Summary of Comments from the Senior Advisory Committee of Coordinators To The Access To Information Review Task Force

The Task Force met several times in 2001 and 2002 with the members of the Senior Advisory Committee of Coordinators (SACC) to get their views on specific issues. However, any relevant issue could be raised and discussed during these encounters.

The SACC is made up of the Access to Information Coordinators of a variety of departments that are considered to be representative of access units across government. They meet regularly to discuss various issues relative to best practices and new developments in access to information. The membership is found in Annex 2. Not all members attended every meeting, and substitutes attended some meetings but every member was given the opportunity to review the summary.

The following is a summary of their comments to the Task Force. Annex 1 is a summary of the comments made by some SACC members in response to a survey of problematic requests undertaken at the request of the External Advisory Committee of the Task Force.

1. Access to Information Units and Community Development

• Challenges: When asked about the challenges faced by Access to Information (ATI) units, SACC members pointed to:
  
  
• The significant increase in the number and complexity of requests over recent years, unaccompanied, in many institutions, by a commensurate increase in resources;
• An increased need for consultations with other government institutions, other governments and the private sector;
• Deficiencies in records management in many institutions, which increases the difficulty of identifying and obtaining records within relatively tight time frames;
• A widespread lack of understanding of the Act and the obligations it imposes on institutions to respond to requests within statutory deadlines; the challenge of balancing the need to protect certain information with the presumption of disclosure in the Act;
• Communications problems they sometimes have with requesters who are not familiar with the Act, or with government or its terminology;
• The difficulty of attracting and retaining sufficient numbers of skilled professionals in access units; and
• A general lack of recognition of the complex and strategic role played by Coordinators.
  
  
• Recruitment and Retention: SACC members identified recruitment and retention of ATI staff as a huge problem. Careers in ATI need to be made attractive. A number of Coordinators and most experienced staff will be retiring or moving to other positions in the near future. Succession planning needs to be done at all levels. The group discussed the current Treasury Board Secretariat initiative of surveying the community as a first step towards succession planning. All agreed that developmental positions were key to enhancing capacity and ensuring succession planning.
  
  
• Classification of Positions: Classification was identified as a problem in the recruitment process. The benchmark position for Coordinators under the existing classification standard is a PM-05, which many departmental classification officers interpret as a maximum. This is in serious need of revision and updating as most of the Coordinators positions should fall within the executive level.

  The members recognized the wide range of positions and responsibilities for Coordinators across government and it's impact on classification of positions. There cannot be just one level of classification. However, it was felt that there is a need for a generic description of the Coordinator's responsibilities and functions that could be used as a base for all Coordinators' job descriptions. Similarly, there is a need for comprehensive descriptions of the range of responsibilities in an ATI unit performed at various levels and corresponding competencies.

• Skill Set: What is expected of Coordinators and their staff has evolved over the last few years. SACC members believe that a broader set of skills is required now. There is a need for good communications skills to deal with senior management and lawyers and negotiation skills to deal with requesters and investigators, as well as training skills to provide training to both their own and to departmental staffs. They suggested that these new skills be reflected in training and job descriptions of access staff.

  All feel that institutions need to better understand the strategic nature of the Coordinator's role. It should also be reflected in job descriptions and in the staffing of positions.
  

• Professional Training: Professional training was also discussed. All supported professionalisation and capacity building in the ATI community. Many were concerned, however, that requiring some kind of "certification" of access staff (as is the case currently for Human Resources staff) could be more of a barrier than a help in recruiting. It could also negatively affect mobility in the community. The point was made that a number of officers had been recruited into developmental ATI positions from program areas, for example.
  

  On the other hand, several members expressed the view that mandatory "directed training" in ATI would raise the level of knowledge and help "professionalise" the community.
  

• Location of ATI Units: SACC members felt that, given the varied size and structure and mandates of government organizations, it is appropriate that the organizational location of the ATI unit varies from institution to institution. Appropriate groupings included ATI units grouped with information management, with rights administration and compliance units, or with strategic units (planning, executive services, etc.). As a general rule SACC members believed that there should not be more than two levels between the Coordinator and the Deputy Minister - as recommended in the TBS Access to Information Policy - however, they recognized there would always be a few exceptions.

