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Report 29 - Access to Information Review Task Force
NEW REPORTING FRAMEWORK FOR ASSESSING THE PERFORMANCE OF THE ACCESS TO INFORMATION PROGRAM
2.4.2 Develop Strategies/Approaches to Deal with Demands
Once demands for information have been analyzed and trends identified, the Program would develop strategies and approaches to deal with them. This would be done at both the department/agency and Treasury Board Secretariat level. In a sense, this is the Program's planning function. It may include the following sub-activities:
1) Reviewing information and analyses and setting strategic priorities for the coming year or more, at both the department/agency level and for government as a whole.
2) Developing strategies and methods for dealing more efficiently and effectively with existing, new and emerging demands for information, some of which may be designed to reduce or eliminate demands for information through the Act.
3) Reallocating resources, as necessary, to address new and emerging priorities.
4) Developing a variety of strategic and operational plans, including the equivalent of a Corporate Business Plan and a Departmental Report on Plans and Priorities. (In the case of the latter, for example, the Treasury Board Secretariat has issued guidance on how departments and agencies should report in its Information Circular entitled "Annual Reports and Statistical Reports of the Access to Information Act and the Privacy Act.")
Developing strategies and approaches to deal with demands for information should result in clearer expectations and priorities, increased coordination and consistency and more efficient and effective use of Access to Information resources.
2.4.3 Implement Strategies/Approaches
Once strategies and approaches have been selected they need to be implemented. This, too, would be done at both the department/agency and government-wide level. This activity is akin to the Program's mobilization function. It involves the alignment (or realignment) of the Program's resources to support strategies developed during the planning phase. It includes the following sub-activities:
1) Modernizing and harmonizing the Program's legal mandate
2) Developing new and revising, where necessary, existing practices.
3) Forging partnerships to deliver strategies.
4) Negotiating to reduce or eliminate technical barriers.
5) Ensuring the right skill set by recruiting, developing and training staff.
6) Ensuring effective request processing throughout the department by training program staff.
7) Consulting with requesters to identify and assess effective, alternative strategies.
8) Redesigning practices and procedures to address demands for information.
It also involves informing the public about effective ways to use the Act and
other avenues to access government information by:
9) Increasing public awareness about the Act and its provisions.
10) Preparing departmental input for Info Source.
11) Helping the public understand how to access information more efficiently and effectively, including awareness of their rights.
12) Providing information on the operation of the Access to Information Program designed to maintain or increase public confidence in accountable government.
Implementing strategies and approaches will lead to the reduction and/or elimination
of technical barriers, more appropriate responses to request, increased public
awareness/knowledge about Access to Information and how to use it which should
lead to more appropriate requests.
2.4.4 Receive Requests/Retrieve Information
Institutions, through their ATIP offices, receive requests for information that they hold. They review the request to make sure that it is clear and complete and either:
i) identify that part of their organization that can best deal with it (the Office of Primary Interest, (OPI) or, in certain cases,
ii) transfer the request to another department or agency if that is more appropriate.
They then set up an ATI file, inform the OPI of the request, and ask the OPI to estimate the time required to locate and prepare the records.
The ATIP office may inform the requester that the institution needs more than the 30 days mandated turn-around time to fill the request. If so, it also informs the requester that s/he may appeal to the Office of the Information Commissioner. In some cases, the requester may be informed that access to the information requested is either exempt or excluded under the Act. The ATIP office tracks the progress of the request, while the OPI sets about retrieving and assembling the requested information.
Receiving and reviewing request for information should result in appropriate departments or agencies being consulted, in timely information about the state of requests and in appropriate fees being charged.
2.4.5 Review/Release Information
Once the OPI has collected the requested information it is sent to the departmental ATIP office to determine whether it may be released. The OPI may make a recommendation in this regard. In some cases, part or all of the requested information may be either exempt or excluded under the Act. The ATIP office and the OPI resolve any differences in releasability and the appropriate information is sent to the requester.
In some cases, more than the 30 days mandated turn-around time may be needed to fill the request, including consultation with other government, other departments or third parties. If so, the ATIP office also informs the requester of the delay and that s/he may appeal to the Office of the Information Commissioner. The ATIP office must also notify the OIC if they apply an extension beyond 60 days.
Reviewing and releasing information should result in appropriate information being released and protections being safeguarded, and appropriate information being protected in the timely and consistent release of information and in increased public access to information.
2.4.6 Receive/Initiate, Investigate and Resolve Complaints
The Office of the Information Commissioner (OIC) deals with complaints filed by requesters when:
- they have been denied requested information;
- they have been asked to pay too much for processing the request or reproducing the information;
- the department's extension of more than 30 days to provide information is unreasonable;
- the material was not in the official language of choice or the time for translation was unreasonable;
- they have a problem with the Info Source guide or periodic bulletins which are issued to help the public use the Act; and,
- they have run into any other problem using the Act.
The OIC may also initiate complaints where there are reasonable grounds to investigate a matter relating to a request. The OIC investigates the complaints, produces findings and makes recommendations for resolutions of the complaints. The OIC may not order a complaint resolved in any particular way. As a consequence, in cases where a complaint is about a denial, and the OIC and the department/agency disagree, the OIC may pursue legal action to the Federal Court with the consent of the complainant.
At the end of the year the OIC prepares an annual report on its operations, on its assessment of the performance of departments and agencies with respect to Access to Information, on highlights of court cases/decisions and may recommend ways to improve the Act.
