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Section II: Analysis by Program Activity

2.1   OPC Performance in 2006-2007

The OPC has a single strategic outcome supported by a program activity architecture (PAA) composed of three operational activities aimed at protecting the privacy rights of individuals, plus a management activity to support the three operational activities.

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

This section presents the OPC performance by program activity and makes the link between each activity and the six priorities for 2006-2007.

Program Activity 1:  Compliance Activities

Activity Description

The OPC is responsible for investigating complaints initiated by individuals or by the Commissioner herself. The OPC responds to inquiries received from individuals and organizations who 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.

Financial Resources (in thousands of dollars)

Planned Spending	Total Authorities	Actual Spending
$10,154	$9,678	$9,373

Human Resources

Planned	Actual	Difference
88 FTEs	82 FTEs	(6) FTEs

The planned level of resources for 2006-2007 is based on the phasing in of new resource levels obtained for the three-year period of 2005-2006 to 2007-2008, and includes the one-time costs of equipping new offices for employees and additional resources for those years to eliminate the backlogs in investigations and inquiries and PIAs.

Expected Results for 2006-2007

• Improved service levels – timeliness, responsiveness, initiative
• Reduced backlogs of complaints and PIA reviews
• Increased Commissioner-initiated complaints and audits

Priorities for this Program Activity

The operations under this activity contributed to the achievement of the following priority described in Section I.

Priority	Type
Improve and expand service delivery	Ongoing

Performance in 2006-2007

The OPC has improved its service delivery to individuals, federal government institutions and private sector organizations through various means as described below: 

Improved service levels

Processing of complaints

Under PIPEDA, the OPC received 385 complaints and closed 386 complaints; an additional 651 complaints were in process (i.e., carried forward from the previous year). The Office also completed 33 incident investigations under PIPEDA. Compared with last year, the OPC was able to improve the percentage of files closed in relation to files in progress from 54 percent to 59 percent.

Under the Privacy Act, the OPC received 843 complaints and closed 957 complaints; an additional 1,106 complaints were in process. The Office also completed 43 incident files under the Privacy Act and received notice of 90 public interest disclosures under the Privacy Act. Compared with last year, the percentage of files closed in relation to files in progress improved from 84 percent to 86 percent.

The average treatment time for a PIPEDA complaint (calculated from the moment the complaint is received to the mailing of the letter of finding) was 17 months in 2006-2007. This represents an increase of five months over last fiscal year, attributable to the increased complexity of some investigations, a new internal process requiring preliminary letters of findings to be sent, and a loss of experienced personnel.

The average treatment time for a Privacy Act complaint (calculated from the moment the complaint is received to the mailing of the letter of finding) was 13.4 months in 2006-2007. This represents an increase of 2.9 months over the last fiscal year, attributable to the loss of experienced personnel and the  backlog which means files are getting older before being assigned. In addition, some investigator time is being expended to assist with management of backlog files, including sending acknowledgement and notification letters and then speaking with complainants about the status of those files.  With the Privacy Actin particular, many complaint files now involve voluminous records, which take considerably more time to review and investigate.  The office is also receiving a number of complaints in multi-media formats, such as CDs, video and audio tapes.  Again, these are more difficult to review and quite time consuming. 

There have been some staffing delays in replacing investigators.  Indeed, there are a limited number of individuals with the privacy and investigation experience being sought.  Moreover, an investigator new to the Office undergoes extensive training and learning and is therefore not operating at the productivity level of a fully trained, experienced investigator during the first year with the Office. 

Monitoring organizations in the implementation of recommendations

This year, the Office continued to formalize its monitoring of organizations in the implementation of recommendations made during the PIPEDA complaint investigations. This was accomplished by issuing 26 preliminary reports that asked for changes such as amendments to existing policies and procedures and the development and promulgation of new ones. At the end of the fiscal year, we received compliance in all cases. This new process has been very effective in encouraging the private sector to find innovative solutions to bridge the privacy gaps uncovered during investigations. It has also strengthened commitments made by organizations to comply with PIPEDA.

