Report 22 - Access to Information Review Task Force

SURVEY OF ACCESS TO INFORMATION UNITS
IN GOVERNMENT INSTITUTIONS

ANNEX 4

ATI contacts are present in all regional offices to act as a point of contact for agency staff. They are there to act as a liaison between the ATI office and the OPI and to answer ATI related questions.

Training or information sessions are conducted once a month at the head office. In the regions, training or information sessions are conducted every 2 years with 2 or 3 sessions in each province.

ATI awareness sessions are mandatory for all EX level staff members.

The mechanisms in place to raise awareness are Access to Information policy manual, components in training sessions for new and other employees, issue-related policy memoranda/bulletins, and information sessions directed to senior management.

The frequency employee/senior management involvement is dependent upon enrolment of employees in specific courses. Briefings to senior management are usually issue-driven and discussed in small groups. The ATI division also makes presentations to various groups of senior management and middle managers (at regional management meetings, policy and operations committee of the department, departmental management committee).

In recent years little has been done in the area of training and information sessions because of the increase in the number as well as the volume associated with these requests has had a taxing effect on the available resources. Informal information sessions have been given to a few branches upon request, but no formal sessions are currently offered. This department has just hired an analyst who will be tasked with providing regular training and information sessions.

Internal reference guidelines available to all ATI Division staff. ATI compliance is also part of senior management accountability agreements.

Training is available to all ATI contacts. These individuals are situated in all operational areas and at headquarters and are responsible for the provision of records to the ATI Division.

Information sessions are available to any area on ATI Act matters such as the recent enactment of Section 67.1. All employees were notified of the enactment of 67.1 In addition, mechanisms were set in place to provide for the investigation of an alleged 67.1 violation.

The head of the institution has notified all areas that in order for ATI to strive to meet legislated time frames, all records requested by the ATI Division are to be forwarded to the ATI Division within 8 calendar days from the date of the request for records. Periodic reports are issued to track the actual time taken within the numerous areas of the institution.

Management has provided information sessions on a variety of ATI Act subject matter to various headquarters senior management complements.

Training is also available to headquarters staff in the review of manuals for inclusion in the Public Reading Rooms as required under the ATI Act. In addition, senior management has established a control framework to ensure that all manuals are included in the Public Reading Rooms.

The office is currently creating an ATI Policy, Consultations, and Training Unit to better serve the institution’s needs.

The ATI Unit has developed and now provides monthly information and awareness sessions in both official languages to meet the needs and answer the questions of all departmental employees. This enhances the understanding and acceptance of the Act, which in turn permits the ATI Unit to better fulfill its mandate towards the Canadian public in general and requesters in particular. Information and awareness sessions are also provided on demand when requested by the branches. The ATI Unit is also working towards the implementation of ATI related duties in all of the department’s job descriptions and that all new employees be given a mandatory ATI awareness session.

This institution has put into effect several mechanisms to inform and encourage employees to adhere to the terms of the Act. One to three hour awareness or information sessions are held on a regular basis. A schedule of these awareness/information sessions is sent out once per year, although sessions are available on demand. Regional ATI contacts take part in a two to three day training session. They also have an ATI intranet site where employees can search for information on the Act.

A “how to” manual on the department’s intranet site to explain the Act generally and to assist officials in reviewing records. Sporadic ATI information sessions, usually at the request of a directorate. Advice is given in the course of processing individual requests.

The department conducts awareness sessions and on-site training to all employees. Training has been given to over 1,000 employees. An ATI briefing is offered to new employees at the department’s Orientation Sessions.

Regular training sessions are available and employees are encouraged to take part however participation is not mandatory. Executive committees, Assistant Deputy Ministers and Head of Branches participate in six half hour to three hour information sessions per year. New employees are encouraged to participate in orientation sessions where a one page ATI fact sheet is handed out.

A guide is available on ATI policies and memorandums that have been issued on both privacy and access procedures. Training sessions have been provided to the field and one training session to senior management, however, on the day of training none of them attended; instead they sent their administrative assistant.

New employees are given tours of ATI division as well as information sessions. Departmental training, awareness sessions are given to departmental employees as required. Advice is provided routinely to staff concerning Access issues. Each year the ATI division ensures that training sessions are targeted for various sectors and this is noted on the ATI divisional yearly work plan.

