Influencing Privacy and the OPC

Operating Environment

This section describes the operating environment of the OPC in three parts. The first part describes the major program delivery mechanisms; the second and third parts describe important internal and external factors affecting program delivery.

Major Program Delivery Mechanisms

Investigations and Inquiries

The OPC seeks to promote fair information management practices by both public and private sector organizations in Canada in accordance with two federal privacy laws. The Privacy Act was enacted in 1983, and PIPEDA, which began coming into effect in 2001, came into full force in 2004. The principal means of doing this is through complaint investigations, which are conducted by the OPC's Investigations and Inquiries Branch. The Branch investigates complaints from individuals alleging that their personal information has been collected, used or disclosed inappropriately.

In conducting this work, the Investigations and Inquiries Branch is supported by activities of other branches, such as the Legal Services and Policy Branch and the Research and Analysis Branch. The Legal Services and Policy Branch provides legal advice on the interpretation and application of both Acts and represents the OPC in matters that proceed before Federal Court. The Research and Analysis Branch provides investigators with research material to assist with the development of needed expertise in such areas as newly emerging technologies, which are the subject of an increasing number of complaints to the OPC.

The Investigations and Inquiries Branch also responds to inquiries from members of the general public, government institutions, private sector organizations, and the legal community, who contact the OPC on a wide variety of privacy-related issues.

Audits and Reviews

To safeguard Canadians' right to privacy, the OPC's Audit and Review Branch conducts compliance reviews under Section 37 of the Privacy Act. These reviews assess systems and practices for managing personal information from collection to disposal by federal departments and agencies. This work is intended to encourage the growth of fair information practices by federal government institutions. The OPC also has the mandate, under Section 18 of PIPEDA, to conduct audits of the personal information management practices in the private sector. The Audit and Review Branch is likewise supported by the Legal Services and Policy Branch and the Research and Analysis Branch, as needed.

Privacy Impact Assessments

The Government of Canada's Policy on Privacy Impact Assessments (PIAs) has added to the responsibilities of the OPC. Our role, as defined in the Policy, is to assess the extent to which a department's PIA has succeeded in identifying privacy risks associated with a project or initiative and to comment on the appropriateness of the measures proposed to mitigate identified risks. The OPC views PIAs as an integral part of the federal government privacy management framework.

Support to Parliament

The Commissioner acts as Parliament's advisor on privacy issues, bringing to the attention of Parliament issues that have an impact on the privacy rights of Canadians. We do this by tabling annual reports to Parliament, by appearing before Parliamentary Committees to provide legal and policy advice on the privacy implications of proposed legislation and government initiatives, and by researching and analyzing issues that we believe should be brought to Parliament's attention.

The OPC also assists Parliament to become better informed about privacy, acting as a resource or centre of expertise on privacy issues. This includes responding to a significant number of inquiries from Senators and Members of Parliament.

Public Education and Communications

The Privacy Commissioner is specifically mandated under PIPEDA to conduct public education activities to ensure that all parties in Canada are aware of the law and of the fair information practices it seeks to promote. This includes the business community, technology developers, and individuals who need knowledge of their rights in order to protect their privacy. There is also an ongoing need to raise awareness of privacy issues that arise in the federal public sector. Public outreach activities include, for example, undertaking public opinion research and media relations, speeches and participation in special events, the printing and dissemination of publications, and posting information on the OPC's Web site.

Research Program

The Research Program is an open and competitive contribution program to support the development of national privacy research capacity in the voluntary, academic and not-for-profit sectors. The purpose of the program is to catalyze research on privacy matters in Canada, to encourage collaboration among different communities, and to generate and transfer knowledge on the privacy impact of emerging technologies, and best practices for effective personal information management in the private and public sectors. The OPC also carries out in-house and contracted research on a broad spectrum of issues such as identity management, video surveillance, and electronic health records.

Internal Factors Affecting Program Delivery

As we enter fiscal year 2007-2008, the OPC moves forward with an increased budget, and new staff that brings with them new ideas and backgrounds. Our staff continues to demonstrate an unwavering commitment to protecting and enhancing the privacy rights of Canadians.