Under the Privacy Act, amendments to existing policies and procedures of the government are often negotiated or agreed to during the investigation process and before letters of finding are issued. Those agreements and recommendations are reflected in the letters of finding.

Alternate dispute resolution

The OPC emphasizes the use of alternate dispute resolution (ADR) approaches – such as the settlement of complaints in the course of investigation and early resolution – to complete investigations. The parties involved were provided with a faster resolution to the complaint, the lengthy investigative process was reduced, and some resources were saved. The OPC managed to settle 109 complaints under PIPEDA, from a total of 386 closed complaints, representing 28 percent of our total number of completed cases. ‘Settled in the course of investigation’ indicated that both the complainant and the respondent organization were satisfied with the actions taken by the Office. As well, OPC used an early resolution process to close 15 PIPEDA cases from a total of 386 closed complaints, representing four percent of closed files. Early resolution is a means used to address complainant’s privacy concerns prior to notifying the respondent organization.

Under the Privacy Act, 61 complaints were settled from a total of 957 closed complaints, representing six percent of the total number of completed cases. Another 38 Privacy Act cases were closed under early resolution from a total of 957 closed complaints, representing four percent of the total number of completed cases.

Inquiries

The OPC received over 10,000 inquiries from the general public relating to the Acts; specifically 6,619 inquiries concerning PIPEDA and 3,829 inquiries concerning the Privacy Act. The OPC responded to 6,436 PIPEDA-related inquiries, 3,400 Privacy Act-related inquiries, and another 3,557 general inquiries during the year.

Litigation

PIPEDA Litigation During the Relevant Reporting Period of 2006-2007

The Privacy Commissioner initiates court action whenever an organization refuses to adopt the Office’s recommendations in well–founded cases under PIPEDA. This policy, consistently applied since 2005, has helped to establish a high level of compliance. Investigation recommendations made by the Commissioner in 2006-2007 had been adopted by year-end. The small percentage of well-founded cases in 2006-2007 that were not resolved prior to the Commissioner issuing her final report were ultimately resolved through negotiated settlements between litigation counsel. In four (4) cases, the matter was resolved within the 45-day period following the Commissioner’s report and prior to her application to Federal Court seeking a compliance order. In another four (4), the matter was resolved or was in the course of being resolved shortly after the Commissioner had proceeded to file an application with the Federal Court. By year end, all recommendations made by the Commissioner in 2006-2007 had been adopted, or were in the process of being adopted to the satisfaction of the Commissioner, resulting in no need to pursue Commissioner-initiated court action.

Several complainant-initiated actions and judicial review applications continued in Federal Courts. Three (3) judicial review applications were initiated by individuals or organizations against the Commissioner to ask the Court to examine the scope of the Privacy Commissioner’s jurisdiction under PIPEDA. Six (6) complainant-initiated court applications continued under PIPEDA in which the OPC was involved as an added party. Of these nine (9) active litigation cases, two (2) were settled or discontinued in the course of litigation; two (2) are proceeding to the hearing stage; and five (5) culminated in important Federal Court decisions clarifying key legal concepts that will not doubt assist organizations in the interpretation and application of the Act in the future. Leave to further appeal one of these decisions to the Supreme Court of Canada was obtained on March 29, 2007.

Privacy Act Litigation During the Relevant Reporting Period 2006-2007

There was little activity in the courts on the public sector side in 2006-2007. One judicial review application was brought against the OPC and was settled and discontinued shortly after. The OPC sought and obtained intervener status in another matter proceeding under the Access to Information Act, but which involves interpreting “personal information” with the same definition as that contained in the Privacy Act and, therefore, is critical to our mandate.

Reduced backlog of complaints and PIA reviews

Complaints

Investigator caseloads have been established at 60 complaints for an experienced investigator at any one time, to optimize case management and expedite investigations and to minimize the risk of investigator burnout. Those files held in abeyance and awaiting an available investigator before assignment are defined as "backlog" complaints. 