ATI officers regularly give advice on the application of the legislation to employees who must review documents requested by applicants. Information sessions are also given as needed. These sessions emphasize to aspect of the Acts that are directly related to the employees area of responsibility. In addition, a 35-page User’s Guide on the Application of the Access to Information Act has been developed by the ATI Office and is available to all employees in hard copy and on the Internet.

This institution has recently instituted a new training and awareness program to inform and encourage their employees to adhere to the terms and spirit of the Act. A special section within the ATI unit has been tasked with developing and offering training within the institution. They now offer 3 training and awareness products. The first is a day and a half introductory course that is offered to all employees on a quarterly basis, the second is a one hour overview session that is offered to senior managers, and the third product is a three hour briefing that is open to all employees. All products are department specific, meaning that the examples and exercises are based on the activities and experiences of this institution.

Although participation in these training and awareness sessions is not yet mandatory, once a year (in March), the Assistant Deputy Minister responsible for ATI sends out, a memorandum advising of the training and awareness sessions to be offered in the upcoming fiscal year. This memorandum is followed up approximately six months later with a report to all senior managers of the training that has been and is to be offered and to whom.

This institution has posted its policies and procedures on its web page. The Departmental Administrative Orders and Directives policy and the policies on how to deal with formal and informal requests is available on this institution’s web page.

The OPIs do not propose the application of exemptions to requested information, but are involved after the fact during the approval stage.

The ATI Division asks OPIs to propose the application of exemptions to requested information, but the practice is that OPIs flag issues of sensitivity with post-it notes or provide a covering memo with issues highlighted for the ATI division to review. The quality of recommendations made by OPIs are variable, depending upon the level of OPI staff member reviewing the text (if the level is relatively low, some sensitive issues are missed, while others are incorrectly flagged; if the level is high, there is a risk of flagging too many issues as being sensitive, or mistaking issues on which public consultations have been held as being issues in the public domain).

OPIs are not asked to propose the application of exemptions.

Our institution does not ask the OPIs to propose the application of exemptions. The ATI Division asks OPI areas to indicate the sensitivity of records provided and to provide a rational as to why in their opinion the information should be exempt. Areas are also requested to identify if a briefing has been prepared or is required to senior management.

Offices of primary interest are not asked to propose the application of exemptions.
Offices of primary interest are not asked to propose the application of exemptions although they are asked to identify hot issues and/or all other information needed to process the request.

Offices of primary interest are asked to do follow-up reviews after the ATI Unit’s initial review. Generally, OPIs are asked to apply discretionary exemptions. Generally their application of exemptions is reasonable, but sometimes needs to be corrected by the ATI Unit.

Offices of primary interest are not asked to propose the application of exemptions, however they are requested to alert the ATI Division of any issues or sensitivities with regards to the records supplied.

Offices of primary interest are asked to propose exemptions along with an explanation of why they believe the exemption(s) applies. The accuracy of their recommendations have been getting much better with training however there is a variance between the different branches. It is estimated that less then 5% are totally wrong with the exemptions that they recommend.

Offices of primary interest are not asked to propose exemptions.

The procedure at this institution is that the ATI analysts propose the application of exemptions to requested information. We do provide OPIs with the opportunity to either concur with our recommended exemptions or to recommend others. In most cases, the OPIs accept our recommendations for disclosure or non/disclosure of information.

ATI advisors usually include their preliminary assessment concerning the disclosure of the records when they consult OPIs. OPIs indicate whether they agree with the assessment and provide their recommendations. They are often correct.

This institution does ask their OPIs to propose the application of exemptions to requested information. The accuracy of their recommendations has been on the rise as the training and awareness has increased. It is estimated that they are correct in their assessments approximately three quarters of the time.

Senior Management is very involved in ATI issues and requests. Sign off for every request occurs at the appropriate ADM level for all requests and with the deputy head for sensitive requests.

Level of Senior Management involvement: generally, Senior Management involvement is moderate, and is issue-driven.

Senior management is moderately involved. They only become involved when sensitive issues are identified. When sensitive files are identified, a briefing along with a copy of the proposed release is provided.

Senior management is very involved in ATI issues and requests.

Senior Management is moderately involved in ATI issues and requests. They are not involved in the review process but are kept in the loop.

Senior Management is very involved. The DM is briefed on all files.

Moderate involvement.

