2021-2022 Annual Report to Parliament: Privacy Act

Table of contents

Introduction

I. Introduction

The purpose of the Privacy Act (PA) is to protect the personal information of individuals under the responsibility and control of federal institutions, and to provide individuals with a right of access to that information.

This report reflects activities of Indigenous Services Canada (ISC), in respect to the stated legislation, for the period of April 1, 2021 to March 31, 2022.

This report, submitted to Parliament pursuant to section 72 of the PA, describes the activities of ISC that support compliance with privacy legislation. The report details the activities and accomplishments of ISC's Access to Information and Privacy (ATIP) Directorate, including highlights such as:

  • Limiting the break in service during Covid-19;
  • Continued training initiatives to increase departmental Privacy capacity and awareness; and
  • Further development of a Privacy/Policy function.

Creation and Growth of the New Departments

In June 2019, the Department of Crown-Indigenous Relations and Northern Affairs Act and the Department of Indigenous Services Act received royal ascent. The ATIP Directorate provides shared services to support ISC and Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) through a Memorandum of Understanding (MOU) between the Departments.

Delegation on ministerial responsibilities for the PA remains institutionally specific.

Indigenous Services Canada's Mandate

The primary mandate of ISC is improving the quality of services delivered to First Nations, Inuit, and Métis Peoples. The Department will work to close socio-economic gaps and ultimately ensure that Indigenous Peoples have control and responsibility over their services and programs. The Department of ISC will focus, in partnership with Indigenous peoples, on the following five interconnected priority areas: health, education, children and families, infrastructure, and a new fiscal relationship.

ISC works collaboratively with partners to improve access to high quality services for First Nations, Inuit and Métis Peoples.

Our vision is to support and empower Indigenous peoples to independently deliver services and address the socio-economic conditions in their communities.

ISC has been given the responsibility to identify the best models for delivering improved services to Indigenous Peoples and improve accountability to Indigenous Peoples for the quality of services delivered by the Department.

As Canada moves towards greater Indigenous self-government, ISC will oversee the provision of existing services to Indigenous Peoples, and particularly First Nations under the Indian Act, including the provision of community infrastructure, emergency management, water, education, moneys and trusts, and registration.

The Department works in collaboration with its partners to create systemic change in how the federal government delivers health services to Indigenous Peoples.

II. Organization

Access to Information Directorate at Indigenous Services Canada

The Access to Information and Privacy Directorate is responsible for the administration of requests made under the Access to Information Act (ATIA) and the PA It was established within the Corporate Secretariat and reports to the Corporate Secretary, who is directly accountable to the Deputy Head and is a member of the ISC Senior Management Team (SMT). The Directorate also coordinates and implements policies, guidelines and procedures to ensure departmental compliance with the ATIA and PA.

Workshop presentations, training courses and awareness sessions designed to increase access to information and privacy capacity across the Department are provided by the ATIP Directorate.

Under a shared service agreement, ATIP analysts processed requests for both ISC and CIRNAC. Requests varied volume and complexity based on their classification level.

The privacy specialists provided critical advice for new initiatives and information sharing activities, resulting in privacy protection in departmental programs.

Policies and procedures continue to be established, under an evolving multi-jurisdictional reality, to ensure that privacy is considered throughout the life cycle of ISC's programs and that informed policy decisions are made concerning the collection, sharing and/or use of personal information.

The ATIP Directorate provides advice and guidance to the Department on a number of topics:

  1. The application of the ATIA and PA;
  2. The release of sensitive or protected information to the public;
  3. Education and awareness of access to information and privacy issues throughout the Department;
  4. Proactive publications;
  5. Departmental Privacy Impact Assessments (PIAs);
  6. Permissible disclosures of personal information pursuant to subsection 8(2) of the PA;
  7. Appropriate PA Statements on Data Collection Instruments, i.e. forms, surveys, recorded events, etc.;
  8. Updates to Info Source and the preparation and registration of Personal Information Banks and their related Classes of Records;
  9. Protocols surrounding privacy breaches; and
  10. Privacy advice in Memoranda of Understanding, Information Sharing Agreements and more complicated Multi-Jurisdictional Information Sharing Agreements (MISAs).

The Intake Team triages and coordinates the receipt of requests for information under the control of the Department made pursuant to the ATIA and the PA.

The Operations Team ensures that a response is provided within the legislated timeframe (30 days). All requests are monitored using the tracking system Access Pro Case Management.

ATIP analysts work closely with the relevant program areas to ensure that all responsive documents are provided and the information contained within those documents is treated in accordance with the Acts to allow for government records to be safely disclosed to the Canadian public.

The Privacy/Policy team is available to provide expert advice, maintain and monitor privacy risks and with the creation of privacy policy training. The Privacy/Policy team also supports ISC in the development of Departmental policies that reflect the Department's unique relationship with its clients and Indigenous partners all while ensuring the Department meets its obligations under the Privacy Act.

In addition to the ATIP Directorate, each of the sectors and regional offices of ISC are ATIP Liaison Officers (ALOs) who receive callouts from the ATIP Directorate and subsequently task the requests as appropriate to areas within their sector. ALOs plays a crucial role in ensuring the appropriate records, impact statements and approvals are obtained and communicated to ATIP Directorate officials within the designated time allowances.

Director's Office

The Director (EX-01), as institutional ATIP Coordinator, holds full delegated authority under the ATIA. The Director is supported in day-to-day administrative tasks by the Deputy Director Operations (PM-06), Deputy Director Privacy/Policy (PM-06), an Administrative Assistant (AS-01) and in reporting by the Systems Administrator (AS-04).

Privacy/Policy Team

The Privacy/Policy Team is led by two Team Leaders (PM-05), who are responsible for the overview of request processing by their team, including the review of privacy/policy requests. The Privacy/Policy Team consists of Analysts at the PM-04, PM-03 and PM-02 levels who respond to Privacy Policy matters (such as privacy breaches, formal/informal and court ordered disclosure requests, Privacy Assessments), provides training and Privacy advice, supported by an intake Clerk (CR-04).

Operations Team

The Operations Team is led by three Team Leaders (PM-05), who are responsible for the overview of request processing by their team, including the review of completed requests. The Operations Team consists of Analysts at the PM-04, PM-03, and PM-02 levels who process Access and Privacy requests of varying volume and complexity, as well as provide training.