Being in an organizational development and staffing mode, the OPC must remain attentive and responsive to the needs of people and the requirement to continuously improve work processes and service delivery. The OPC is working to: adapt decision-making processes to manage in a more integrated fashion; find the balance between being more proactive in its approach to service delivery while remaining responsive to incoming demands; put in place more advanced knowledge management tools and enable opportunities for effective knowledge transfer; and integrate skills of existing and new staff. At the same time, the OPC is continuing to address its backlog of cases to improve its response time relating to investigations, inquiries, audit and review activities.

In sum, there is ongoing momentum in the organization as a result of changes implemented in recent years. This momentum offers the OPC an opportunity to hire and train new staff and align the organization so that all aspects of the OPC mandate are effectively and efficiently supported and resourced. We face the future as an organization that has been revitalized and has gained the reputation of not only being a centre of expertise, but an organization in which Parliament and Canadians can put their trust.

External Factors Affecting Privacy and the OPC

Opinion polling in Canada continues to show that, as a society, we are deeply concerned about privacy, and at times conflicted about the appropriate response to various social, political, and technological factors which threaten privacy. It is the role of this Office to help analyze, understand, and balance these conflicting societal pressures, in a climate where individuals can rapidly swing from supporting an initiative or value, to protesting it. Principal among the threats to privacy is technology. As a society, Canadians willingly embrace communications technology and innovation, and hope to stay on the cutting edge of such technologies as the Internet, remote sensing, and predictive profiling, while recognizing inherent privacy risks that require effective limits, controls and oversight.

The Internet presents a number of new privacy threats: the exposure of children and youth through online social networking sites, the compilation of behavioural profiles from harnessing search engines to collect data about individuals, and the exposure of individuals to the risks of identity theft and online fraud. New miniature computing devices, from radio frequency identification devices (RFIDs) to nanotechnology, will very soon revolutionize the supply chain and practically every item we deal with, as tags enable physical goods to communicate with readers and the Internet. It is impossible to overstate the transformative nature of this technology and its potential to invade the privacy of citizens and create a surveillance state. It may also enable us to grapple with enormous environmental and logistical challenges, from monitoring pine beetle invasions in remote regions to tracking defective medical devices, so finding solutions to the privacy problems must engage our attention.

The global war on terror and on organized crime has created a social and political climate where it has become accepted practice to retain transactional data, to install video cameras in previously free and open spaces, and to search this data for suspected persons. Software programs detect unusual behaviour patterns in both physical space and on the communications networks, and innocent citizens are singled out for scrutiny in an attempt to predict crime, not just detect it. This has implications beyond privacy to the foundations of our justice system and Charter of Rights, but it starts with information, which is our domain of interest.

The growing tolerance of the population for profiling and surveillance activities partly reflects the fears of an aging population that worries about crime, illegal immigration, and loss of power and control over information. In our scanning and research activities, the goal is to provide fact-based approaches to these issues, and inform the media and the public of the impacts of activities and technology which invade privacy, as well as shed light on policy alternatives. As the government prepares for potential emergencies, such as disaster recovery planning, increased public health surveillance in the event of a flu or SARS epidemic, or critical infrastructure surveillance measures, we seek to mitigate the privacy implications of management plans and the potential use of extraordinary powers.

We cannot do this in isolation. Part of our resource increase was to allow us to engage the many stakeholders (government departments, academics, the business community, the legal community, other data protection commissioners in Canada and abroad, civil society and individuals) in an attempt to build a stronger community working towards proactive solutions. These solutions include privacy enhancing technologies, better risk assessment, public information and awareness, research that analyses costs, benefits, and privacy impacts of new proposals.

There is an enormous challenge for those who defend privacy. Safety and security will always prevail over privacy values, until someone gets hurt. The situation in Canada with the Commission of Inquiry into the Actions of Canadian Officials in Relation to Maher Arar is a case in point in which incorrect information led a Canadian to be deported to and tortured in Syria. The speed of change is daunting, and the human response to change can be a failure to believe in the power of individuals to cope, to correct, and to reverse direction. The pressures of a globalized world bring us a myriad of potential partners but an overwhelming task of selection, focus, and harmonization of efforts.

It is the task of this Office to be a positive agent for change and for hope in the protection of privacy as a core human value that Canadians cherish. One of the reasons that Canada will host the 29^th International Conference of Data Protection and Privacy Commissioners in Montreal in September 2007 is to provide an effective forum for discussing potentially common solutions to increasingly global issues.