Senior Management is very involved with ATI issues and requests.

Moderate to little involvement on the part of senior management. Involvement is issue based and level of involvement depends on which branch is involved.

Senior management is moderately involved in ATI issue and files.

Senior Management’s involvement is moderate since the ATI requests are usually for historical records and the more routine personnel records.

Senior Management is very involved in ATI requests and issues.

Senior management is very involved in ATI issues and requests. An example of this involvement in ATI issues is that the Deputy Minister writes to the Information Commissioner once a year to inform the Commissioner of any new developments and to inform him of the state of the administration of the Act within this institution.

The ATI coordinator meets with the ADM-level official responsible for Public Affairs once a week to discuss ongoing ATI files and issues. Mandatory ATI briefings of senior management takes place once a week.

ATI issues are not normally raised at the senior management committee. Issues are handled as they arise by the appropriate managers. Issues only infrequently require senior management committee involvement. Some issues require ADM level involvement, but are not usually universal enough in nature to require the attention of the entire management committee. The ATI Coordinator meets with appropriate Directors General and Assistant Deputy Ministers if necessary to respond to specific issues. While such participation is not pre-planned, the ATI Coordinator will meet with at least two DGs (other than her own) in any given month, and usually will have occasion to meet with her ADM at least once monthly. The ATI Coordinator also has met Regional DGs at various presentations, where issues of common interest are discussed.

ATI issues are only occasionally brought to the attention of the Senior Management Committee by the Corporate Secretary who is briefed by the ATI Coordinator.

The ATI Coordinator and/or the staff participate regularly in meetings with senior management regarding ATI questions and/or issues.

The ATI Coordinator and/or Deputy Coordinator meet on a weekly basis with representatives of the Minister’s, the Deputy Minister’s and the ADM’s offices to discuss sensitive ATI issues and files. Representatives of the ATI Unit are also present on several internal committees such as the monthly Government on Line committee, and the Coordinator sits on the Senior Management meetings.

A senior analyst is involved in the weekly Senior Management Committee to discuss ATI issues.

The ATI request status report is reviewed at weekly Executive Committee meetings. The ATI Coordinator does not attend. Coordinator/ATI staff meets with senior management as needed.

A list of requests is sent to the Deputy Minister’s office every week. That office then determines which requests they would like a briefing prior to release.

Issues are only brought to their attention when they are sensitive or a major decision has to be taken. Consultation with ATI occurs on a regular basis.

ATI issues are brought to the attention of senior management committees at quarterly meetings or if there is an issue that needs more attention than average. ATI staff conduct weekly meetings with communications staff, staff from the DM’s office and from the Minister’s office. Quarterly performance reports are provided to senior management.

The ATI Coordinator sits as a member on the Branch management committee. This committee meets once every two weeks and an update of the work of the ATI division is provided. If other ATI issues are pressing, the Coordinator advises the DG of Branch accordingly.

ATI issues are not brought to the attention of the Senior Management Committee on a regular basis. They are however discussed with the Assistant Deputy Minister of Corporate Services as required. Officials from the Minister’s Office and the Deputy Minister’s Office view the release package for sensitive requests. In addition, ATI issues are brought to the attention of senior management via a weekly report of active requests and quarterly statistical reports.

ATI issues are brought to the attention of senior management at a weekly meeting involving the ADM responsible for ATI, the ATI Coordinator, representatives of the Deputy Minister’s office, Parliamentary Affairs office and the Minister’s office. The ATI Director also has a one on one session with the ADM responsible for ATI once a week to discuss ATI issues. The ADM in turn formally or informally discusses ATI issues with members of the Senior Management Committee.

All requests are brought to the attention of senior management. Senior management is briefed once per week as well, the ATI Coordinator meets with his ADM-level once a week to discuss ATI requests and issues.

External communications or media relations: the release or issue holds a potential requirement for media lines, media calls, questions in the House of Commons, media scrums, (requirement for appropriate briefing notes, house cards). Internal departmental communications: Issue of substance requiring change of procedures and/or departmental direction to employees.

The criteria used to determine whether or not a request or ATI issue is brought to the attention of the Senior Management are the sensitivity of the issue and records proposed for release, matters of principle, and legal issues.