Intake Team

The Intake Team is led by one Team Lead (PM-5) and is comprised of various Intake Officers (PM-04, PM-01 and CR-04's), who enter all applications into the electronic case management system, acknowledge receipt of requests, perform imaging services, interact with and respond to inquiries from the public.

III. Delegation Order

Under section 73 of the PA, the Minister's authority may be delegated to departmental officials in order to administer the PA within ISC. The delegation order signed by Minister Marc Miller on November 6, 2020, was in effect during this reporting period (Appendix A).

Under section 73 of the PA, the order delegates full authority and responsibility for the PA to the following positions:

  • Deputy Minister
  • Associate Deputy Minister
  • Corporate Secretary
  • Departmental ATIP Director (Coordinator)
  • ATIP Deputy Directors

Statistics

IV. Interpretation of the Statistical Report

ISC's Statistical Report and Supplemental Report were submitted to the Treasury Board Secretariat (TBS) on August 2, 2022 (Appendix B). The Report details various aspects of the requests ISC received and processed during the period of April 1, 2021 to March 31, 2022.

1. Requests under the Privacy Act

In 2021-2022, ISC received 202 requests, representing an increase of approximately 12% compared to the 180 received in 2020-2021 (Table 1.1). Another 52 requests were carried over from the previous year, this reflected a total of 254 requests to be processed in course of the reporting period. The ATIP Directorate completed 203 requests and carried 51 requests into the next reporting period 2022-2023.

1.1 Number of requests received

This fiscal year there was an increase of 181% in privacy requests since the 2018-2019 reporting period.

Table 1.1a Number of requests received and outstanding from 2018 to 2022
Number of Requests 2018-2019 2019-2020 2020-2021 2021-2022
Received 72 288 180 202
Outstanding from last year 0 17 61 52
Total 72 305 241 254
Table 1.1b Number of requests closed and carried over from 2018 to 2022
Number of Requests 2018-2019 2019-2020 2020-2021 2021-2022
Closed this year 61 241 192 203
Carried over to next year 11 64 49 51
1.2 Channels of requests

The channels of requests serve to identify the mechanism used by the Canadian public to request their personal information records: Government of Canada Online Portal, e-mail, mail, phone or fax. The channels of requests are a new reporting requirement. In the course this reporting period, the majority of the informal requests were received through the Government of Canada Online Portal.

Table 1.2 Channels of requests
Source Number of Requests
Online 112
E-mail 90
Mail 0
In person 0
Phone 0
Fax 0
Total 202

2. Informal requests

No Informal requests were received pursuant to the PA in 2021-2022.

3. Requests closed during the reporting period

3.1 Disposition and completion time

Of the 203 requests closed during the reporting period, ISC was able to fully or partially disclose records in 108 cases (72% of the requests) (Table 3.1.1). The most frequent outcome of requests processed during the reporting period was a partial disclosure, in 76 cases or 33% of the time. No records existed in 59 cases or 21% of the time. (Table 3.1.2).

Table 3.1.1 Percentage of completed files relevant to each disclosures
Text alternative for Percentage of completed files relevant to each disclosures

Table 3.1.1 is a pie chart that compares the percentage of completed files relevant to each disclosure.

Files disclosed in full accounted for sixteen percent (16%) of disclosures, for a total of thirty-two (32) files. Two (2) files closed fifteen (15) days of receipt, seven (7) between sixteen (16) and thirty (30) days, eleven (11) between thirty-one (31) and sixty (60) days, four (4) between sixty-one (61) and one-hundred-twenty (120) days, two (2) between one-hundred-twenty-one (120) and one-hundred-eighty (180) days, three (3) between one-hundred-eighty-one (181) and three-hundred-sixty-five (365) days, and three (3) more than three-hundred-sixty-five days (> 365) after receipt.

Files disclosed in part accounted for thirty-seven percent (37%) of disclosures, for a total of seventy-six (76) files. Three (3) files closed fifteen (15) days of receipt, eleven (11) between sixteen (16) and thirty (30) days, twenty-four (24) between thirty-one (31) and sixty (60) days, sixteen (16) between sixty-one (61) and one-hundred-twenty (120) days, five (5) between one-hundred-twenty-one (120) and one-hundred-eighty (180) days, nine (9) between one-hundred-eighty-one (181) and three-hundred-sixty-five (365) days, and eight (8) more than three-hundred-sixty-five days (> 365) after receipt.

Two percent (2%) of files closed all exempted, for a total of three (3) files. One (1) file closed sixteen (16) and thirty (30) days after receipt, one (1) for thirty-one (31) and sixty (60) days, one (1) for and sixty-one (61) and one-hundred-twenty (120) days.

No records existed for twenty-nine percent (29%) of files, for a total of fifty-nine (59) files. Four (4) files closed with the first fifteen (15) days, twenty (20) between sixteen (16) and thirty (30) days, fourteen (14) between thirty-one (31) and sixty (60) days, ten (10) between sixty-one (61) and one-hundred-twenty (120) days, one (1) one-hundred-twenty-one (120) and one-hundred-eighty (180) days, five (5) between one-hundred-eighty-one (181) and three-hundred-sixty-five (365), and five (5) more than three-hundred-sixty-five days (> 365) after receipt.

Requests were abandoned by requesters in sixteen percent (16%) of files, for a total of thirty-three (33) files. This is twenty (20) files closed in the first fifteen (15) days. Four (4) files closed in sixteen (16) and thirty (30) days, one (1) file closed between thirty-one (31) and sixty (60) days, and one (1) between sixty-one (61) and one-hundred-twenty (120) days. Three (3) closed between one-hundred-eighty-one (181) and three-hundred-sixty-five (365), and four (4) more than three-hundred-sixty-five days (> 365) after receipt.

In course of the current reporting period, 29 requests were processed and completed within the initial 15 days of receipt and another 43 were closed within 30-days. Resulting in 35% of received requests completed within 30-days. An additional 51 files were completed between 31 and 60 days of receipt, with or without an extension recorded on the file. The remaining 80 files were finalized in 61 or more days.