At the end of the reporting period, there were 104 PIPEDA complaint files in abeyance, pending assignment to an investigator (down from 264 the previous year). There were 372 Privacy Act files in abeyance, pending assignment to an investigator (down from 644 the previous year).  This represented a significant reduction in the backlog – 60 percent for PIPEDA complaints and 42 percent for Privacy Act complaints.  The Office was able to achieve this in large part through:

• An increase in its complement of investigators, although the full complement is not yet achieved;
• Improvements to existing investigative practices and procedures, including the fast-tracking of those complaints which could be handled quickly;
• The development of a centralized administrative unit to provide staff with consistent and effective support; and
• Group training to enhance investigative skills.

The OPC foresees eliminating the backlog within 18 months, assuming the anticipated staffing levels are met.

PIA reviews

With regard to Privacy Impact Assessments (PIAs), at the beginning of the fiscal year (April 2006) there were 49 PIAs to be reviewed by the OPC. During the fiscal year, a total of 23 PIAs were received from departments and agencies for review, and 22 PIA reviews were completed. Therefore, there were 50 PIAs pending review as of March 31, 2007.

The PIA backlog was not reduced in terms of total number; it remained essentially unchanged. However, complex large PIA reviews were completed during the year on a priority basis. Moreover, in addition to reviewing PIA submissions, several consultation meetings were held with various departments and agencies seeking the Office’s advice on how to conduct PIAs and ways in which to identify and manage privacy risks. OPC PIA reviews and face-to-face consultations resulted in many recommendations further mitigating privacy risks associated with the introduction of new or significantly changed systems of the federal government.

The OPC continued to follow-up on prior PIA review reports – with 20 responses received from federal institutions – indicating positive responses and actions by departmental and agencies to the Office’s reviews.

While the plan was to reduce the PIA review backlog, continuing resource constraints hampered OPC capacity to do so. At the beginning of the fiscal year, the Office had two PIA review officers. While there were plans to hire two more, the staffing process took more time than expected. Meanwhile, the senior PIA review officer left the OPC early in the fiscal year, leaving one PIA review officer.

Contingency actions were taken. We hired one casual employee for a period of four months to do PIA reviews and contracted the professional services of others. As a result of this and work of March 31, 2007, there were 13 PIAs in the process of review.    

Once the Audit and Review Branch is fully staffed to a planned level of 19 (compared to a staff complement of seven as of March 2007), PIA review backlogs should be significantly reduced and more audits completed. Staffing action for the branch as a whole was in progress and fully engaged by March 2007. It should be noted that requisite audit and PIA skills are in high demand and scarce.

Increased Commissioner-initiated complaints and audits

Complaints

The number of Commissioner-initiated complaints increased to six in 2006-2007, up from five last year.

Commissioner-initiated complaints complement the Office’s existing procedure whereby the OPC open incident files that serve as a form of breach notification from federal government institutions and private sector organizations. In 2006-2007, the OPC experienced an overall increase of nine percent in the number of incident files investigated and closed compared to the previous year.

Audits

Considerable progress has been made over the past two years in developing and undertaking privacy audits. Not only are there more audits being done compared to the past, they are more comprehensive in nature. 

Four audits that were in process at the end of the previous fiscal year (March 2006) were completed during fiscal year 2006-2007.  

For 2006-2007, the OPC originally planned to start seven audit projects under the Privacy Act. One more was added during the year making a total of eight new projects. Of the eight, two were completed in the fiscal year, two were substantially completed by March 2007 (reports pending), two were in process as of March 31, and two deferred to future years.

In addition, the Office also initiated two audits in the private sector pursuant to PIPEDA. These were substantially completed and reports pending as of March 31, 2007.

When the year began, the OPC hoped to have fully completed five new audits under the Privacy Act during the fiscal year. However, as the result of staffing delay as well as loss of audit staff due to extended illness and departure, the Office was unable to complete two of the original five with the fiscal year as first planned. The problem was mitigated to some extent by hiring professional auditors under contract. 