• Centralizing ATI Personnel: SACC members did not endorse the suggestion that it would be better if all access professionals belonged to one institution (for example, the Treasury Board Secretariat), and were deployed to departments. Moreover, they saw this as incompatible with exercising the delegated authority of the head of specific institutions. They were of the view that their credibility and effectiveness were a function of being a member of a particular department.
  
  
• Delegation of Authority: All agreed that the appropriate delegation of authority is key to a well-functioning access system and to timely decision-making. However, given the great variations in the volume of work, the extent of institutional decentralization, the sensitivity of information held in institutions and the skills and experience of access units, they recognized that the extent and nature of delegation will of necessity vary among institutions.

  In general, SACC members believe that authority should be delegated as far down as possible, and need not be limited to the Access Coordinator. This was done in most of the large departmental units and was found to be effective.

• Access to Deputy Head: In the view of SACC members what is critical for the Coordinator is to have ready access to the Deputy Head and senior management when needed. However, not all Coordinators had. The Internal Audit Policy was discussed. It sets out a requirement for the Deputy Heads to ensure that their head of internal audit has unimpaired ability to carry out his or her responsibilities and have access to the Deputy Head to report findings. This was thought to be a good model to emulate for Access Coordinators and SACC members recommended it become policy.
  
  
• Sensitive Files/Ethical Issues: In very frank discussions, the Coordinators talked about the stress involved in dealing with sensitive files and difficult requests. In delicate situations raising ethical issues for example, if they believed there were abuses under the Act several SACC members said they would turn to their Deputy Minister or ADM for support. Some others would seek the advice of the Treasury Board Secretariat ATIP Policy Unit, while others would seek the advice of their Departmental Legal Services. One Coordinator had sought the advice and received the support of the Information Commissioner in such circumstances. SACC members welcomed the recent establishment of Ethics Officer positions in departments as one more source of advice and support.

  SACC members, while highly supportive of the professionalisation of the Coordinator's role, forcefully rejected the idea of a specific code of conduct for access officials. In their view, the duty to respect the Access Act is binding on all public servants and any code of conduct should therefore apply to the public service as a whole. However, they were favourable to spelling out the roles and responsibilities for all public servants, including access officials, in the Access Policy.

• Access to support and expertise: A recurring theme was the need for central leadership in providing support to access units. SACC members wanted the Treasury Board Secretariat to act as a clearing house for gathering and disseminating best practices in the administration of the Act across the government and to encourage departments to share and adopt best practices.

  They suggested the Secretariat increase its capacity to act as a source of advice and guidance on problematic issues such as difficult investigations, onerous requests or possible non-compliance with the legislation. They would like to see more Implementation Reports issued. They suggested the Secretariat take the initiative in creating better linkages among its Access Policy Unit, the ILAP unit in the Department of Justice responsible for legal advice on ATI, and the broader access community in government. In addition, they wished for a higher level of expertise in their departmental legal units and for legal information sessions for access staff.

• Tools/technology: All agreed that government-wide tracking software for access requests should be available in all ATI offices. This is not yet the case with smaller agencies and some in a few larger ones. There was a sense that TBS should help the smaller agencies to acquire this technology.

  Coordinators are interested in technology allowing for end-to-end processing of requests (e.g. on line requests through the web, electronic payment, approval within the department, and electronic release). However, no departments are currently testing any end-to-end applications.
  
  Six departments had submitted proposals for central funding under the Government On-line initiative for technology to improve the access process. Unfortunately, none of these proposals ended up being funded. Coordinators hope there can be funding for these initiatives in the future given that the access process could be significantly facilitated. For example, not only could requests be received, tracked and processed electronically, but fees could be collected and statistics generated automatically on all aspects of the processing of requests. It could also provide analysis of trends and information frequently requested for posting in reading rooms or proactive release.

  SACC members suggested that TBS should host learning networks on the use of technology in processing requests.
  
  

2. Proactive and Informal Disclosure

SACC members were very much in favour of increased emphasis on proactive and informal disclosure mechanisms. Criteria should be developed by TBS as to what departments should place on the web and at what frequency.

There should be systematic analysis of access requests received by institutions to identify issues of high public interest and concern, and to provide this information proactively. One example was Environment Canada's initiative to make fish consumption advisories available on their Web site as a result of previous access requests for information on the mercury level in fish. Another example is Health Canada's initiative to make information on adverse drug reactions available informally.

ATI units could provide advice to departments on informal disclosure and proactive release policy, mechanisms and best practices. One Coordinator even advertised the advisory services of the ATI unit in the department. This does not mean that ATI units should be asked to review all proactive or informal disclosures.