Table 3.1.2 Disposition and completion time
Disposition of requests Completion Time (days)
1 to 15 16 to 30 31 to 60 61 to 120 121 to 180 181 to 365 More than 365 Total
All disclosed 2 7 11 4 2 3 3 32
Disclosed in part 3 11 24 16 5 9 8 76
All exempted 0 1 1 1 0 0 0 3
All excluded 0 0 0 0 0 0 0 0
No records exist 4 20 14 10 1 5 5 59
Request abandoned 20 4 1 1 0 3 4 33
Neither confirmed nor denied 0 0 0 0 0 0 0 0
Total 29 43 51 32 8 20 20 203
3.2 Exemptions

As seen in previous years, section 26 (personal information of another individual) was the most common exemption invoked during the reporting period (78 times). The other exemptions applied in 2021-2022 were under sections 27 (Solicitor Client Privilege), which was invoked on four (4) occasions and section 28 (Medical Records), which was applied once (Table 3.2).

Table 3.2 Number of requests closed where exemption provisions were invoked
Section Number of requests
18(2) 0
19(1)(a) 0
19(1)(b) 0
19(1)(c) 0
19(1)(d) 0
19(1)(e) 0
19(1)(f) 0
20 0
21 0
22(1)(a)(i) 0
22(1)(a)(ii) 0
22(1)(a)(iii) 0
22(1)(b) 0
22(1)(c) 0
22(2) 0
22.1 0
22.2 0
22.3 0
22.3 0
23(a) 0
23(b) 0
24(a) 0
24(b) 0
25 0
26 78
27 4
27.1 0
28 1
3.3 Exclusions

No mandatory exclusion provisions were applied to requests that were closed in fiscal year 2021-2022.

3.4 Format of information released

Over the course of this reporting period, the majority of responses (102) were provided to the requesters electronically through E-post Connect or through e-mail. On six (6) occasions, individuals who did not have access to retrieve records electronically were provided with paper copies through regular mail (Table 4.4).

Table 3.4 Format of information released
Paper Electronic Other
E-record Data set Video Audio
6 102 0 0 0
3.5 Complexity

The following sections detail several factors affecting the complexity of requests that were completed throughout 2020-2021.

3.5.1 Relevant pages processed and disclosed for paper and e-record formats by size of requests

Of the 203 requests closed, 144 requests generated 22,677 pages processed. The total amount of pages disclosed was 11,250 during the reporting period (Table 3.5.1).

Table 3.5.1 Relevant pages processed and disclosed.
Number of pages processed Number of pages disclosed Number of requests
22,677 11,250 144
3.5.2 Relevant pages processed per request disposition for paper and e-records formats by size of requests

Of the 144 requests, 117 requests (81%) required the processing of 100 pages or less. Also, a total of 8,014 pages required processing for 23 requests (16%), on files comprising between 101 and 1,000 pages to be reviewed. However, four (4) requests (3%) had more than 1,001 pages to be reviewed, for a total count of 13,161 pages to processed.

Table 3.5.2 Relevant pages processed per request disposition for paper and e-records formats by size of requests.
Disposition < 100 pages 101-500 Pages 501-1000 Pages 1001-5000 Pages More than 5000 Pages
Requests Pages Requests Pages Requests Pages Requests Pages Requests Pages
All disclosed 30 334 2 284 0 0 0 0 0 0
Disclosed in part 55 1,131 13 3,025 4 2,618 3 6,421 1 6,740
All exempted 3 23 0 0 0 0 0 0 0 0
All excluded 0 0 0 0 0 0 0 0 0 0
Abandoned 29 14 1 147 3 1,940 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0 0 0 0 0 0
Total 117 1,502 16 3,456 7 4,558 3 6,421 1 6,740
3.5.3 Relevant minutes processed and disclosed for audio formats

No audio files were provided to the ISC ATIP office in response to an ATIA request.

3.5.4 Relevant minutes processed per request disposition for audio formats by size of requests

No audio files were provided to the ISC ATIP office in response to an ATIA request.

3.5.5 Relevant minutes processed and disclosed for video formats

No video files were provided to the ISC ATIP office in response to an ATIA request.

3.5.6 Relevant minutes processed per request disposition for video formats by size of requests

No video files were provided to the ISC ATIP office in response to an ATIA request.

3.5.7 Other complexities

During the reporting period, two (2) privacy files required consultation which resulted in a partial disclosure of these file.

Table 3.5.7 Other complexities
Disposition Consultation required Legal advice sought Other Total
All disclosed 0 0 0 0
Disclosed in part 2 0 0 2
All exempted 0 0 0 0
All excluded 0 0 0 0
Abandoned 0 0 0 0
Neither confirmed nor denied 0 0 0 0
Declined to act with the approval of the Information Commissioner 0 0 0 0
3.6 Closed requests

The following section details the number of privacy requests closed within the legislated timelines.

3.6.1 Number of requests closed within legislated timelines

During the reporting period, 143 requests or 70% were closed within legislated timelines. (Table 2.6.1) These are higher results achieved from the previous reporting year which saw only 53% compliance.

Table 3.6.1 Number of requests closed within legislated timelines
Number of requests closed within legislated timelines 143
Percentage of requests closed within legislated timelines (%) 70.44
3.7 Deemed refusals

The following sections detail the number of, and reasons for requests in deemed refusal (past legislative timelines) throughout 2021-2022.

3.7.1 Reason for not meeting legislated timelines

The majority of deemed refusals or late requests were a result of the Department's ability to retrieve records. (Table 3.7.1).

Table 3.7.1 Number of requests closed within legislated timelines
Number of requests closed past the legislated timelines Principal Reason
Interference with Operations / Workload External Consultation Internal Consultation Other
60 60 0 0 0
3.7.2 Request closed beyond legislated timelines (including any extension taken)

Requests closed beyond legislated timelines include any files where a request for extension was requested. During this reporting period 60 requests were closed past the legislated timelines and 26 were closed past the timelines where an extension was taken on the file.

Table 3.7.2 Number of days past deadline
Number of days past legislated timelines Number of requests past legislated timeline where no extension was taken Number of requests past legislated timeline where an extension was taken Total
1 to 15 days 5 4 9
16 to 30 days 0 6 6
31 to 60 days 1 4 5
61 to 120 days 3 5 8
121 to 180 days 3 0 3
181 to 365 days 7 9 16
More than 365 days 7 6 13
Total 26 34 60
3.8 Requests for translation

During the reporting period, there were no instances where a requester asked for responsive records be translated to another official language.