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.

Financial Resources (in thousands of dollars)

Planned Spending	Total Authorities	Actual Spending
$3,393	$3,701	$2,976

Human Resources

Planned	Actual	Difference
19 FTEs	14 FTEs	(5) FTEs

Expected Results for 2006-2007

• Positive engagement with Parliament
• Dialogue with provinces and territories on issues of common interest
• PIPEDA review and Privacy Act reform framework documents available
• OPC strategy developed for PIPEDA review and Privacy Act reform, and implementation under way
• Plan for 2007 International Data Protection and Privacy Commissioners Conference on track

Priorities for this Program Activity

The operations under this activity contributed to the achievement of the following priorities described in Section I.

Priorities	Type
Respond to Parliament	Ongoing
Participate in PIPEDA review and Privacy Act reform	Ongoing
Plan and prepare for the 2007 International Data Protection and Privacy Commissioners Conference	New

Performance in 2006-2007

Positive engagement with Parliament

The OPC appeared 11 times before House of Commons and Senate Parliamentary Committees on various issues such as:

• C-2: The Federal Accountability Act  
• C-25: An Act to amend theProceeds of Crime (Money Laundering) and Terrorist Financing Act and the Income Tax Act 
• C-31: The Elections Act

The OPC was invited twice to appear before the Standing Committee on Access to Information, Privacy and Ethics regarding the five-year statutory review of PIPEDA. On both occasions, the OPC tabled submissions on the application of PIPEDA and proposed amendments to it. In June 2006, OPC tabled its Privacy Act Reform Proposal, once again calling for a comprehensive review of the Privacy Act.

OPC continues to support Parliamentarians on privacy-related matters.

Involvement in dialogue with provinces and territories on issues of common interest

The OPC continued to work collaboratively with provincial privacy commissioners on different initiatives. As an example, in March 2007, Canada's federal, provincial and territorial commissioners joined together in their respective roles during the Fraud Prevention Month to call for renewed efforts in the fight against fraud, such as identity theft.  

In addition, the Office participated in two federal/provincial/territorial meetings, one in Nunavut in June 2006 and another in Banff in January 2007. The OPC also organized the Winnipeg Conference of Investigators in March 2007.  Those meetings, as well as other working level meetings, provide good forums to discuss experiences and approaches to continue to further harmonize privacy protection.

We are also developing a pilot project plan to enhance our presence in the different regions of the country - starting in Atlantic Canada. The idea is that OPC representatives will be based in the region to work more closely with the privacy protection ombudsmen in Atlantic Canada and to launch more locally targeted public education and outreach efforts, particularly with small businesses.

Status of PIPEDA review and Privacy Act reform processes

The Personal Information and Electronic Documents Act

In July 2006, the OPC issued a consultation paper which described several issues that we had identified as warranting consideration during the review. In November 2006, the Office tabled with the Standing Committee of the House of Commons on Access to Information, Privacy and Ethics a background paper summarizing the views received as part of this consultation, and setting forth the OPC’s preliminary views on how PIPEDA was functioning.  The OPC followed this up with an appearance before the Committee in February 2007.  See section 1.6 above (“External Factors”) for further details.

The Privacy Act

The Privacy Commissioner presented to Parliament in June 2006 a discussion document on reforming the Act.  The Office also appeared before the Committee in June 2006 to present this discussion document, which contains many recommendations.  See section 1.6 above (“External Factors”) for further details.

Plan for the 2007 International Data protection and Privacy Commissioners Conference

In September 2007, the OPC will be hosting the 29th International Conference of Data Protection and Privacy Commissioners in Montreal. By bringing together some of the world's foremost data protection experts to boldly chart the challenges ahead, the conference will explore ways of protecting and enhancing the privacy rights of all people.