2.2 Summary of OPC Plans and Priorities for 2007-2008

Having considered the present internal and external business environment surrounding the OPC, senior management established five (5) priorities to give focus to its activities and further advance towards the achievement of its single Strategic Outcome and its ultimate, intermediate and immediate outcomes (presented in Figure 2). The priorities have remained relatively stable since last year's Report on Plans and Priorities. The five priorities are presented below and the plans to deliver on each priority are described in the paragraphs that follow:

Strategic Outcome: The privacy rights of individuals are protected.

OPC Priorities for 2007-2008:

1. Improve and expand service delivery
2. Engage with Parliament on privacy issues
3. Continue to promote Privacy Act reform and PIPEDA review
4. Organize, host and evaluate the 29^th International Conference of Data Protection and Privacy Commissioners
5. Build organizational capacity

1. Improve and expand service delivery

The OPC has a client-centered approach and considers that it is critical to continue efforts to further improve and expand its service delivery. In line with commitments made in its business case, the OPC will work to make greater use of various tools available to proactively promote privacy compliance, while at the same time, significantly reduce backlogs and improve response times of complaint investigations and privacy impact assessment (PIA) reviews without compromising their quality. This is essential to sustain the renewed trust of Canadians in the OPC and our ability to protect their privacy rights. Fair, prompt and effective treatment of these files also provides a key opportunity for education and knowledge transfer.

Improved service delivery will be achieved through hiring new staff, increased automation and use of technology in processing files, and streamlining processes. A key activity for 2007-2008 will be to define performance standards for core activities such as responding to inquiries, conducting investigations, carrying out audits, and reviewing PIAs. In future years, the OPC will incorporate those standards to its operations and will be able to measure and report performance against its own standards, and eventually possibly against standards recognized internationally.

An expanded focus on service delivery in 2007-2008 will include continuing to increase the number of audits and follow-up audits of privacy systems and practices in both the public and private sectors. Audit and review activities determine compliance with privacy laws and lead to recommendations to implement information management practices in-line with modern principles of personal information protection. With the addition of new resources in the audit and review function, the volume of audit activity will increase from a past average of three or four projects a year to a total of eight planned audits to be initiated in 2007-2008. And we anticipate completing three other major audits started in fiscal year 2006-2007. While a 100% increase in volume is notable, audits will also be more comprehensive and effective as illustrated by the audit of the Canada Border Services Agency reported in June 2006. The OPC will also publish additional guidance materials to help public and private sector organizations comply with legislative requirements and improve privacy management practices.

2. Engage with Parliament on privacy issues

Parliamentarians rely on the Commissioner for advice, information and support relating to privacy issues. In 2007-2008, the OPC will continue to support Parliamentarians through the provision of useful and timely submissions and policy positions relating to potential privacy implications of proposed legislation and/or government initiatives.

The OPC will respond to inquiries of Parliamentarians and be more proactive in informing legislators and decision-makers of privacy issues on the basis of sustained knowledge about trends and emerging issues in the privacy field. As the reputation of the OPC continues to solidify as a centre of excellence, the Commissioner's advice and views may be solicited more frequently. Interventions before Parliamentary Committees to comment on legal and policy issues may also increase. The OPC is committed to providing sound legal and policy analyses and expertise to support Parliamentarians in their review of the privacy implications of bills.

3. Continue to promote Privacy Act reform and PIPEDA review

The OPC has pointed out on many occasions that the Privacy Act is long overdue for a fundamental reform. The Act came into effect in 1983 when there were no personal computers, no Internet, no cell phones, no geo-positioning systems, let alone biometrics and RFID chips or nanotechnology. It was crafted in the era of reel-to-reel computer tapes and paper files in filing cabinets, when trans-border data flow almost entirely was achieved through shipping goods, tapes or paper, not digital bits. The OPC will continue to promote Privacy Act reform by engaging Parliament as well as encouraging federal government institutions to adopt leading practices to respect the privacy rights of individuals and to protect their personal information.

As for PIPEDA, this Act includes a provision for a review every five years. In the summer of 2006, the OPC released a discussion paper on issues related to PIPEDA review. We received more than 60 submissions from organizations and individuals. In November 2006, the Standing Committee of Access to Information, Privacy and Ethics began its study of PIPEDA. The OPC appeared before the Committee along with a number of witnesses. The OPC continues to take an active role in the process.