When forwarding records in response to an ATI request, OPI areas are asked to indicate if a briefing is required. In addition, Parliamentary Affairs also determines if a briefing may be required based on the summary line of a request. Requests from political parties, the media and unions for example, are criteria that indicate a need for a possible briefing to senior management. In addition, the specific issue relative to the requests in terms of the institution's business or ongoing recent developments can also be used to identify the need for briefings.

The criteria used to determine whether or not a request or ATI issue is brought to the attention of the Senior Management are the sensitivity of the issue and records, the category of requester making the request.

The DM is briefed on all ATI files that are received in this department.

All requests are brought to their attention. DGs and ADMs sign off on requests, and the Deputy approves exemptions. As noted previously, the requests status list is reviewed weekly by the Executive Committee.
A list of requests is sent to the Deputy Minister’s office every week. That office then determines which requests they would like to be briefed on prior to release.

It must be a highly sensitive request. This happens rarely as the Communications and Parliamentary Relations divisions are implicated in the early stage of the process.

ATI requests are brought to the attention of senior management on a case by case basis depending on the issue at hand.

There are no specific criteria for bringing ATI issues to the attention of the Senior Management Committee. Issues would however be brought to the attention of the Senior Management Committee should they impact on the overall operations of the institution, require a coordinated approach, require communications involvement and set a precedent or which may impede the ability of this institution to carry out its objectives.

The subject matter and the source of the request are considered when deciding whether or not to bring a request to the attention of senior management.

OPIs normally identify and exercise their judgement with regards to what ATI issues are to be brought to the attention of the Senior Management Committee. In most cases the decision to bring an ATI issue to the attention of the Senior Management Committee is issue driven.

The ATI coordinator meets with the ADM-level official responsible for Public Affairs once a week to discuss ongoing ATI files and issues. Mandatory ATI briefings of senior management takes place once a week.

Monthly statistical reports to Director General, Executive Services. New sensitive requests (stripped of personal information) are reported to the Minister's Office every two weeks.

Heads up process (for information, not approval) for sensitive releases to DM and Minister’s Office. This process involves sending a memorandum to the Minister’s Office via senior management containing a copy of the release package and applicable media lines.

The Corporate Secretary, communications, parliamentary relations and the Minister’s office are all cc’d on all retrieval memorandums in order that they be aware of what requests are being received and processed by the institution. The ATI Coordinator receives a weekly status report for all ongoing requests and those in the approval stage. There is no formal reporting mechanism in place to advise senior management of decisions on proposed releases, however the ATI Coordinator keeps senior management informed of the status of requests that are of particular interest to them.

Once the file has been completed by ATI, a briefing is prepared when required and sent to senior management. The briefing indicates the date on which the request is to be released. Part of the briefing package includes a case summary of the request. Given the sensitivity of the request there may be a need to prepare Qs/As by the communications area for use by senior management.

Weekly reports outlining new requests received, requests awaiting approval, and response deadlines are sent to the Minister’s office, the Deputy Minister’s office, the ADMs’ offices, Communications Branch, the Corporate Secretary, and the Manager of Parliamentary Relations.

The DM is briefed on all ATI files that are received in this department.

Requests are reviewed by the DG, ADM (or senior ADM), and approved by the Deputy. The ATI coordinator reports to the Director, who reports to the Director General who reports to the DM.

We have no reporting mechanisms. The Director (ATI) responsible as per the delegated authority to sign-off requests. The Communications and Parliamentary relations divisions are however provided with an un-vetted copy of the records upon receipt from the OPI and for sensitive requests they are also provided with a vetted copy simultaneously as the records goes in for final signature and approval by the Director.

Senior managers are provided with regular status reports of active requests, overdue requests and quarterly performance reports. The ATI staff meets regularly with staff from communications, the Deputy Minister’s office and the Minister’s office.

This institution uses a Performance Measurement Information System that each departmental employee is required to use. Each employee provides a monthly update on work completed with statistics. The institution also prepares quarterly updates to the yearly business plan that is linked to the strategic priorities and objectives of the department.

A list of all active requests is provided to senior management on a weekly basis. The list shows the last action taken on files and all outstanding actions. Quarterly statistical reports are also provided.

Senior management receives, on a weekly basis, a status report of active requests. They also receive a performance report that looks at whether or not the different branches within the institutions are respecting the deadlines for the retrieval process.

The ATI office also has its own internal reporting mechanisms that are aided by the ATIP Flow database.