Key milestones achieved by the OPC in the preparation of this conference include:

• Development of a draft program and the identification of key discussion themes
• Posting of preliminary program on the conference web site
• Identification of potential speakers and panellists
• Establishment of initial contacts/invitations with potential speakers and panellists
• Confirmation of conference venues in Montreal
• Hiring of additional external and internal resources to assist in conference planning and organization
• Promotion of the conference at national and international privacy events

As a lead up tothe conference, OPC colleagues from provincial jurisdictions are hosting three pre-conferences which will enhance the program. The Ontario Information and Privacy Commissioner will host a conference exploring personal health information. The Information and Privacy Commissioners of British Columbia and Alberta will host a conference on the privacy framework adopted by APEC Ministers.  Meanwhile, Quebec’s President of la Commission d’accès à l’information will host a conference on data protection in the context of la Francophonie. The OPC is working in close collaboration with these provincial counterparts to ensure that their pre-conferences are a success.

Major research and policy documents produced

Contributions Program

The Office evaluates funding proposals under the Contributions Program on the basis of both merit and alignment with OPC research and policy development priorities. A total of $388,319 was awarded to 11 organizations in 2006-2007 for research into emerging privacy issues, including research in the following matters:

• The establishment of professional certifications standards for privacy and information access professionals
• The use of digital rights management technology in Canada and its privacy implications
• The various aspects of identity policy in Canada
• The effectiveness of privacy policies aimed at children
• The challenges of de-identifying personal health information
• The relationship between technology and policy choices in health care
• The privacy implications of the use of various surveillance technologies in vehicles
• The secondary uses of health information and electronic medical records
• The implications to Canadians of the trade in personal information and the effectiveness of Canadian laws in adequately protecting consumers
• The use and handling of DNA collected during the course of criminal investigations

As well, one organization was awarded funding for the dissemination of research results on workplace privacy.

In addition to funding research under the Contributions Program, the OPC undertook in 2006-2007 two initiatives with a view to communicating knowledge gained through the program. In February 2007, the Office organized, in cooperation with the Law and Technology Group of the University of Ottawa, an Internet program – Privacy Symposium. This one-day event, held on the University of Ottawa campus, brought together program-funded researchers who have done work on Internet privacy issues. This event was a success, with over 100 participants attending from across Canada and abroad. In anticipation of the upcoming 2007 International Data Protection and Privacy Commissioners Conference in Montreal,  the OPC has undertaken to summarize all of the research reports prepared under the program since its inception – some 25 summaries in total. In addition to being distributed at the conference, these summaries will be posted on the OPC web site.

Other research-related activities

In addition to papers produced under the Contributions Program, the OPC published a number of fact sheets on its web site, including three dealing with new technologies and the challenges they posed to privacy. (Refer to the Public Outreach section below for complete list of fact sheets.) The Office provided Parliamentary committees with written submissions and other background material relating to issues on which it had been called on to testify, notably position papers on the PIPEDA review and Privacy Act renewal. The OPC presented a background paper on privacy standards as part of our contribution to a privacy standards workshop held in Ottawa in February 2007. The event brought together stakeholders from across Canada. Finally, the OPC undertook work on a guidance document pertaining to the use of radio-frequency identification (RFID) technology and video surveillance in the private sector, and started work on an ID management conceptual framework. Release of these documents is planned for fiscal year 2007-2008.

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.

 

Financial Resources (in thousands of dollars)

Planned Spending	Total Authorities	Actual Spending
$2,751	$2,654	$3,367

Human Resources

Planned	Actual	Difference
18 FTEs	10 FTEs	(8) FTEs

Expected Results for 2006-2007

1. Key privacy issues identified and positions articulated
2. Engagement activities launched for key audiences, such as Parliament, business, federal government, the general public, academics and the legal community

Priorities for this Program Activity

The operations under this activity contributed to the achievement of the following priorities described in Section I.

Priorities	Type
Improve and expand service delivery	Ongoing
Respond to Parliament	Ongoing

Performance in 2006-2007

Key privacy issues identified and positions articulated

As already mentioned in this Report, the OPC appeared 11 times before House of Commons and Senate Parliamentary Committees on various privacy issues (Bill C-2, C-25 Act, and Bill C-31) and was invited three times to the Standing Committee on Access to Information, Privacy and Ethics regarding the five-year statutory review of PIPEDA and the Privacy Act reform.