4. Organize, host and evaluate the 29^th International Conference of Data Protection and Privacy Commissioners

In September 2007, Canada will host the 29^th International Conference of Data Protection and Privacy Commissioners (refer to our Web site for more information on the Conference at: www.privacyconference2007.gc.ca), bringing together representatives from the world of business, public administration, science, the IT industry as well as governmental and non-governmental organizations to discuss cutting-edge issues related to privacy and the protection of personal information. This will provide a unique opportunity to highlight and enhance Canada's international role in promoting privacy standards.

The OPC has already dedicated efforts to prepare for this major event through careful planning in 2006-2007. Focussing on engaging a broad cross-section of society to participate in the events planned, we have collaborated with four provincial commissioners who will host complementary events in their own regions, leading up to the conference. Working with federal government departments, we hope to bring a wide audience to the event, building on other meetings and activities. Workshops will engage not only the world's data commissioners and experts, but many stakeholders in Canada, fulfilling our need to involve them in the solutions to problems. Engaging civil society will also bring strong and unique perspectives to the debate, and will provide significant learning and networking opportunities. Conference papers will enrich our community in Canada and feed our public education program. The theme of the conference is Terra Incognita, as it truly is an unknown world to which we sail in this information age. In the months leading to the conference in 2007-2008, the OPC will intensify its efforts to ensure that this conference is a success. We will:

• Invest resources to implement the conference strategy and key activities;
• Engage OPC staff in activities, ensuring they benefit as a team from this learning and networking opportunity;
• Implement procedures to host the conference, in cooperation with provincial and international colleagues;
• Provide opportunities for the press to understand the issues and access the experts who will gather in Montreal;
• Engage stakeholders across Canada and internationally;
• Tie in the relevance of research generated through the OPC's Research Contributions Program and the excellent opportunity for knowledge transfer; and
• Evaluate the outcome of the conference.

5. Build organizational capacity

The OPC is in development mode and will continue in 2007-2008 to dedicate considerable energy and effort to increase its organizational capacity to approved levels. In order to achieve success, our plan includes the following major components:

Finalize OPC organizational structures. In 2007-2008, we will continue to:

• Review and revise the organizational structure, including the creation of regional offices;
• Create and classify new positions;
• Recruit applicants; and
• Screen and select new staff.

Train and integrate new and existing staff. We will identify and provide training and development opportunities for existing and new staff, based on personal learning plans and organizational learning priorities. Our success also depends on our ability to build staff engagement through exemplary leadership and sound management practices.

Implement aspects of the new Federal Accountability Act that will have an impact on the OPC, namely the creation of an office to handle access to information and privacy requests. Other impacts, such as the increase in the number of organizations to be covered by the Privacy Act, may require a greater number of privacy investigators or other staff.

Improve OPC's infrastructure (e.g. Information Management / Information Technology, accommodations, policies and procedures). The OPC has completed implementation of a new structure to classify its information holdings. New procedures and guidelines will be developed and implemented in 2007-2008 to comply with the Management of Government Information Policy and the OPC will move forward to have all of its information in electronic format by scanning existing and new documents.

In terms of accommodations, the OPC will make some adjustments to its floor plans to optimise existing space and accommodate new and existing staff while working on a long-term accommodation plan. We will review our policies and procedures to ensure they are up-to-date and compliant with Treasury Board policies and other relevant legislation.

2.3 Link Between Priorities, Expected Results and Program Activities

The priorities, discussed in the previous section, serve to advance the achievement of the OPC's results over the next three fiscal years with an emphasis on 2007-2008. Priorities will be refined annually based on the OPC's changing environment. While the operating environment of the OPC evolves over time, its expected results (See OPC Results Framework in Figure 2 of this Report on Plans and Priorities) will remain relatively stable: the OPC results are based on its mandate and long-term vision of the four complementary roles vis-à-vis Parliamentarians, individuals, federal government institutions and private sector organizations.