• Request received in ATI office.
• A memo is sent to the appropriate offices of primary interest requesting that they retrieve the relevant records and that a response is requested within 8 days.
• Once all records are received, the ATI office has 6 days to process the request if no extensions for volume or consultations are necessary.
• Once the ATI office has processed the request, two days are set aside for the preparation of media lines.
• Two days are set aside for sign off at the ADM level.
• When the proposed response has received sign off at the ADM level, it is forwarded to the Deputy head for approval and signature.
• At the time when the request is forwarded to the ADM level for sign off the proposed response is also sent to the Minister’s office as a heads up.

• Indexing – in ATIPFlow
• Record Retrieval
• Record Review
• Consultations
• Sign-Off

• Retrieval of records – program staff are sent a memo requesting that all relevant information be retrieved, photocopied and sent with recommendations to the ATI unit within seven (7) days of the date on the memo. Should the program staff feel that the retrieval of records will take more than 5 hours, they are asked to estimate the amount of time necessary to retrieve the relevant records and forward that estimate to the ATI unit.
• Processing of request by ATI analysts – once records are received from program staff, the ATI analyst proceed with the processing of the request.  Where extensions are necessary for volume, consultations with foreign, or  consultations with third parties, the ATI analyst sends out notices to the requester that such extensions are necessary to complete the request.  When necessary, consultations are processed according to section 27, 28 and 44 of the ATI Act.
• Approval of response by ATI Coordinator and Senior Management – when the initial review is complete, the ATI coordinator is asked to approve the proposed release package. Should the coordinator feel that the response in hand should be seen by senior management, then it is passed along for their approval.
• Preparation of the response to requester – when review and approval process is complete and depending on the number of pages and exemptions, either the ATI analyst or clerical staff will apply tape to exempted information and make copies of the records. Should preparation or photocopy fees apply, the requester is advised of the costs. If fees do not apply, the ATI coordinator signs the letter of response and the release package is forwarded to the requester.

• Request is received and acknowledged by letter. If request is not complete, missing information is requested.
• Request for records from applicable OPI area(s) is sent. Records are gathered and sent to ATI. The OPI area(s) indicates recommendations regarding exemptions and the need for a briefing. Records are to be sent within 8 calendar days.
• If OPI area is in a search scenario, the ATI Division is contacted to confirm search factors. A fee letter would then be prepared and forwarded to the requester.
• If search aspects do not apply, the file is subsequently sent for processing upon receipt of the records. Extension aspects are considered when the file is assigned to processing based on Treasury Board guidelines and in-house data on average file size.
• Fees for reproduction are also determined either as an estimate prior to actual processing or upon conclusion of the actual processing of the request.
• Once file is approved, records are sent to the requester.
• ATI will also return to the OPI area(s), a package which contains the specific exemptions that were applied to the records involved for reference purposes.

• After a request is received in the ATI Unit a call out is sent to the responsible OPIs who are given seven (7) days to retrieve relevant records.  Should it be deemed that the issue at hand is a sensitive one, a heads up is sent out. When relevant records are provided by the OPI, the ATI staff begin the review process which may require consultations with third parties and other governments. Once the review process is complete, the response is prepared and approval is sought. Should the request be deemed as sensitive, the proposed response is reviewed by communication, an issue sheet is sent out to interested parties, ATI release advisories are sent out and finally the records are released to the requester.

• Retrieval of records - program staff are sent a memo via e-mail requesting that all relevant records be retrieved, photocopied and sent with any recommendations on disclosure, exemptions, and to identify sensitive issues. Program staff are given eight (8) days to retrieve records.
• Program staff advise if fees are applicable, requests extensions due to volume, refer requests to regions (when necessary) or provide nil responses.
• Once received in Corporate ATI, the documents are reviewed, consultations processed (if necessary), exemptions applied, package paginated and prepared for release.
• It should be noted that from the 4th day of the process, program staffs along with communications staffs are tasked with the preparation of briefing and communications material so that they may be ready once a file is ready for release. At this point in time, briefing and communication material is prepared for all files including nil record responses.
• Once reviewed in Corporate ATI, the proposed release package is sent to the program areas for review of the proposed release package and sign off and is then returned to Corporate ATI.
• Various approvals are given and the records are released to the requester.