3. Info Source

SACC members were of the opinion that Info Source will be used more and more by Canadians, and that it should be linked to Government On-Line. They believe that updating Info Source should be an ongoing thing, however, it is a burden on ATI units and there is a need for resources to do a better job.

In addition, Info Source should be organized by subject to stay relevant and understandable to users, and should be linked to departmental web sites. TBS is currently reviewing Info Source.

4. Annual Reports

Departments should improve reports to Parliament on access by providing more explanatory and narrative information and not just statistics. Their challenges, goals for improvements and performance against these goals should also be reported.

5. Enhancing access awareness and accountability in institutions

SACC members volunteered their "best practices" to increase awareness of, and accountability for, access in their institutions. These ranged from reporting late files to Assistant Deputy Ministers, to making presentations to Senior Management Committee on an ongoing basis, and to giving year-end analyses at Senior Management Committee. In some cases departmental branches were given a customized year in review analysis and a weekly list on their desktops. In other cases, ATI was included in the job descriptions of managers and officers, and training/awareness sessions were regularly given to senior managers. Another best practice was to educate program managers by keeping them in the loop on the decision to release and the resolution of any complaint. Still other best practices included a monthly award to the best performing OPI and linking ATI activities clearly to corporate objectives in the Corporate Plan.

6. Application of Exemptions

A number of discussions with SACC members were about the application of certain exemptions:

• Existence of a Record not required to be disclosed (s. 10): Some members indicated they use the s.10 provision on a regular basis, mostly in connection with investigations. They are concerned that indicating what exemptions would apply would disclose the existence of the information protected, such as the existence of an investigation or of a legal opinion.

  Some members were not certain if s.10 could apply to matters other than intelligence. Others noted it had been used for s.20, s.19, s.14 and s.23.

• Personal Information (s.19): A number of members noted that, in some cases, the Office of the Information Commissioner and the Office of the Privacy Commissioner have divergent views on what constitutes 'personal information' or on what personal information should be released in the public interest. This puts departments in impossible situations. Coordinators would like mechanisms to resolve these issues. Some members expressed the view that the two offices should be merged.
  
  
• Third Party Issues (s.20): SACC members believe the solution to unnecessary litigation is largely in educating third parties about the disclosure requirements of ATI at the time of contract. Many do not know about the Act, especially small businesses. A "best practice" followed in one department is to send out with all third-party notices a short document to help the third parties understand their obligations in responding.

  Departments fear inadvertently releasing confidential third party information - and thereby incurring liability or damaging relationships of trust. In many cases they do not know the third party's business well enough to judge.

  SACC members felt the legislated time limits for notifying third parties to be too short: the 20 days for the third party to respond to the 1^st notice from the institution is too short as the third party may have to review thousand of pages of sensitive and technical information to come up with an informed decision and make realistic representations to the institution. By the same token the 10 days for the institution to review the third party representations on complex and voluminous files is much too short. Some members suggested extensions should be available with notice to the Information Commissioner for voluminous or complex files. Right now the only thing Coordinators can do is to get permission for more time from the requester.

  Some members were of the view that the 20 days period for the second notice to the third party of the intention of the institution to disclose was too short as it is when the serious negotiations take place. All SACC members believe that with more time to educate and negotiate, between first and second notice, there would be more consent by third parties to release and there would be fewer unnecessary court proceedings.

7. Fee structure and application

There were a number of discussions on the fee structure, the application of fees and fee waivers.

All SACC members agreed that fees should not be considered a cost recovery mechanism but that they were important to ensure the sustainability of the system by providing both discipline in it and by contributing toward the cost of processing the request. They suggested that fees paid be invested to improve the ATI system.

• Application Fee: SACC members believe that a modest application fee is needed to ensure that only serious requests are made. This was perceived to be even more important for the future with the advent of easily made electronic requests. The reception of the application fee also signals the start of the formal process under the Act. Members generally expressed the view that the application fee has not kept pace with inflation and should be updated. Some felt the application fee should be $25, as provided for in the Act.
  
  
• Processing Fee: Problem areas with the current fee structure and its application were the difficulty to estimate precisely cases where a lot of search time is involved but very little released (looking for a "needle in a hay stack"), fees applicable for data bases and for expensive searches of back-up tapes, and supervision of requesters reviewing "original documents".