Table 3.8 Request for translation
Translation Requests Accepted Refused Total
English to French 0 0 0
French to English 0 0 0
Total 0 0 0

4. Disclosure under subsections 8(2) and 8(5)

Permissible disclosure pursuant to subsection 8(2) of the Privacy Act describes the circumstances under which personal information under the control of government institutions may be disclosed without the consent of the individual to whom the information pertains. In 2021-2022, ISC made 56 permissible disclosures under 8(2)(e) and three (3) under 8(2)(m). The Treasury Board of Canada Secretariat requires these permissible disclosures to be captured in the statistical report.

The disclosures authorized under 8(2)(e) pursuant to requests made by investigative bodies were completed in accordance with the PA. The PA permits the disclosure of personal information to an investigative body specified in the regulations, on the written request of the body, for the purpose of enforcing any law of Canada or a province or carrying out a lawful investigation, if the request specifies the purpose and describes the information to be disclosed. The Department has the control of a substantial amount of personal information required to provide benefits and services to Indigenous Peoples.

There were three (3) disclosures authorized under 8(2)(m) where the head of the institution found the public interest in disclosure clearly outweighed any invasion of privacy that could result from the disclosure. The PA permits disclosure under 8(2)(m) pursuant to any purpose where, in the opinion of the head of the institution the public interest in disclosure clearly outweighs any invasion of privacy that could result from the disclosure, or disclosure would clearly benefit the individual to whom the information relates.

The Office of the Privacy Commissioner was notified of all three (3) disclosures pursuant to section 8(2)(m) as required under section 8(5) of the PA.

Other permissible disclosures not captured by the statistical report include:

There was eight (8) disclosures authorized under 8(2)(d) pursuant to a request from the Department of Justice and disclosure complied existing criteria for disclosure. The PA permits the disclosure of personal information to the to the Attorney General of Canada for use in legal proceedings involving the Crown in right of Canada or the Government of Canada.

There were 640 disclosures authorized under 8(2)(f) pursuant to an agreement or arrangement between the Government of Canada and another jurisdiction for the purpose of administering or enforcing any law or carrying out a lawful investigation. The department provides services across multiple-jurisdictions and agreements exist and continue to be drafted to respect the department's obligations under the PA.

There were three (3) disclosures authorized under 8(2)(j) pursuant to requests to undertake research or statistical activities. The PA permits the disclosure personal information to any person or body for research or statistical purposes with specific provisions

There were two (2) disclosures authorized under 8(2)(k) pursuant to requests from the authorized researchers identified in the PA. The PA permits the disclosure of personal information for the purpose of researching or validating the claims, disputes or grievances of any of the aboriginal peoples of Canada.

The Privacy/Policy team processed a combined total of 726 requests under section 8(2) of the PA during 2021-2022.

Table 4 Disclosures Under Subsections 8(2) and 8(5)
Paragraph 8(2)(e) Subsection 8(2)(m) Subsection 8(5))
56 3 3

5. Requests for Correction of Personal Information and Notations

During the reporting period, there were no requests for correction of personal information or notations.

6. Extensions

6.1 Reasons for extensions

In 2021-2022, 134 extensions were taken under subsection 15(a) of the PA due to volume of requests. This also includes, 51 cases, where delays were due to the difficulties of obtaining records within the Department. Extensions were applied pursuant to section 15(a)(i), due to volume/interference, in the majority of the cases.

Table 6.1 Reasons for extensions
Number of requests where an extension was taken 15(a)(i) Interference with Operations 15(a)(ii) Consultation 15(b) Translation purposes or conversion
Further review required to determine exemptions Large volume of pages Large volume of requests Documents are difficult to obtain Cabinet Confidence Section (Section 70) External Internal
134 0 16 65 51 0 2 0 0
6.2 Length of extensions

The majority of extensions, more specifically 65 extensions, requested and applied during the reporting period were due to the volume of requests received.

Table 6.2 Length of extensions
Number of requests where an extension was taken 15(a)(i) Interference with Operations 15(a)(ii) Consultation 15(b) Translation purposes or conversion
Further review required to determine exemptions Large volume of pages Large volume of requests Documents are difficult to obtain Cabinet Confidence Section (Section 70) External Internal
1 to 15 days 0 0 0 0 0 0 0 0
16 to 30 days 0 16 65 51 0 2 0 0
31 days or > 0
Total 0 16 65 51 0 2 0 0

7. Consultations received from Other Institutions and Organizations

ISC did not receive any consultations from another Government of Canada institutions during 2020-2021.

8. Completion Time of Consultations on Cabinet confidences

During the reporting period, no consultations on the application of section 70 of the PA were sent to Departmental Legal Services Unit for consultation on potential Cabinet confidences.

9. Complaints and Investigations Notices Received

During the 2020-2021 reporting period, there was three (3) complaints received from the Office of the Privacy Commissioner under section 31.

Table 9 Complaints and Investigation Notices Received)
Section 31 Section 33 Section 35 Court action Total
3 0 0 0 3

10. Privacy Impact Assessments (PIAs) and Personal Information Banks (PIBs)

10.1 Privacy Impact Assessments

A Privacy Impact Assessment (PIA) is a risk evaluation of the flow of personal information held within a program or service. This process enables the Department to determine whether new or substantially modified technologies, information systems, initiatives, and proposed programs or policies meet federal government privacy requirements. It identifies and mediates risks on programs collecting and using personal information.

The Department completed no PIAs during the 2020-2021 reporting period.

10.2 Institution-specific and Central Personal Information Banks

The ATIP Directorate completed the transfer and realignment of ISC's Institutional Specific Personal Information Banks from the previous departmental designation. This is reflected in the annual publishing of the departmental Info Source Chapter Info Source: Sources of Federal Government and Employee Information for Indigenous Services Canada.

10.2. Institution-specific and Central Personal Information Banks
Personal Information Banks Active Created Terminated Modified
Institution-specific 37 0 0 0
Central 48 0 0 0
Total 85 0 0 0

11. Privacy Breaches

11.1 Material Privacy Breaches reported

The ATIP Directorate supports the Department in investigating potential privacy breaches. ISC reported no material breaches during this fiscal year. Material privacy breaches are at the highest risk and impact is defined as: involving sensitive personal information and could reasonably cause serious injury or harm to the individual and or involves a large number of affected individuals.