The Results Framework is aligned to the OPC's Program Activity Architecture (PAA)². The PAA provides the structure for planning and reporting on the OPC's activities. Our program has three operational activities aimed at achieving one strategic outcome on behalf of Canadians, plus a management activity to support the first three activities. Section 2.4 that follows: describes each Program Activity, presents the OPC's expected results by Program Activity and associates performance indicators to each expected result; and links Program Activities and results with the annual priorities for 2007-2008.

Strategic Outcome:	Protection of the privacy rights of individuals
Program Activities:	1. Compliance activities	2. Research and policy development	3. Public outreach
	4. Management Excellence

2.4 Analysis by Program Activity

This section provides information on the OPC's outcomes, expected results and performance indicators on the basis of the Program Activity Architecture (PAA), and links the 2007-2008 priorities described in Section 2.2 to the Program Activities.

The OPC will implement its newly developed Results and Performance Measurement Framework using an incremental approach over the next few years. The performance indicators identified in this section are those against which the OPC will start measuring its performance in 2007-2008. More indicators identified in the OPC's comprehensive Results and Performance Measurement Framework will be introduced in future reports on plans and priorities as they become operational. In addition to 'performance' indicators that generate information about the extent of achievement of 'results', the OPC uses 'volume' indicators or statistics to collect relevant information about its 'activities'. The level of discussion of a report on plans and priorities does not warrant listing the volume indicators; those may, however, serve to report useful information in the departmental performance report.

Office of the Privacy Commissioner of Canada
Expected Result	Performance Indicator
Ultimate Outcome for Canadians
The OPC plays a lead role in influencing federal government institutions and private sector organizations to respect the privacy rights of individuals and protect their personal information.	Extent and direction of change in the privacy practices of federal government institutions and private sector organizations

 

Planned Resources	2007-2008	2008-2009	2009-2010
Financial Resources	$19,711,000	$18,919,000	$18,937,000
Human Resources	154 FTEs	150 FTEs	150 FTEs

Program Activity 1: Compliance Activities

Activity Description

The OPC is responsible for investigating complaints and responding to inquiries received from individuals and organizations that contact the OPC for advice and assistance on a wide range of privacy-related issues. The OPC also assesses through audits and reviews how well organizations are complying with requirements set out in the two federal laws and provides recommendations on PIAs pursuant to the Treasury Board Secretariat policy. This activity is supported by a legal team that provides specialized legal advice and litigation support, and a research team with senior technical and risk assessment support.

Expected Results	Performance Indicators
Intermediate Outcomes
Individuals receive effective responses to their inquiries and complaints.	Timeliness of OPC responses to inquiries and complaints
Federal government institutions and private sector organizations meet their obligations under federal privacy legislation and implement modern principles of personal information protection.	Extent to which audit, investigation and PIA review recommendations are accepted and implemented over time
Immediate Outcomes
The process to respond to inquiries and investigate complaints is effective and efficient.	Timeliness of OPC responses to inquiries and complaints
The process to conduct audits and reviews is effective and efficient, including effective review of privacy impact assessments (PIAs) for new and existing government initiatives.	Audits completed as scheduled and within allotted resources % of PIA reviews completed within allotted time

 

Planned Resources	2007-2008	2008-2009	2009-2010
Financial Resources	$11,139,000	$11,403,000	$11,405,000
Human Resources	107 FTEs	103 FTEs	103 FTEs

Priority for this Program Activity

Over the next three years, the OPC will advance work towards the achievement of the above outcomes by pursuing the following priority:

Priority	Type
Improve and expand service delivery	Ongoing

Program Activity 2: Research and Policy Development

Activity Description

The OPC serves as a centre of expertise on emerging privacy issues in Canada and abroad by researching trends and technological developments, monitoring legislative and regulatory initiatives, providing legal, policy and technical analyses on key issues, and developing policy positions that advance the protection of privacy rights. An important part of the work done involves supporting the Commissioner and senior officials in providing advice to Parliament on potential privacy implications of proposed legislation, government programs and private sector initiatives. Given the importance of information technology impacts, an important component of this work is analysis of IT initiatives embedded in projects.