Engagement activities

The increased funding from the business case has permitted the OPC to undertake more extensive public awareness initiatives, carrying out the comprehensive proactive communications and outreach strategy first developed in 2004-2005.

« Canadians continue to place greater importance on having strong privacy laws, and this year’s study points to the highest levels of importance observed since March ‘05.” EKOS Research (March 2007)

The OPC commissioned its annual public opinion survey in March 2007 to revisit Canadians’ views on some of the emerging privacy issues with a focus on transborder flow of personal information, technology and privacy issues and general perceptions and awareness of privacy rights. The survey was instrumental in generating useful knowledge of, and insights into, the public's views of key privacy issues and will be analyzed to identify public education activities, policies and guidelines. A report on the study will be made available on the OPC web site.

In addition to initiating public opinion research, the OPC prepares daily press clipping packages and media analysis on key issues to support management in its decision-making. In this fiscal year, the Office responded to approximately 450 requests from the media for information and interviews on key privacy issues.

In an effort to both respond to and engage Parliamentarians, the OPC appeared 11 times at standing committees (both Senate and House), including eight submissions to Parliament, responded to various requests for information/clarification on privacy issues from MPs, and participated in a briefing session on the Office for Parliamentarians and their staff.

The OPC conducted research, generated public debates and worked at raising awareness of a number of important national privacy issues with all stakeholder groups, namely the public, respondents and complainants, federal departments and agencies, the legal community, academics and so on. As well, the OPC continued to hold its bi-monthly privacy lecture series, offering insights on privacy issues and future trends to audiences that include government representatives, academics, members of the private and non-profit sectors and OPC staff.

As part of its efforts to work collaboratively with other key privacy stakeholders, the OPC continued to liaise with provincial privacy commissioners to clarify responsibilities as they relate to the protection of privacy. The Office also kept provincial and territorial counterparts informed of its key activities and the release of privacy-related papers or submissions.

List of Fact Sheets developed in 2006-2007: Identity Theft - A Primer Recognizing Threats to Personal Data: Four Ways That Personal Information Gets Hijacked Online Privacy Impact Assessments Digital Rights Management and Technical Protection Measures Applications for Court Hearings under PIPEDA Risks of Metadata Privacy Act: Not an excuse to promote secrecy

In the spirit of providing top-notch information on the OPC web site, every effort is made to ensure that new and useful information is posted on an ongoing basis and in a timely manner. For example, the Office created an e-learning module for retailers. Members of the Canadian Federation of Independent Business and the Retail Council of Canada have been very supportive of this public education initiative and will collaborate with the OPC in the next fiscal year on focus-testing the online e-module. Overall, the most popular sections of the web site are related to privacy legislation, fact sheets and the business guide – the OPC site surpassed 1.3 million visitors for a second consecutive year. Focus group testing of the web site with key audiences has been initiated to further enhance it to ensure that the site is a leading resource for privacy issues. Findings will be analyzed and implemented in a web site project, which will be initiated in the next fiscal year.

Speaking engagement opportunities have helped the Office raise awareness of privacy issues among diverse audiences and settings, including professional and industry associations, non-profit and advocacy groups and universities. In 2006-2007, the Office received 114 requests for speaking engagements, and OPC officials delivered 86 speeches and presentations at events and conferences. These included addresses to the Retail Council of Canada in Toronto, the Barreau du Québec, and an access and privacy conference organized by the University of Alberta.

It is important to note that the OPC continued with its publications program. For this year, the OPC distributed more than 4,050 copies of its publications – ranging from privacy legislation to the PIPEDA guide for businesses and annual reports – to stakeholders, the general public, and legal communities. In addition, we worked on a campaign in partnership with the Retail Council of Canada to provide 5,000 of their members with a guide for businesses on how PIPEDA applies to them. This demonstrates the Office’s commitment to be more proactive in its public education activities, and to expand service delivery.