11.2 Non-Material Privacy Breaches

The ATIP Directorate completed the investigation and review of eleven non-material privacy breaches. These reported breaches determined to not meet the threshold of a material privacy. Most privacy breaches were due to administrative errors and identified as low risk.

Table 11.2 Non-Material Privacy Breaches
Number of non-material privacy breaches 11

12. Resources related to the Privacy Act

12.1 Costs

In 2021-2022, ISC spent a total of $560,317 on staffing and goods and services which includes Professional services contracts and other related costs. These amounts reflect the level of effort in support of ISC's responsibilities pursuant to the Act (Table 12.1)

Table 12.1 Allocated Costs
Text alternative for: Table 12.1 Allocated Costs

Table 12.1 is a pie chart that itemizes allocated costs for staffing and goods and services.

In 2021-2022, ISC spent a total of five-hundred-sixty-thousand-three-hundred-seventeen dollars ($560,317) on staffing and goods and services which includes Professional services contracts and other related costs.

Of this amount, two-hundred-sixty-one thousand-seven hundred-sixty-two dollars ($261,762) was spent on salaries, twenty-eight-thousand-sixty-six dollars ($28,066) on overtime, and two-hundred-seventy-thousand-four-hundred-eighty-nine dollars ($270,489) on goods and services.

12.2 Human Resources

In 2021-2022, ISC allocated a total 3.5 full time employees (FTE), which includes the services of one consultant (Table 12.2).

Table 12.2 Human resources
Text alternative for: Table 12.2 Human resources

Table 12.2 is a pie chart describing human resources allocations.

In 2021-2022, ISC allocated a total three-point-five (3.5) full time employees (FTE), which includes the services of one (1) consultant.

Highlights

V. 2020-2021 Points of Interest

The ATIP Directorate administers the Privacy Act (PA) as a shared service for both Indigenous Services Canada (ISC) and Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) since November 30, 2017. This past fiscal year (2021-2022) was the fourth full year of reporting for Indigenous Services Canada under the Access to Information Act and the Privacy Act.

ISC received 202 new privacy requests and closed 203, with a total of 22,677 pages processed under the PA. This fiscal year, there was an increase of 181% in privacy requests since the 2018-2019 reporting period.

The most cited exemption under PA was Section 26 for personal information of other individuals.

There were 56 permissible disclosure requests processed under paragraph 8(2)(e), three (3) under paragraph 8(2)(m) and three (3) more under subsection 8(5) of the PA, which allows for the release of personal information without consent. There were an additional 667 permissible disclosures completed. The majority of the permissible disclosures relate to disclosures under provisions of existing agreements. They are primarily disclosures of information about specific Indigenous individuals, who have received services or benefits from the Department or associated multi-jurisdictional partners.

The relationship existing between Indigenous Peoples, Provinces, Territories and the Department leads to a large volume of requests for permissible disclosures under section 8(2) and necessitates the continuous development and renewal of Information Sharing Agreements and Memorandums of Understanding.

The focus of the Privacy and Policy unit in 2021-2022 was on data sharing activities on the disclosure of personal information related to the ongoing settlement activities and responsive program developments (Health, Education and Child and Family Services; and internal privacy policy support for pandemic response, human resources, health, and child and family services related purposes).

ATIP Directorate also trained a total of 369 ISC Employees on the Access to Information Act and Privacy Act in 2021-2022.

The ATIP office continuously monitors progress on all Privacy files. Reports are prepared monthly to ensure compliance with legislative timelines so that risks can be mitigated. In addition, quarterly reports are also extracted on the Department's performance in meeting legislative time frames and are shared with the senior management table (SMT).

For the 2020-2021 fiscal year, ISC spent $560,317 and was supported by 3.5 human resources for the administration of the Privacy Act on behalf of the Department.

In effort to better serve Canadians, ATIP has continued to provide responses to requesters electronically through E-Post Connect and email. The department continues to monitor new internal procedures options to streamline processes and increase effectiveness.

Appendix A

Order of Delegation of the Privacy Act dated November 6, 2020

Delegation Order

Access to Information Act and Privacy Act

I, the Minister of Indigenous Services Canada, pursuant to section 95 of the Access to Information Act and section 73 of the Privacy Act, hereby delegate the persons holding the positions set out in the Delegation of Authority Schedule attached hereto, or the persons occupying on an acting basis those positions, to exercise the powers, duties and functions of the Minister as head of Indigenous Services Canada, under the provisions of the Act and related regulations set out in the schedule opposite each position. This delegation supersedes all previous delegation orders.

Original document signed on 6 November, 2020
The Honourable Patty Hajdu, P.C., M.P.
Minister of Indigenous Services

Designation Pursuant to Section 73 of the Accees Information Act

6
Advise requesters that we need additional information to proceed with their request
7(a)
Give written notice to requestor that we can proceed with the request
8(1)
Transfer request to another institution or accept transfer from another institution
9
Extend time limits
10
Refuse to acknowledge or deny the existence of records
11
Charge additional fees
12
Provide access in alternate format
13
Exempt information obtained in confidence
14
Exempt information pertaining to federal-provincial affairs
15
Exempt information pertaining to international affairs and/or defence
16
Exempt information pertaining to law enforcement and investigations
17
Exempt information pertaining to the safety of individuals
18
Exempt information pertaining to the economic interests of Canada
19
Exempt personal information
20
Exempt or disclose third party information
21
Exempt information pertaining to advice, decision-making processes of government plans and positions etc.
22
Exempt information pertaining to testing procedures or audits
23
Exempt information pertaining to solicitor-client privilege
24
Exempt information subject to statutory prohibitions or other Acts of Parliament
25
Sever information
26
Exempt information to be published within 90 days
27(1)(4)
Notify third parties of their rights to provide comments/representations regarding the disclosure of their records
28
Receive third party representations; make a decision as to whether to disclose the record or part thereof; and, notify third party of right to appeal to Federal Court
29(1)
Disclose information on Information Commissioner's recommendation
33
Advise the Information Commissioner of any third-party involvement
35(2)
Make representations to the Information Commissioner during an investigation
37(4)
Release information to complainant
43(1)
Issue a notice to a third party of an application for Court review
44(2)
Issue a notice to an applicant that a third party has applied for Court review
52
Request special rules for hearings
69
Exclude Cabinet Confidences
71
Inspect and exempt information in manuals
72(1)
Prepare Annual Report to Parliament
77
Carry out responsibilities conferred to the Head of the institution by the regulations made under section 77 which are not included in the above