  The processing of requests from frequent requesters tended to be more efficient as they generally have more focused requests and charge accounts with institutions.

  Generally, SACC members were in favour of a media free reproduction charge (e.g. $ per page/megabyte/etc).

• Fee Waivers: Waivers of fees were also discussed. It was quickly recognized that there was no consistency across institutions or even within institutions. Some had developed a policy but many had not. All institutions adjusted the fee charges for sub-standard records management. Institutions normally warn requesters before starting to search if they do not expect to find anything or if it is clear, from the nature of the records requested, that nothing is releasable but some requesters want them to go ahead in any event.

  Factors considered by ATI units in waiving or simply not charging fees varied, and included the status of the requester (victim, client, staff), where no records were released, and where the institution was late or had made a mistake of some kind. SACC members believe that generally institutions tend to waive less in the case of large requests. They concluded that there was a need for more consistency and policy rationale in waivers. They were not opposed to criteria to guide the exercise of waivers, but insisted that it was important to maintain some discretion to ensure the required flexibility to deal with each case fairly.

• Australian Law Reform Commission model: SACC members discussed the features of the model proposed by the Australian Law Reform Commission (but not implemented). It would merge all the separate fees applicable into a simple sliding scale of fees based on the number of pages released. It could be a more predictable system for users and simpler for departments to administer. In addition, it could possibly lower the potential for disputes.

  SACC members were not convinced that the Australian proposal, however simple, established better incentives for departments and requesters. They believed that having separate search fees encouraged departments to do a thorough search and encouraged applicants to focus their requests. The preparation fee encouraged departments to make rigorous severance of material and disclose as much as possible. They commented that departments with a rigorous, well-documented process to estimate and calculate fees did not experience difficulty or complaints and, if there were, they felt very assured they could justify their estimates. The members believe the current fee structure is working and the problems with fees have more to do with training and processes and lack of institutional policies. They saw the current fee model as the most appropriate because it provided the required flexibility to accommodate a variety of circumstances. The main improvement they suggested was an update of the fee rates.

8. Administrative Review

In the United States and in a number of jurisdictions abroad, a requester has a first right of appeal to the head of the institution. There was a discussion on whether or not this was a suitable mechanism for the federal access regime.

SACC members were not convinced that it would be an improvement. They were concerned that it would lead to the possibility of more delay for requesters and that it would be difficult to get managers' time to do a good job on the review. The also felt that a review by another manager or unit in the institution would erode the authority of the access Coordinator whose decisions or advice would be subject to second-guessing by the person or unit conducting the review.

9. Follow-up with requesters

SACC members recognized that unnecessary complaints could be avoided by clearing up misunderstandings about the Act, the nature of the record sought, or its existence. They believed that the best way to do that was to ensure good follow-up with requesters at many points during the process but especially at the outset to clarify the request and at the end to offer to provide explanations to requesters about the release. A good feedback loop would provide an opportunity to deal with misunderstandings before they degenerated into complaints and to keep requesters aware of any problems encountered with processing requests. Each contact with the requester should be noted on the process file.

Another good practice was to offer to put the requester in direct contact with the program staff to explain his/her request especially where it is technical in nature.

An open, receptive attitude among ATI staff and building relationships with requesters to better understand their needs were seen as essential to the effectiveness of the process.

10. Documenting process files

The Office of the Information Commissioner is concerned that departmental process files are often not documented as well as they should be on the reasons for using exemptions. This was making investigations more laborious.

SACC members acknowledged that documentation was at times cursory but they made the point that the Coordinators' first priority is to provide a response within the legislated timeframes. With the recent focus of the Information Commissioner on meeting deadlines, it had become the top priority for departmental management as well and anything else took a back seat. The members' view was that not all exemptions needed to have documentation but agreed that there were instances where better documentation could be achieved. However, they insisted that documentation standards needed to be realistic and sustainable in terms of resources available in both ATI offices and program areas.

11. Improvements in the system/Relationship with OIC

Overall, SACC members were of the view that the pressure put on institutions by the Information Commissioner in recent years has resulted in many institutions reviewing their processes, and in some ATI units receiving more visibility and resources. A number of members, however, were concerned that some initiatives by the Information Commissioner had caused a degree of animosity and lack of trust between the OIC and the institutions.

SACC members were of the view that the working relationship between the Office of the Information Commissioner and the public service needs to be more harmonious and developed so they work collaboratively to advance the public availability of information and education about government activities.