Furthermore, we developed a number of public education materials. For example, we updated and reproduced the business guide to help clarify obligations under PIPEDA, developed guidelines for identification and authentication that respect the fair information practices in PIPEDA and ensure compliance with its security provisions and produced numerous facts sheets on personal data, made available to the public. In addition, the Office posted a Questions and Answers document for individual Canadians explaining how they could go about filing a Federal Court application under PIPEDA. The document is an effort to demystify the process so people may have meaningful access to the court process and legitimately exercise their legal rights.

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 are expected to take responsibility for the expected results, and to integrate the necessary activities in their operational plans.

Expected Results for 2006-2007

• Allocated resources fully utilized
• New staff fully integrated
• Trained management and staff, sub-delegated managers
• Records information easily and quickly retrievable
• MITS compliance achieved
• Business continuity plan in place
• Regional offices planning completed
• Draft performance management framework and baseline measures in place

Priorities for this Program Activity

The operations under this activity contributed to the achievement of the following priorities described in Section I.

Priorities	Type
Improve and expand service delivery	Ongoing
Build organizational capacity: hire and integrate new staff, engage and train existing staff	New
Develop results-based systems and baselines	New

Performance in 2006-2007

Additional management achievements are also presented in Section 3.2 of this Departmental Performance Report.

The OPC conducted a review of its organizational structure during 2006-2007 as part of the implementation of the business case. Thirty-seven of the 47 organizational positions required to deliver on the business case (or 79 percent) were either created or reviewed in 2006-2007, complete with associated staffing actions, and the remaining 10 positions (or 21 percent) will be addressed in 2007-2008. Like other organizations, the OPC has faced challenges in the recruitment of personnel, which has impacted on its obligations to fully staff the additional resources allocated as part of the business case.

New staff were fully integrated in their respective branches. For example, new investigators and inquiry officers received a complete orientation program including mentoring, hands-on training, and group courses on interviewing and telephone techniques; as well, a nation-wide investigator’s conference allowed staff to foster partnerships and share experiences with provincial counterparts.

All sub-delegated managers and the majority of the non-delegated managers attended in-class training offered by the Canada School of Public Service as well as information sessions with employees and at the Senior Management Committee, accessed web information and newsletters, and received one-on-one mentoring from OPC staffing experts.

Enhancements were made to the document repository (RDIMS) and business rules for effective information management have been developed to help reduce information silos and ensure that information is easily accessible and retrievable. These enhancements are currently being tested in a pilot and will be rolled out to all OPC employees starting in June 2007.

The OPC has an action plan for implementing the Management of Information Technology Standards (MITS) and the December 2006 deadline for initial compliance has been met. An annual exercise will thereafter be conducted to sustain MITS compliance. Interim reports on MITS compliance have been positive to date.

A Business Continuity Plan for the OPC has been under development in 2006-2007 and work to finalize it will continue in 2007-2008.

Consultations were conducted in the Atlantic Provinces with Ombudsmen's Offices and the governments of Nova Scotia and New Brunswick as well as with regional academics to determine the needs of the region. Discussions took place on the possibility of sharing offices and other resources with the local Ombudsmen.

The OPC approved its comprehensive Results and Performance Measurement Framework in December 2006, along with a three-year implementation schedule starting in 2007-2008. (Refer to the OPC 2007-2008 Report on Plans and Priorities for more details.) In order to prepare for first year implementation of the framework in 2007-2008, the required measurement instruments were developed during the last quarter of 2006-2007. This will prepare the OPC for reporting against a first series of performance indicators from its new framework in the next Departmental Performance Report. The OPC has certain baseline measures in place already, for example the proportion of audit recommendations that are accepted and implemented, the proportion of cases referred to litigation versus settled to the satisfaction of both parties, reach of OPC materials to various audiences, etc. Some other indicators for which there are no baseline measures at present will be supported by performance information as the framework is implemented using an incremental approach over three or more years.

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