Expected Results	Performance Indicators
Intermediate Outcome
Parliamentarians and others have access to clear, relevant information, and timely and objective advice about the privacy implications of evolving legislation, regulations and policies.	Number of potential privacy-relevant legislative initiatives and bills on which the OPC: (i) was consulted before the introduction and/or during the legislative review process and (ii) appeared before Parliamentary committees
Immediate Outcomes
The work of Parliamentarians is supported by an effective capacity to identify and research privacy issues, and to develop policy positions for the federal public and private sectors, which are respectful of privacy.	Key privacy issues identified and positions articulated to influence the evolution of bills through the drafting stage at the departmental level and the legislative process through Parliament
Knowledge about systemic privacy issues in Canada is enhanced, serves to advance the interpretation and application of federal privacy laws, and improves privacy management practices.	Key privacy issues identified, analysed, and potential impacts assessed

 

Planned Resources	2007-2008	2008-2009	2009-2010
Financial Resources	$4,534,000	$4,078,000	$4,079,000
Human Resources	24 FTEs	24 FTEs	24 FTEs

Priorities for this Program Activity

Over the next three years, the OPC will advance work towards the achievement of the above outcomes by pursuing the following priorities:

Priority	Type
Engage with Parliament on privacy issues	Ongoing
Continue to promote Privacy Act reform and PIPEDA review	Previous
Organize, host and evaluate the 29th International Conference of Data Protection and Privacy Commissioners	Previous

Program Activity 3: Public Outreach

Activity Description

The OPC plans and implements a number of public education and communications activities, including speaking engagements and special events, media relations, and the production and dissemination of promotional and educational material.

Expected Results	Performance Indicators
Intermediate Outcomes
Individuals have relevant information about privacy rights and are enabled to guard against threats to their personal information.	Reach of target audience with OPC public education materials
Federal government institutions and private sector organizations understand their obligations under federal privacy legislations.	Degree of organizational awareness and understanding of privacy responsibilities3
Immediate Outcomes
Individuals receive and have easy access to relevant information about privacy and personal data protection, enabling them to better protect themselves and exercise their rights.	Reach of target audience with OPC public education materials
Federal government institutions and private sector organizations receive useful guidance on privacy rights and obligations, contributing to better understanding and enhanced compliance.	Reach of organizations with OPC policy positions, promotional activities and promulgation of best practices

 

Planned Resources	2007-2008	2008-2009	2009-2010
Financial Resources	$4,038,000	$3,438,000	$3,453,000
Human Resources	23 FTEs	23 FTEs	23 FTEs

Priorities for this Program Activity

Over the next three years, the OPC will advance work towards the achievement of the above outcomes by pursuing the following priorities:

Priority	Type
Engage with Parliament on privacy issues	Ongoing
Continue to promote Privacy Act reform and PIPEDA review	Previous
Organize, host and evaluate the 29th International Conference of Data Protection and Privacy Commissioners	Previous

Other Activities: Management Excellence

Activity Description

The OPC continues to enhance and improve its management practices in order to meet the highest standards of performance and accountability. The resources associated with Corporate Services have been apportioned to the three first Program Activities, which they support. All managers of the OPC are expected to take responsibility for the expected results, and to integrate the necessary activities in their operational plans.

Expected Results	Performance Indicators
Intermediate Outcome
The OPC achieves a standard of organizational excellence, and managers and staff apply sound business management practices.	Ratings against MAF (as being the expectations for high organizational performance in modern public service management)
Immediate Outcomes
Key elements of the OPC Management Accountability Framework (MAF) are integrated into management practices and influence decision-making at all levels.	Ratings against MAF (as being the expectations for high organizational performance in modern public service management)
The OPC has a productive, principled, sustainable and adaptable workforce that achieves results in a fair, healthy and enabling workplace.	Employee satisfaction; number of grievances received; quality of labour relations; retention of staff
HR management practices reflect new accountabilities stemming from Public Service Modernization Act and Public Service Employment Act.	Full, unconditional staffing delegation from PSC; HR planning integrated into business planning at the OPC
Managers and staff demonstrate exemplary professional and ethical conduct in all of their work, and are responsive to the highly visible and complex nature of the environment in which they operate.	Feedback from employees on fairness, respect and engagement
The performance of the OPC is defined, measured and reported upon regularly in a meaningful and transparent manner.	OPC reports, particularly RPP and DPR, are well received by Central Agencies and stakeholders

Priorities for this Program Activity

Over the next three years, the OPC will advance work towards the achievement of the above outcomes by pursuing the following priority:

Priority	Type
Build organizational capacity	Previous

 

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