• Request received, ATI Unit determines which areas of the Department may be in possession of files/records relevant to the request. In most cases, the ATI Unit sends a request for the relevant documents to the records offices, one or more of the directorates, and Executive Services.
• When the ATI Unit receives records, a review file is created, comprising all relevant documents. The file is reviewed by the ATI Unit for exemptions and exclusions, and the ATI Unit also makes recommendations for consultations outside the Department.
• The file is sent to the directorate for an in-depth review. The directorate recommends additional exemptions and exclusions, if any, as well as other required consultations, and provides comments on the review undertaken by the ATI Unit. The file is returned to the ATI Unit.
• The ATI Unit then consults, as needed, with other organizations. When the ATI Unit receives replies to the consultations, the file is returned to the directorate for a follow-up review. This follow-up review provides the directorate the opportunity to review the recommendations from other organizations. Where the directorate agrees with the recommendations, the file is routed by the directorate to the ADM for review, and then returned to the ATI Unit.
• The ATI Unit prepares the file for the DM's approval of exemptions; at the same time, a copy of the proposed disclosure package is sent to the Minister's office.
• Following approval of the exemptions, the ATI Unit sends the records, with any exempt and excluded information deleted, to the applicant.

• The request is received and entered into the ATIPFLOW database.
• Six (6) days are allocated to the retrieval of the records by the appropriate branch(s) and to send them to the ATI office. Time allocated to these step may be increased if a legal extension is allowed by the legislation.
• A total of 8 days is allocated to the review of records by the ATI office. Time allocated to these steps may be increased if a legal extension is allowed by the legislation.
• Review by the Communications Group (as required). Eight (8) days allocated for this task.
• Two days allocated for the approval stage by the delegated authority.
• Preparation of response package for the requester and review of sensitive files (as required). 2 days allocated for this task.

• ATI administrative tasks for retrieval – 1 day
• Retrieval memo sent to branches involved and branches have 10 working days to provide response.
• ATI Review process – 4 to 10 days
• Routing – ATI Coordinator – 1 day
      >   Communications – 2 days
      >   ADM responsible for ATI – 1 day
      >   Associate DM – 1 day
      >   ATI response – 1 day

• In comparison with other department our process is similar with the exception that our requests do not incur any delays in the Minister’s Office or with Senior Management, in comparison with other departments.

• Analysis of request – Upon receipt of the request, the ATI office makes sure that it complies with the legislation and regulatory requirements, ie) the requester has a right of access to the records, has enclosed the application fee, etc. The request is also analyzed to ascertain its subject of  interest and scope. This often calls for contact with the requester and with departmental employees in the office of primary interest (OPI) who have the best knowledge of the subject matter.
• Request for Material-Gathering – Once the scope and subject of the request is clear, the ATI office forwards a memorandum and the ATI request checklist to request material from the appropriate OPI(s), asking for all records on the subject, regardless of their number, content or form (hard copy and electronic format). The identity of an individual requester is considered to be personal information and the names will be removed from all copies of the request that are sent outside the ATI office.
• If there is any question about the scope or relevance of records, the OPI consults the ATI office immediately. The ATI office will make the final determination on the relevance of records in consultation with the OPI and the requester.
• Receipt of Documents – Once the ATI office has received the records that have been gathered from all sources, copies are made and the originals are returned.
• Review of Records and Consultations – A full review of the relevant records begins at this stage. The ATI office examines each record to determine if it can be released or whether it should be exempted or excluded.  Consultations are sent to the departments that have an interest in the records and to the OPI to obtain their comments and recommendations on the disclosure of the records. The OPI must provide a written rationale concerning the records which in their view should not be released.
• The ATI office reviews the recommendation received from the OPI and, in case of disagreement, discusses them with the OPI. The OPI’s advice will be taken into consideration in determining whether circumstances require the protection of information that falls within a discretionary exemption. The final decision rests with the ATI Director, with the exception of the disclosure of records containing information subject to solicitor-client privilege. Only the client may waive the privilege.
• Approval – Following the review and consultation process, the ATI officer makes a final recommendation on the disposition of the request to the ATI  Director. The ATI Director then reviews the recommendations and decides, on behalf of the Minister, what records can be released in whole or in part in response to the request. The requester will then be informed in writing of the Department’s decision and will be provided with a copy of the releasable records. The requester will also be advised of the right of complaint about the response to the Information Commissioner.