Delegation of Authority Schedule

Position Access to Information Act and Regulations Privacy Act and Regulations
Deputy Minister Full authority Full authority except:
sections 73.1(3), 73.1(5).
Associate Deputy Minister Full authority Full authority except:
sections 73.1(3), 73.1(5).
Corporate Secretary Full authority except:
sections 94, 96(3) or 96(5).		 Full authority
Sections 72, 73.1(3), 73.1(5).
Director, Access to Information and Privacy Full authority except:
sections 94, 96(3) or 96(5).		 Full authority, except:
Sections 72, 73.1(3), 73.1(5).
Deputy Director, Access to Information and Privacy Full authority, except:
sections 33, 37(1)(c), 37(4), 41(2),
43(2), 44(2) and 52(2)(b) and 52(3), 94, 96(3) or 96(5).		 Full authority except:
Sections 8(2)(j), 8(2)(m), 8(5), 9(1),
9(4), 10, 33(2), 35(1)b), 35(4), 36(3)(b), 51(2)(b), (3), 72, 73.1(3), 73.1(5).

Please see Access to Information Act for more information on the Access to Information Act.

Designation Pursuant to Section 73 of the Privacy Act

Sections and Powers, Duties or Functions

8(2)
Disclose personal information without the consent of the individual to whom it relates
8(4)
Keep copies of requests made under 8(2)(e), keep records of information disclosed pursuant to such requests and to make those records available to Privacy Commissioner
8(5)
Notify the Privacy Commissioner in writing of disclosure under paragraph 8(2)(m)
9(1)
Retain a record of use of personal information
9(4)
Notify the Privacy Commissioner of consistent use of personal information and update index accordingly
10
Include personal information in personal information banks
11(a)
Publish annually an index of all personal information banks and their respective contents
11(b)
Publish annually an index of all personal information held by the institution which is not part of a bank
14
Respond to request for access, within statutory deadline; give access or give notice
15
Extend time limit and notify applicant
16
Where access is refused
17(2)(b)
Language of access or alternative format of access
17(3)(b)
Access to personal information in alternative format
18(2)
May refuse to disclose information contained in an exempt bank
19(1)
Shall refuse to disclose information obtained in confidence from another government
19(2)
May disclose any information referred to in 19(1) if the other government consents to the disclosure or makes the information pubic
20
May refuse to disclose information injurious to federal-provincial affairs
21
May refuse to disclose information injurious to international affairs and/or defence
22
May refuse to disclose information injurious to law enforcement and investigation
23
May refuse to disclose information injurious to security clearances
24
May refuse to disclose information collected by the Canadian Penitentiary Service, the National Parole Service or the National Parole Board
25
May refuse to disclose information injurious to which could threaten the safety of individuals
26
May refuse to disclose information about other individuals, and shall refuse to disclose such information where disclosure is prohibited under section 8
27
May refuse to disclose information subject to solicitor-client privilege
28
May refuse to disclose information relating to an individual's physical or mental health where disclosure is contrary to the best interests of the individual
31
Receive notice of investigation by the Privacy Commissioner
33(2)
Make representations to the Privacy Commissioner during an investigation
35(1)
Receive the Privacy Commissioner's report of findings of the investigation and give notice of action taken
35(4)
Give complainant access to information after 35(1)(b) notice
36(3)
Receive Privacy Commissioner's report of findings of investigation of exempt
37(3)
Receive report of Privacy Commissioner's findings after compliance investigation where the institution has not complied with sections 4 to 8
51(2)(b)
Request that matter be heard and determined in National Capital Region
51(3)
Request and be given right to make representations in section 51 hearing
72(1)
Prepare Annual Report to Parliament
77
Carry out responsibilities conferred on the Head of the institution by the regulations made under section 77 which are not included above

Delegation of Authority Schedule

Position Access to Information Act and Regulations Privacy Act and Regulations
Deputy Minister Full authority Full authority except:
sections 73.1(3), 73.1(5).
Associate Deputy Minister Full authority Full authority except:
sections 73.1(3), 73.1(5).
Corporate Secretary Full authority except:
sections 94, 96(3) or 96(5).		 Full authority
Sections 72, 73.1(3), 73.1(5).
Director, Access to Information and Privacy Full authority except:
sections 94, 96(3) or 96(5).		 Full authority, except:
Sections 72, 73.1(3), 73.1(5).
Deputy Director, Access to Information and Privacy Full authority, except:
sections 33, 37(1)(c), 37(4), 41(2),
43(2), 44(2) and 52(2)(b) and 52(3), 94, 96(3) or 96(5).		 Full authority except:
Sections 8(2)(j), 8(2)(m), 8(5), 9(1),
9(4), 10, 33(2), 35(1)b), 35(4), 36(3)(b), 51(2)(b), (3), 72, 73.1(3), 73.1(5).

Please see Privacy Act for more information on the Privacy Act

Appendix B

Statistical Report on the Privacy Act

Name of institution: Indigenous Services Canada

Reporting period: 4/1/2021 to 3/31/2022

Section 1: Requests Under the Privacy Act

1.1a Number of requests received and outstanding
Number of Requests
Received during reporting period 202
Outstanding from previous reporting periods
Outstanding from previous reporting period
 39
Outstanding from more than one reporting period
 13
Total outstanding from previous reporting periods 52
Total 254
1.1b Number of requests closed and carried over
Number of Requests
Closed during reporting period 203
Carried over to next reporting period
Carried over within legislated timeline
 34
Carried over beyond legislated timeline
 17
Total Carried over to next reporting period 51
Table 1.2 Channels of requests
Source Number of Requests
Online 112
E-mail 90
Mail 0
In person 0
Phone 0
Fax 0
Total 202