12. Investigation of complaints

• Streamlining Time Limits: There was general agreement that investigations, especially those dealing with process issues (delays, fees, format, etc.), should be streamlined. SACC members believed that reasonable time limits for investigating a complaint would force both departments and the OIC to have more effective processes and earlier outcomes for requesters. There was concern, however, that it could put too much pressure on the OIC and departments given the resources available currently. If time limits were set, members emphasized the need for extensions of time limits for investigations to reflect the complexity of some files.

• Investigative Process: SACC members believe that there is a need for a more transparent and consistent process, and a need to focus the scope of the investigations. Coordinators need to know clearly what issues are being investigated. Several members said that they were not always sure when an investigation was over and were concerned about issues surfacing a long time after the beginning of the investigation. Many members expressed the view that the process has to become more rigorous and disciplined on both sides. In general, they are concerned that investigations are too long, lack consistency, do not build trust, and are not the learning processes they could be for institutions. They were of the view that the Information Commissioner should post his investigation protocol on his web site and that it should be explained to all institutions.

  For the most part, SACC members saw investigators as very professional. However, there was a high turnover resulting in unevenness in experience and skills. They recognized that ATI staff needed to be better informed on the investigative process and their role in it.

• Concerns: SACC members generally had a number of specific concerns with investigations:
  
  
  • Self-initiated complaints by the OIC - the members generally did not believe they were the best way to deal with systemic issues. They also suggested that, for transparency, data on self-initiated complaints should be reported separately from complaints by requesters;
    
    
  • "Scope creep" - they were concerned about expansion of investigations beyond the issues raised in complaints especially in cases of delay complaints or "deemed refusals". For example, SACC members were of the view that the investigation of a complaint of delay should not expand to cover the application of exemptions and that an investigation for a complaint of delay should be extremely streamlined where the response has been provided to the requester;
    
    
  • A perceived lack of focus or transparency as to what is being investigated in some cases;
    
    
  • SACC members believed the practice of issuing subpoenas was snowballing;
    
    
  • Interview overkill on some files;
    
    
  • Highly charged interviews, sometimes with confrontational tactics;
    
    
  • The practice of confidentiality orders/agreements for witnesses and their counsel.
    
    
• Best practices: SACC members had a number of suggestions for improvements to the review process and investigations:
  
  
  • The first point of contact for the OIC should always be the ATI analyst who is responsible for the file;
    
    
  • Clear rules as to how the interaction of the institution with the OIC would be handled during an investigation (i.e., the Coordinator will not get involved with the IC unless the ATI officer and the investigator on file cannot solve the issue) ensure that issues are addressed appropriately and not escalated needlessly;
    
    
  • Keeping the Coordinator in the loop always re: officials being interviewed or upcoming orders, etc.;
    
    
  • The specific grounds of complaint should be provided to Coordinators;
    
    
  • Obtaining the questions of investigators in writing and answering them in writing ensures clarity and focus;
    
    
  • Establishing a more structured approach to representations by parties;
    
    
  • An opportunity to signal errors of facts in investigation reports;
    
    
  • Departmental procedures on how to handle complaints and investigations for both ATI units and program staff;
    
    
  • Consistency in approach by OIC investigators on access issues;
    
    
  • Investigators organized by portfolios so they could get to know areas of government activities and make more informed judgements;
    
    
  • Training for ATI staff on the investigative process and on their role in it - OIC should brief ATI staff on their investigative process;
    
    
  • Structured, open forums so that investigators and Coordinators can meet regularly and discuss at a general level the review and investigation process.

SACC members noted that a relationship of mutual cooperation has to be built in order to make investigations more effective for both parties. They expressed the wish that investigations would evolve into learning processes for institutions.

13 Clear rules of interpretation

Overall, SACC members emphasised the need for more clarity and coherent guidance to institutions:

• There should be only one set of rules for institutions to follow not one from TBS and a different one from the OIC.

• All interpretative findings by the Information Commissioner should be posted on his office's Web site to provide guidance institutions and requesters.

Consultation with Access to Information Units on "problematic requests"

At the request of the External Advisory Committee, the Task Force contacted the Access to Information Units of the largest departments and asked them for concrete examples of what they might consider as "frivolous", "vexatious", "repetitive", "burdensome" or other otherwise "problematic requests".

