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ARCHIVED - Horizontal Internal Audit of Electronic Recordkeeping in Small Departments and Agencies


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Detailed Findings and Recommendations

Finding 1: Policy and Strategic Direction


Implementation of strategic direction over electronic recordkeeping in SDAs is in the early stages.

We reviewed the Secretariat's strategic guidance provided to SDAs to coordinate IM activities government-wide. We examined the progress implementation of the Government of Canada Information Management Strategy in SDAs, 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 departments and agencies – 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 SDA community has formed a network of committees designed to discuss common challenges and share information from the perspective of small agencies, which generally have fewer resources and less infrastructure requirements. This network is referred to as the Community of Federal Agencies[2]. Its committees facilitate information sharing and discussions toward developing solutions to common challenges for SDAs in meeting government requirements. None of these committees currently address challenges related to SDAs in IM; however, the Heads of IT Committee have announced this committee's intention to include IM concerns in future meetings. The inclusion of IM within the mandate of this committee will enable SDAs to leverage each others' knowledge and experience in this area.

The management control framework for information management in SDAs incorporates Treasury Board policy requirements.

We found that the requirements of the Treasury Board Policy on Information Management and its associated directives were appropriate given the size and scope of IM activities in SDAs. The policy is principles-based and provides a reasonable framework for roles and responsibilities between central agencies and individual departments and agencies. In accordance with Treasury Board policy, SDAs have established IM as a distinct part of their organization structure. Most have identified an IM senior officer who is in a position to inform senior management of risks to the IM activities and is responsible for the development of related guidance. Some SDAs have established separate committees with specific mandates relating to IM. Most SDAs discuss IM on an as-needed basis at their existing executive or operational committees. To further strengthen their management control frameworks, SDAs would benefit from ensuring that IM is included in the roles and responsibilities of a senior management committee to ensure associated risks and other requirements are discussed as needed. 

IM planning and monitoring of its implementation is in the early stages of maturity.

While some SDAs have IM plans that are in place, most do not. For those SDAs that do have such plans in place, most are not yet monitoring the progress of these plans. One SDA has formalized its IM plan and is monitoring progress on a timely basis. This plan is appropriate to the size and scale of the SDA's IM requirements and provides a degree of formality required to ensure success of initiatives. For those SDAs that have limited IM requirements, it may be appropriate to include their IM planning within their overall departmental plan to ensure needs are accounted for. As significant IM priorities arise that require additional resources, it will be important for SDAs to incorporate these requirements into overall departmental planning activities. SDAs would benefit from the development of performance indicators to assist in monitoring the effectiveness of their IM plans. 

Recommendations
  1. SDAs should develop IM plans appropriate to the size and scope of their IM needs, and include measurable performance indicators to be able to monitor the effectiveness of the plans.

Finding 2: Retaining Information That Has Business Value


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

We examined methodologies that SDAs use to identify the business value of the information they generate. We also examined how electronic record keeping tools and applications are being used in the departments. We examined the retention and disposition processes, and the guidance provided to all staff. Finally, we examined the methodology 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 longterm benefit to the Government of Canada and to Canada's national interest.

In the absence of identifying information of business value, SDAs could overburden their systems with information that has no long-term value for the operations of the 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. Without tools and applications to manage information centrally, the retention and disposition processes could become increasingly more complex. After determining the effectiveness of departmental processes for retention and disposition of information, LAC grants records disposition authorities to departments that allow SDAs 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 with no long-term value. 

Most SDAs have not yet identified information of business value.

Most SDAs have not yet defined business value as it relates to the IM needs in their organization, and provide little to no guidance for departmental staff. Most SDAs 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 SDAs still classify records based on security and/or access restrictions; business value is not addressed. As a result, SDAs are potentially spending resources tracking, maintaining, and archiving information of no long-term business value to the Government of Canada.

Electronic recordkeeping systems are inconsistently used by departmental staff.

Use of enterprise-wide applications for electronic recordkeeping varies in most SDAs from employee to employee. Most SDAs have not made electronic recordkeeping systems mandatory and instead leave use 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. Some SDAs are also using multiple enterprise-wide applications for different operational areas, some of which are not interoperable. Because information exists in SDAs across multiple platforms, information may not be readily accessible to decision makers to deliver program objectives. It is important for SDAs to ensure interoperability between systems is addressed when implementing their IM strategy.

It should be noted that effective enterprise-wide electronic record keeping systems can be cost prohibitive for some departments.  SDAs should consider options such as working with partners, including other government departments or shared service initiatives, to make the purchase of effective systems more economical.

One SDA maintains paper-based records as a result of a legislative requirement to do so.  Some SDAs still maintain paper-based systems as they have not yet migrated to complete electronic record keeping. These SDAs often create electronic records which are then duplicated in paper form for inclusion in the physical file. This may hinder efficiency of IM activities, as well as increase the risk of inaccurate records being provided to decision makers. The Policy on Information Management requires that Deputy Heads ensure that electronic systems are the preferred means of creating, using, and managing information within a department. SDAs should put plans in place to be able to meet this requirement.

Retention and disposition processes do not reflect the electronic environment.

Most retention and disposition strategies were developed for paper-based recordkeeping. As SDAs move towards greater use of electronic record keeping systems, SDAs are increasingly challenged to retain and dispose of multiple versions of electronic records. Disposition of electronic records is performed by staff on an ad hoc basis and is not linked to established retention and disposition processes.  In theory, departmental staff could be deleting information that is important for decision makers; conversely, storage capacity could be burdened by electronic records which are unnecessarily retained.

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 suffered from 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 disposal government-wide.

Recommendations
  1. SDAs should define information of business value for their organization and develop methods to ensure it is tracked and stored in an effective manner.
  2. SDAs should develop strategies to increase the use of enterprise wide electronic recordkeeping systems within their department.
  3. SDAs, in collaboration with LAC, should develop formal retention and disposition processes that can be followed by all departmental staff.

Finding 3: Learning and Awareness


SDAs are addressing training and awareness requirements for their IM practitioners but not for all departmental staff.

We examined the Secretariat's functional guidance for IM practitioners, and the courses developed for the IM community. We examined IM mandatory training that SDAs provide for their IM practitioners. Finally, we also examined IM training provided to all SDA staff outside the IM function, and whether IM practitioners are able to determine if the 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. Training plans help to 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 the 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 departments and agencies, the Secretariat and LAC can ensure that centralized guidance is customized to the various working levels that will implement IM strategies.

Training for IM practitioners is planned and coordinated.

Most SDAs have trained and experienced staff within their IM functions.  The staff turnover for IM practitioners is low, and training requirements can be effectively planned over a long term. IM practitioners in SDAs are well positioned to implement further electronic recordkeeping advances for departments. 

Some IM training is being provided to departmental employees but learning requirements have not been identified.

Most SDAs have not developed IM learning strategies for all departmental staff. Most SDAs have developed one or two training sessions for departmental staff but without clearly defined learning objectives. Some SDAs offer new employees individual sessions with departmental IM professionals. One SDA is cross-training IM practitioners with departmental staff and vice versa in order to promote IM awareness throughout the organization. Because SDAs 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 understands their role in implementing the IM strategy, including the need to track and retrieve information of business value and what training may be required.

Recommendations
  1. SDAs should perform electronic recordkeeping training needs analyses for departmental staff, and implement actions required.

Management Action Plans

The findings and recommendations of this audit were presented to each of the departments and agencies included in the scope of the audit. The Office of the Comptroller General has asked each department and agency that has received recommendations as a result of the audit to prepare detailed management action plans.