Section 2: Informal requests

2.1a Number of informal requests received and outstanding
Number of Requests
Received during reporting period 0
Outstanding from previous reporting periods
Outstanding from previous reporting period
 0
Outstanding from more than one reporting period
 0
Total outstanding from previous reporting periods 0
Total 0
2.1b Number of informal requests closed and carried over
Number of Requests
Closed during reporting period 0
Carried over to next reporting period 0
2.2 Channels of informal requests
Source Number of Requests
Online 0
E-mail 0
Mail 0
In person 0
Phone 0
Fax 0
Total 0
2.3 Completion time of informal requests
Completion Time
1 to 15 Days 16 to 30 Days 31 to 60 Days 61 to 120 Days 121 to 180 Days 181 to 365 Days More Than 365 Days Total
0 0 0 0 0 0 0 0
2.4 Pages released informally
Less than 100 pages processed 101-500
pages processed		 501-1000
pages processed		 1001-5000
pages processed		 More than 5000 pages processed
Requests Pages disclosed Requests Pages disclosed Requests Pages disclosed Requests Pages disclosed Requests Pages disclosed
0 0 0 0 0 0 0 0 0 0

Section 3: Requests Closed During the Reporting Period

3.1 Disposition and completion time
Disposition of Requests Completion Time
1 to 15 days 16 to 30 days 31 to 60 days 61 to 120 days 121 to 180 days 181 to 365 days More than 365 days Total
All disclosed 2 7 11 4 2 3 3 32
Disclose in part 3 11 24 16 5 9 8 76
All exempted 0 1 1 1 0 0 0 3
All excluded 0 0 0 0 0 0 0 0
No records exist 4 20 14 10 1 5 5 59
Request abandoned 20 4 1 1 0 3 4 33
Neither confirmed nor denied 0 0 0 0 0 0 0 0
Total 29 43 51 32 8 20 20 203
3.2 Exemptions
Section Number of requests
18(2) 0
19(1)(a) 0
19(1)(b) 0
19(1)(c) 0
19(1)(d) 0
19(1)(e) 0
19(1)(f) 0
20 0
21 0
22(1)(a)(i) 0
22(1)(a)(ii) 0
22(1)(a)(iii) 0
22(1)(b) 0
22(1)(c) 0
22(2) 0
22.1 0
22.2 0
22.3 0
22.4 0
23(a) 0
23(b) 0
24(a) 0
24(b) 0
25 0
26 78
27 4
27.1 0
28 1
3.3 Exclusions
Section Number of Requests
69(1)(a) 0
69(1)(b) 0
69.1 0
70(1) 0
70(1)(a) 0
70(1)(b) 0
70(1)(c) 0
70(1)(d) 0
70(1)(e) 0
70(1)(f) 0
70.1 0
3.4 Format of information released
Paper Electronic Other
E-record Data set Video Audio
6 102 0 0 0 0
3.5 Complexity
3.5.1 Relevant pages processed and disclosed for paper and e-record formats
Number of Pages Processed Number of Pages Disclosed Number of Requests
22,677 11,250 144
3.5.2 Relevant pages processed by request disposition for paper and e-record formats by size of requests
Disposition Less than 100 pages processed 101-500 pages processed 501-1000 pages processed 1001-5000 pages processed More than 5000 pages processed
Number of Requests Pages Processed Number of Requests Pages Processed Number of Requests Pages Processed Number of Requests Pages Processed Number of Requests Pages Processed
All disclosed 30 334 2 284 0 0 0 0 0 0
Disclosed in part 55 1,131 13 3,025 4 2,618 3 6,421 1 6,740
All exempted 3 23 0 0 0 0 0 0 0 0
All excluded 0 0 0 0 0 0 0 0 0 0
Request abandoned 29 14 1 147 3 1,940 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0 0 0 0 0 0
Total 117 1,502 16 3,456 7 4,558 3 6,421 1 6,740
3.5.3 Relevant minutes processed and disclosed for audio formats
Number of Minutes Processed Number of Minutes Disclosed Number of Requests
0 0 0
3.5.4 Relevant minutes processed per request disposition for audio formats by size of requests
Disposition Less than 60 Minutes processed 60-120 Minutes processed More than 120 Minutes processed
Number of Requests Minutes Processed Number of Requests Minutes Processed Number of Requests Minutes Processed
All disclosed 0 0 0 0 0 0
Disclosed in part 0 0 0 0 0 0
All exempted 0 0 0 0 0 0
All excluded 0 0 0 0 0 0
Request abandoned 0 0 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0 0
Total 0 0 0 0 0 0
3.5.5 Relevant minutes processed and disclosed for video formats
Number of Minutes Processed Number of Minutes Disclosed Number of Requests
0 0 0
3.5.6 Relevant minutes processed per request disposition for video formats by size of requests
Disposition Less than 60 Minutes processed 60-120 Minutes processed More than 120 Minutes processed
Number of Requests Minutes Processed Number of Requests Minutes Processed Number of Requests Minutes Processed
All disclosed 0 0 0 0 0 0
Disclosed in part 0 0 0 0 0 0
All exempted 0 0 0 0 0 0
All excluded 0 0 0 0 0 0
Request abandoned 0 0 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0 0
Total 0 0 0 0 0 0
3.5.7 Other complexities
Disposition Consultation Required Legal Advice Sought Interwoven Information Other Total
All disclosed 0 0 0 0 0
Disclosed in part 2 0 0 0 2
All exempted 0 0 0 0 0
All excluded 0 0 0 0 0
Request Abandoned 0 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0
Total 2 0 0 0 2
3.6 Closed requests
Table 3.6.1 Number of requests closed within legislated timelines
Number of requests closed within legislated timelines 143
Percentage of requests closed within legislated timelines (%) 70.44334975
3.7 Deemed refusals
Table 3.7.1 Reason for not meeting legislated timelines
Number of Requests Closed Past the Legislated Timelines Principal Reason
Interference with operations / Workload External Consultation Internal Consultation Other
60 60 0 0 0
3.7.2 Request closed beyond legislated timelines (including any extension taken)
Number of days past legislated timelines Number of requests past legislated timeline where no extension was taken Number of requests past legislated timeline where an extension was taken Total
1 to 15 days 5 4 9
16 to 30 days 0 6 6
31 to 60 days 1 4 5
61 to 120 days 3 5 8
121 to 180 days 3 0 3
181 to 365 days 7 9 16
More than 365 days 7 6 13
Total 26 34 60
3.8 Requests for translation
Translation Requests Accepted Refused Total
English to French  0 0 0
French to English  0 0 0
Total 0 0 0