• Retrieval of Records – program staff are sent a memo requesting that all relevant records be retrieved, photocopied and sent with recommendation to the ATI unit within seven (7) to ten (10) days.
• Review Stage – This involves the review of OPI’s proposed exemptions and recommendations, to conduct all necessary consultations etc…
• Approval Stage – Two steps are involved in the approval of requests. The first entails the review of proposed disclosures pursuant to the ATI Act by a dedicated ATI Communications Officer who identifies those issues contained in, or likely to arise from, the disclosure of subject records. This communications officer is an ATI branch employee and works solely on ATI issues. This same individual is responsible for the research and creation of appropriate communications products in the format accepted by those who will be using them.
• The second step entails review of the records intended for disclosure by a second individual dedicated to the identification of issues having political sensitivities attached to them. Once the individual responsible for this process feels confident that there are no issues of concern, or that the prepared communication product reflect the contents of the file being released it is signed by that individual and returned to the ATI Coordinator for release to the applicant. Concurrently, the individual responsible for the latter review is responsible for briefing the Minister’s staff. Issues of concern are discussed at that stage, as is the need for any additional communications products that may be needed such as QP cards.
  

The approval of release packages occurs at the ADM level for non-sensitive requests and at the Deputy head level for sensitive requests.

Non-Sensitive requests: ATI staff within the ATI Division approves all such release packages (infrequent program input). Legal input not sought.

Sensitive requests: ATI staff approves all such release packages with considerable input regarding exemptions from programs and where appropriate (e.g., involving sensitive material regarding current/former employees), from senior management. Legal Services is infrequently involved.

For non-sensitive request the actors involved in the approval are the ATI analysts who briefs the ATI Coordinator who ultimately approves the proposed response. In these cases the ATI Coordinator reviews the proposed exemptions and concerns brought forth by the analysts and makes the ultimate decision on whether to sign the proposed letter of response.

For sensitive requests the actors involved in the approval process are the ATI analysts who brief the ATI Coordinator. In these cases the ATI Coordinator reviews the proposed exemptions and concerns brought forth by the analysts and brings these and any other concerns to the attention of the Corporate Secretary. Following deliberations and approval of senior management the ATI Coordinator signs the letter of response.

The approval process for any file entails a review by the ATI manager. The ATI manager will approve the file except where exemptions are being applied which are not delegated to the manager as per the instrument of delegation. In these instances, the ATI Coordinator who has full signing delegation will approve the file.

For non-sensitive requests the actors involved in the approval are the ATI Head Advisor, the Deputy Coordinator and finally the Coordinator (if required).

For sensitive requests the actors involved in the approval process are the ATI Head Advisor, the Deputy Coordinator, and the Coordinator who consult closely with the ADMs, the Communications' Director and the DM (as required) in order to accommodate any concerns they may have on a given issue.

This "approval process" will however not prevent the ATI Unit from releasing the information by the legislated due date.

No distinction is made between sensitive and non-sensitive files. All files are approved at the ADM and DM levels.

The DG of the OPI approves the proposal for exemptions/disclosure of information following review by ATI and the OPI, and receipt of recommendations further to external consultations. Depending on the directorate involved, the file is then signed by the senior ADM or the ADM. It is then routed to the DM for final approval, by way of the Director, Coordination and Liaison, and the Director General, Strategic Operations.

The Coordinator reviews the recommendations of the ATI Advisors for all requests (sensitive and non-sensitive). The RDGs review and the ADMs approve the recommendations.

The ATI Coordinator, the Communications branch, the ADM and the Senior Associate Deputy Minister approve all ATI requests.

All requests are signed off by the ATI Director with the exception of releases of personal information under section 8(2)(m), for which approval is obtained through the responsible ADM.

Analyst - initial review
Team leader - second review
Director - final approval and signature

Non-sensitive documents are sent to the ATI Director for approval and signature. Sensitive documents are sent to the Executive Assistants, Deputy Minister’s office and Minister’s office, for review; they are then forwarded to the ATI Director for final approval and signature.

The principal actors involved in the approval process are the team leaders and the Deputy ATI Coordinator.

A total of 2 days are spent on non-sensitive requests and 4 days on sensitive requests.