The External Advisory Committee wanted to have a clearer sense of the realities covered by these often-used words.

Observations

• Overwhelmingly, coordinators first made the point that the current Act has no provision for "frivolous, vexatious or repetitive requests" and, therefore, this could not be, and was not, considered relevant in responding to access requests.
  
  
• No tracking is done of such requests but, in the view of the coordinators, they do not often encounter requests that can be characterized as "frivolous or vexatious". When a "vexatious or frivolous" request does present itself, however infrequently, it tends to attract much attention because of the inordinate drain on resources and the very negative impact it has on the attitudes of departmental staff toward access.
  
  
• Coordinators also noted that it was often only in retrospect -- when the requestor showed no interest in the resulting information -- that a request could be categorized as "frivolous or vexatious".
  
  
• Requests that are repetitive and burdensome are encountered more frequently and because of the greater frequency are more problematic for institutions.

Examples

The following were provided by ATI Units as illustrative of what they meant by "problematic requests":

• Requesters filing repetitively for the same documents - some requesters repeatedly request the same documents about themselves. Some of these individuals believe that the government is monitoring them. Other requesters repeatedly ask for the same records (not updated) about their business. They may have forgotten what they originally asked for or their records may be so disorganized that it is easier to request government for them.
  
  
• Requests are made for access to the same records as are being accessed under pre-discovery court processes. These are often perceived as "trying to tie up the Department" in an effort to stall the court case, since the same lawyers need to be involved in both processes. These requests are often for very large quantities of documents. Specific examples of these type of requests:
  
  
  • A request for documents back to 1980 received from a legal firm encompassed over 200,000 pages and will take three years to process, leading to a fee estimate of $433,000 for search time. An agreement was reached with the requester to process 5,000 pages a month, but the requester is unhappy because of the slowness in receiving the documents.
    
    
  • A request for information was made involving some 200,000 documents also requested under discovery in the context of litigation involving the same people to review the records; it required a three-year extension. The department hired 5 people and spent $1.3 million dollars to process this request.
    
    
• University students filing ATI requests because their professor of political science tells them this is the best way find out about how access to information works. The students tend to ask for difficult records but have no interest in the outcome. If the information is offered informally they respond that if they do not receive the information under the Act they cannot get a passing grade on the assignment. Such requests are considered to be "nuisance" requests.
  
  
• One department regularly receives a request every 6 months from one requester for "all briefing notes to the Minister on all subjects". This requester resists efforts to persuade him to narrow his requests. This results in a disclosure package of 10,000 pages every 6 months for which no fees or very low fees are charged because the requester views the records in the department.
  
  
• A request for "all the records in the office of Mme "X" was considered to be vexatious since the requester showed little interest in the outcome. The request took a year to process and partial releases were made every month. The requester came in to view the first release and never came back to see the rest.
  
  
• A request was received from an employee who lost a competition. The information sought was all the similar level staffing actions for the last 5 years from across Canada. Processing this request resulted in practically shutting down the human resources services of the department, with a significant impact on almost all staffing actions in the department for several months.
  
  
• Several departments across government reviewed requests from a firm for information. The firm then tried to pressure departments into buying their goods and services to solve the "problem" revealed by the information. This was perceived by Coordinators to be inconsistent with the intent of the Act.
  
  
• An employee whose employment contract was not renewed left the department in an angry mood and subsequently made multiple requests for information pertaining to a new legislative implementation project, including draft proposals, committees, etc. Members of his firm also made multiple access requests. None of the requesters showed any interest in the information when it was ready for release. It was suspected that he was trying to slow the department down and "get even".
  
  
• A request was received from a union leader in one department asking for the number of water jugs in meeting rooms in headquarters as well as in all regional offices across the country, where they were purchased, and how much they cost, as well as wastebaskets, paper shredders, etc. This entailed finding the procurement documents and invoices for these items in each office. The requester was thought to be trying to "get even" with the department because of a labour disagreement.

List of Members

Senior Advisory Committee of Co-ordinators (SACC)

Canada Customs & Revenue Agency
Citizenship & Immigration
Correctional Service Canada
Finance Canada
Foreign Affairs & International Trade
Justice Canada
Fisheries & Oceans Canada
Health Canada
Human Resources Development Canada
National Archives of Canada
National Defence
Privy Council Office
Public Works & Government Services Canada
Royal Canadian Mounted Police
Treasury Board Secretariat

Consultation