Section 4: Disclosures Under Subsections 8(2) and 8(5)

Paragraph 8(2)(e) Paragraph 8(2)(m) Subsection 8(5) Total
56 3 3 62

Section 5: Requests for Correction of Personal Information and Notations

Disposition for Correction Requests Received Number
Notations attached 0
Requests for correction accepted 0
Total 0

Section 6: Extensions

Table 6.1 Reasons for extensions
Number of requests where an extension was taken 15(a)(i) Interference with Operations 15(a)(ii) Consultation 15(b) Translation purposes or conversion
Further review required to determine exemptions Large volume of pages Large volume of requests Documents are difficult to obtain Cabinet Confidence Section (Section 70) External Internal
134 0 16 65 51 0 2 0 0
6.2 Length of extensions
Length of Extensions 15(a)(i) Interference with operations 15 (a)(ii) Consultation  15(b) Translation purposes or conversion
Further review required to determine exemptions Large volume of pages Large volume of requests Documents are difficult to obtain Cabinet Confidence Section (Section 70) External Internal
1 to 15 days 0 0 0 1 0 0 0 0
16 to 30 days 0 16 65 51 0 2 0 0
31 days or greater                0
Total 0 16 65 51 0 2 0 0

Section 7: Consultations Received From Other Institutions and Organizations

7.1a Consultations, received and outstanding, from other Government of Canada institutions and other organizations
Consultations Other Government of Canada Institutions Number of Pages to Review Other Organizations Number of Pages to Review
Received during the reporting period 0 0 0 0
Outstanding from the previous reporting period 0 0 0 0
Total 0 0 0 0
7.1b Consultations, closed and carried over, from other Government of Canada institutions and other organizations
Consultations Other Government of Canada Institutions Number of Pages to Review Other Organizations Number of Pages to Review
Closed during the reporting period 0 0 0 0
Carried over within negotiated timelines 0 0 0 0
Carried over beyond negotiated timelines 0 0 0 0
7.2 Recommendations and completion time for consultations received from other Government of Canada institutions
Recommendation Number of Days Required to Complete Consultation Requests
1 to 15 Days 16 to 30 Days 31 to 60 Days 61 to 120 Days 121 to 180 Days 181 to 365 Days More Than 365 Days Total
Disclose entirely 0 0 0 0 0 0 0 0
Disclosed in part 0 0 0 0 0 0 0 0
Exempt entirely 0 0 0 0 0 0 0 0
Exclude entirely 0 0 0 0 0 0 0 0
Consult other institution 0 0 0 0 0 0 0 0
Other 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0
7.3 Recommendations and completion time for consultations received from other organizations outside the Government of Canada
Recommendation Number of Days Required to Complete Consultation Requests
1 to 15 Days 16 to 30 Days 31 to 60 Days 61 to 120 Days 121 to 180 Days 181 to 365 Days More Than 365 Days Total
Disclose entirely 0 0 0 0 0 0 0 0
Disclosed in part 0 0 0 0 0 0 0 0
Exempt entirely 0 0 0 0 0 0 0 0
Exclude entirely 0 0 0 0 0 0 0 0
Consult other institution 0 0 0 0 0 0 0 0
Other 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0

Section 8: Completion Time of Consultations on Cabinet Confidences

8.1 Requests with Legal Services
Number of Days Fewer Than 100 Pages Processed 101-500 Pages Processed 501-1000 Pages Processed 1001-5000 Pages Processed More than 5000 Pages Processed
Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed
1 to 15 0 0 0 0 0 0 0 0 0 0
16 to 30 0 0 0 0 0 0 0 0 0 0
31 to 60 0 0 0 0 0 0 0 0 0 0
61 to 120 0 0 0 0 0 0 0 0 0 0
121 to 180 0 0 0 0 0 0 0 0 0 0
181 to 365 0 0 0 0 0 0 0 0 0 0
More than 365 0 0 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0 0 0
8.2 Requests with Privy Council Office
Number of Days Fewer Than 100 Pages Processed 101-500 Pages Processed 501-1000 Pages Processed 1001-5000 Pages Processed More than 5000 Pages Processed
Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed
1 to 15 0 0 0 0 0 0 0 0 0 0
16 to 30 0 0 0 0 0 0 0 0 0 0
31 to 60 0 0 0 0 0 0 0 0 0 0
61 to 120 0 0 0 0 0 0 0 0 0 0
121 to 180 0 0 0 0 0 0 0 0 0 0
181 to 365 0 0 0 0 0 0 0 0 0 0
More than 365 0 0 0 0 0 0 0 0 0 0
Total 0 0 0 0 0 0 0 0 0 0

Section 9: Complaints and Investigations Notices Received

Section 31 Section 33 Section 35 Court action Total
3 0 0 0 3

Section 10: Privacy Impact Assessments (PIAs) and Personal Information Banks (PIBs)

10.1 Privacy Impact Assessments
Number of PIAs completed 0
Number of PIAs modified 0
10.2 Institution-specific and Central Personal Information Banks
Personal Information Banks Active Created Terminated Modified
Institution-specific 37 0 0 0
Central 48 0 0 0
Total 85 0 0 0

Section 11: Privacy Breaches

11.1 Material Privacy Breaches reported
Number of material privacy breaches reported to TBS 0
Number of material privacy breaches reported to OPC 0
11.2 Non-Material Privacy Breaches
Number of non-material privacy breaches 11

Section 12: Resources Related to the Privacy Act

12.1 Allocated Costs
Expenditures Amount
Salaries $261,762
Overtime $28,066
Goods and Services
Professional services contracts
 $253,285  
Other
 $17,204  
Total Goods and Services $270,489
Total $560,317
12.2 Human Resources
Resources Person Years Dedicated to Privacy Activities
Full-time employees 2.500
Part-time and casual employees 0.000
Regional staff 0.000
Consultants and agency personnel 1.000
Students 0.000
Total 3.500
Note: Enter values to three decimal places.

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