Non-Sensitive Request Approval: One or two days (sometimes longer depending upon bottlenecks) Sensitive Request Approval: One or two days (Sometimes longer depending upon bottlenecks) N.B.: Delegation of Authority was amended in 2000 to give the ATI office Senior Officers the authority to apply exemptions for all non-discretionary exemptions and for some of the discretionary exemptions.

Non-sensitive: different with every request depending on the volume, number of exemptions applied etc… Sensitive: different with every request depending on the volume, number of exemptions, complexity of the issue at hand.

Approximately 70% of a manager's time is spent in the review of the file once processed by a consultant. No information is available as to the ATI Director's time.

A total of 10 minutes can be spent on non-sensitive requests and one hour for sensitive ones.

No distinction is made between sensitive and non-sensitive files during the approval process. Program staff are given 4 days to approve and then the records are sent for review for impact analysis which on average takes 34 days.

A total of 2 days can be spent on both non-sensitive and sensitive requests.

There is no difference made between sensitive and non-sensitive requests, all take 5 days for approval.

Actually very little, as this is always determined in the initial stage and our Communications and Parliamentary relations division must prepare accordingly and thus, avoiding unnecessary delays. Again this is only for sensitive requests.

Non-sensitive documents: 1 working day.
Sensitive documents: average of 13.6 days working days.

No distinction is made between sensitive and non-sensitive requests at the approval stage. At most the approval process can take up to five (5) days. At the ATI level, approval typically takes one day.

ATIP FLOW, a specialized computer database is used to track and aid in the processing of requests. This department also uses a specialized photocopier that exempts all items highlighted with a red marker or highlighter.

ATIP Flow: all ATI request file tracking and monitoring is done through this system. Statistics generated are used to make informed decisions.

ATIP FLOW, a specialized computer database is used to track and aid in the processing of requests.

ATIP IMAGE, a specialized computer database that allows records to be scanned as images and for exemptions to be applied electronically. This department started its use of this tool only a few months ago. Not all files are treated using this tool at this time.

The management and processing of requests is assisted by the knowledge base of individuals involved in the processing of requests within the ATI Division. On the job coaching and training, team meetings and management meetings are also useful tools. Progress reports on inventory and completed files, weekly reports to senior management, use of legal services as needed, use of Treasury Board Secretariat, results of complaints.

Other tools available include standard texts and the availability of working documents in electronic format.
While it is difficult to assess the contribution of each of the above, ATI staff involved in the processing of requests can determine the inventory status of their files, files that have been closed and a determination as to the achievement of the legislative time period involved. The day to day coaching and exchanges between consultants and managers serves to enhance the completion of ATI requests. As of this year, total compliance with timelines has increased 500%.

ATIP FLOW, a specialized computer database is used to track and aid in the processing of requests.

ATIP Liaison, a specialized computer database that is very much like ATIP FLOW but that is used by all the liaison officers in the regions and sectors.

ATIP Consult, an intranet application that acts as a search engine to be used by department staff to see at what stage requests are at.

E-print, allows for reports to be sent via email.

ATIP FLOW software, request status list (updated weekly), the Acts and guidelines, advice from counsel, recommendations derived from external consultations and from OPIs. On a day-to-day basis, probably the chief tools/resources are ATIPFLOW and the OPIs. The Treasury Board guidelines are not very helpful.

ATIP FLOW, a specialized computer database is used to track and aid in the processing of requests. Other resources used are the INFOSOURCE, Acts and Regulations, OPIs, Liaison officers.

We have a Guide available; policies and memorandums that have been issued on privacy and access procedures. The availability of proper tools certainly play a major role as it contributes to facilitate the work of the Analysts, Clerk, regional staff, etc, and it also enhances the knowledge of ATI issues within the department. Resources within ATI shops must be properly assess by each department and staff appropriately in order to meet legislative deadlines and provide a reasonable service to requestors.

ATIP FLOW, a specialized computer database is used to track and aid in the processing of requests.

ATIP IMAGE, a specialized computer database that allows records to be scanned as images and for exemptions to be applied electronically.

ATIP Flow is used to track all requests processed by the ATI Office. The system is user-friendly, provides an overall view of the workload of each ATI Officer as well as visual reminders of approaching deadlines. It also provides good search and reporting capability.

Other tools used include personal computers, telephone, facsimile machine and electronic mail.

ATIP Flow, a specialized database is used to help manage and track ATI requests.

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