Receiving/initiating, investigating and resolving complaints should result in appropriate information being released and protections being safeguarded, in the timely and consistent release of information and in increased public access to information. It should also result in consistent practices and appropriate fees being charged.
2.4.7 Assess Strategies and Approaches to Deal with Demands for Information
This is the Program's review function. It emphasizes learning and growth. It seeks to determine how efficient and effective the Program's strategies and approaches to dealing with demands for information have been. It feed the first two functions in the Program's performance model: a) Monitor/Analyze Demands for Information and b) Develop Strategies/Approaches to Deal with Demands. It includes the following sub-activities:
i) Assessing the Program's strategies and approaches with a view to:identifying, if any, weakness in their efficiency and effectiveness; and, recommending ways to overcome them.
ii) Conducting surveys of requesters about the service they received.
iii) Reporting on government-wide and departmental performance through appropriate documents.
Assessing strategies and approaches to deal with demands for information should result in better managed access to information efforts and more efficient and effective strategies and approaches.
Return to Table of ContentsThe following logic chart (see page 13) depicts these eight key activities along with their main outputs and the outcomes they are expected to produce. This Activity ==> Output ==> Impacts chain shows what results can be achieved. As such, the logic chart makes explicit the "cause and effect" relationships of performance so that they can be managed and validated.
In the Activity ==> Output ==> Impacts chain, activities are major (in terms of resources) or significant (in terms of importance) chunks of work. These are what resources are used for. Outputs are the goods or services provided through the Access to Information Program to its customers or clients. These are key because these are the basis on which clients judge performance. Impacts (used synonymously with results or outcomes) are the consequences of these outputs. (Note that this terminology is akin to that used by the Treasury Board Secretariat in its recent documentation on Results-based Management and Accountability Frameworks).
In looking at the logic chart, it is important to note that the Activity ==> Output ==> Impacts chain -- that is, the vertical arrows -- focuses on primary causality. For example, developing strategies and approaches is primarily designed to set clearer expectations and priorities, increase coordination and consistency and use Access to Information resources more efficiently and effectively. It may lead to the timely, consistent release of information, but other activities, such as the review and release of information are primarily designed for that purpose.
The horizontal arrows connecting the activities suggest a "logical" sequence in which the program may deliver its services. They also capture the notion that earlier activities support the impacts achieved by later activities, but that their "influence" fades the further they are from the impact.
2.6 Performance Data Suggested by the Model
The model presented in the logic chart suggests a variety of performance measures by which the ATI Program could be reviewed. First, the activities suggest the need for workload indicators as these are important for resourcing purposes. Second, the outputs suggest the need for client and third party satisfaction indicators. Last, the key impacts suggest the bottom-line results that the Program is expected to achieve.
Although the model suggest a variety of performance measures, many of these would be of limited value. There is a need to be selective in identifying performance measures. For purposes of this project, emphasis has been placed on identifying those measures which provide information which is useful to decision-making
The model suggests several key performance indicators at the workload level. These include: (i) the number of requests received - including a measure of their complexity, such as number of pages requested, number of units involved in assembling the information or ambiguity of the Act in terms of releasing the requested information; and, (ii) the number of consultations. To a lesser extent, the number of strategic/operational plans (outputs from Activity 2 in Logic Model, page 13) and the number of reviews (outputs from Activity 7 in Logic Model, page 13) would also be useful performance indicators. Resources expended in servicing ATI requests, not only by the ATIP offices, but also by the OPIs involved in assembling the requested data, would also be key workload data.
At the client satisfaction level the model suggests such measures of service quality as timeliness (from the client=s perspective), helpfulness of ATIP office/staff, apprising client=s of their rights, etc. At the third party satisfaction level.
The model suggest such measures of service quality as adequate explanations of the response and assistance in understanding the legislation and its application.
At the impact level, the model suggests three key performance measures: (1) the timeliness of response to requests the release of requested information; (2) the degree to which information has been appropriately released or protected; and, (3) the extent that fees are appropriately collected or waived.
Some of the timeliness indicators would include: (a) exactly how much time to process a request - both lapse and task time - in total and step-by-step; (b) how many requests took longer than 30 days to complete, how much longer and why; (c) how many extensions were not completed on time and why; and, (d) the main reasons for delays and what can be done to reduce/eliminate them.
Some of the appropriate application of exemptions indicators would include: (a) the number and significance of cases where the OIC/Federal Court supported exemptions and cases where the OIC/Federal Court refused exemptions; (b) the number and significance of cases where information was released erroneously; and, (c) the number of successful challenges by third parties.
Some fee application indicators would include: (a) fees recovered; (b) the number of hours spent on search and preparation, and the number of pages reproduced; and (c) the amount of fees waived or not collected and appropriateness of and the reasons.
2.6.1 Other Assumptions and Implications Underlying the Model
As noted earlier, the performance model described above suggests a framework
for managing the program and its performance. The management of a program
based on such a performance model implies: a) management commitment; b)
an adequate level of resourcing; c) an appropriate level of skills/experience
in the assigned staff; d) a certain level of monitoring and feedback;
and, e) regular reporting on key result outcomes consistent with TBS's
latest guidelines on results-based management and accountability frameworks
(e.g., Results for Canadians). In addition, the performance model would
be expected to provide useful management information for improving efficiency
and effectiveness of the program itself.
Performance Model for Access to Information
