2023-2024 Annual Report to Parliament: Access to Information Act

Introduction
Performance
1. Interpretation of the Statistical Report
V. Monitoring Compliance
1. Training and Awareness
2. Policies, Guidelines, and Procedures
Proactive Publication
1. Proactive Publication under Part 2 of the ATIA
Highlights
1. 2023-2024 Points of Interest
Annex A
- Order of Delegation of the Access to Information Act dated November 6, 2020
- Delegation of Authority Schedule
Annex B

Introduction

roman numeral 1. Introduction

The purpose of the Access to Information Act (ATIA) is to provide Canadians with access to records under the control of federal institutions, except for records subject to limited and specific exemptions and exclusions.

This report reflects the access to information activities of Indigenous Services Canada (ISC) with respect to the stated legislation, for the period of April 1, 2023 to March 31, 2024.

The annual report is tabled in Parliament pursuant to section 94 of the ATIA and in accordance to section 20 of the Service Fees Act. The report describes the activities of ISC in compliance with access to information legislation.

Creation and Growth of the Departments

Since the creation of the Department, the Access to Information and Privacy (ATIP) ATIP Office has provided a shared service support for ISC and Crown-Indigenous Relations and Northern Affairs (CIRNAC) through a service level agreement (SLA).

Delegation of ministerial responsibilities for the ATIA remains institutionally specific.

Indigenous Services Canada's Mandate

The primary mandate of ISC is to work collaboratively with partners to improve access to high quality services for First Nations, Inuit and Métis. The Department aims 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.

roman numeral 2. Organization

Administration of the Access to Information Act at Indigenous Services Canada

Under the SLA, CIRNAC's ATIP Office processes requests made under the ATIA and the Privacy Act (PA). ISC's Corporate Secretary manages the SLA for ISC, and is directly accountable to the Deputy Head. The Corporate Secretary is a member of the ISC Senior Management Committee. The ATIP Office 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 Office.

Under a shared service model, all ATIP analysts processed requests for both ISC and CIRNAC. Requests are varied in volume and complexity.

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

The application of the ATIA and PA;
The release of sensitive or protected information to the public;
Education and awareness of access to information and privacy issues throughout the Department; and
Proactive publications.

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. All requests are monitored using the AccessPro case management tracking system.

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

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

The ATIP Office will be transitioning away from an unsupported and sunsetting case management solution and as such ISC and CIRNAC procured a new case management solution: ATIPXpress. This solution was chosen in the hopes that it will increase efficiency, reduce processing times, and streamline the processing of requests. This in turn could reduce the number of complaints we receive, alleviating pressures from both the Office of the Information Commissioner, and the Privacy Commissioners of Canada and improve service to the public. This new case management system provides a supported, stable, and technologically contemporary tool that provides the ability to manage both department's workloads fluidly within one system, further cutting down processing time. The solution is expected to be implemented in fiscal 2024-2025.

ATIP Operations has created and implemented a developmental program. The program is based on predetermined performance benchmarks that clearly state the expectations at each level from CR-04 to PM-06. An employee can choose to participate to develop their skills and build experience. With guidance from the team leaders, employees can advance within the organization.

This program was created to be open and transparent in order to develop and retain current staff and provide growth opportunities within the ATIP Office. The developmental program is highly successful and each year more and more analysts graduate to higher PM levels. During this reporting period, eleven analysts were promoted or provided acting opportunities based on their success in the program.

The Department has continued to meet its publication requirements in this reporting period. The Department has published briefing material titles submitted to the Minister and Deputy Minister on a monthly basis as well as the summaries of the completed requests on the Open Government Portal, thereby continuing to improve communication with applicants and promoting transparency.

The Department continued to use the Microsoft Office 365 tools to communicate internally and engage with key stakeholders. The ATIP office also leveraged these tools for the transfer of information with sectors to allow for business continuity within the hybrid workplace structure.

To better serve our clients, the Department participates in the Access to Information and Privacy Online Request Service. Our clients can submit requests under the Act through this online channel administered by TBS.

In April 2023, the ATIP Office returned on-site in a hybrid model. Pandemic response conditions substantially reduced the use of paper. During this reporting period, the office mostly received electronic requests and records, and in most cases provided release packages electronically to applicants with the use of E-post Connect, which was implemented in February 2020.

The Department continues to use electronic tools to facilitate the collection, consultation and processing of information even with the return to the workplace.

roman numeral 3. Delegation Order

Under section 95 of the ATIA, the Minister's authority may be delegated to departmental officials in order to administer the ATIA within ISC.

During the reporting period, the delegation order signed by Minister Marc Miller on November 6, 2020, was in effect Appendix A). Under section 95 of the ATIA, the order delegates full authority and responsibility for the ATIA to the following positions:

Deputy Minister
Associate Deputy Minister
Corporate Secretary
ATIP Coordinator
ATIP Deputy Directors

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 is also supported 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 ensuring the department is adhering to the collection, use and disclosure of personal information holdings as per the Privacy Act. They also ensure all policies for Access and Privacy align with Treasury Board policies and directives. 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, court ordered disclosure requests, Privacy Assessments, etc.) and provide training and Privacy advice. They are 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-01s and CR-04s), 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.

Performance

roman numeral 4. Interpretation of the Statistical Report

ISC's Statistical Report and Supplemental Report were submitted to the Treasury Board Secretariat (TBS) on July 15th, 2024 (Appendix B). The Report details various aspects of the requests ISC received and processed during the period of April 1, 2023 to March 31, 2024.

1. Requests under the Access to Information Act

1.1 Number of requests

In 2023-2024, ISC received 363 requests, representing a decrease of approximately 12% compared to the 412 received in 2022-2023 (Table 1.1.1). With the addition of the 312 requests that were carried over from the previous year, this reflected a total of 675 requests to be processed in the course of the reporting period. The department completed 421 requests, 58 or 14% more than received, and carried 254 requests into the next reporting period 2024-2025 (Table 1.1.2).

The listing of ISC's completed access to information requests can be found on the Open Canada's website.

Table 1.1.1 Number of requests 2020-2024
Number of Requests	2020-2021	2021-2022	2022-2023	2023-2024
Received during reporting period	358	444	412	363
Outstanding from previous reporting period	359	377	335	312
Total	717	821	747	675

Table 1.1.2 2020-2024 Number of requests closed and carried over to next reporting period
Number of Requests	2020-2021	2021-2022	2022-2023	2023-2024
Closed during reporting period	342	484	435	421
Carried over to next reporting period	375	337	312	254

1.2 Sources of requests

Of the 363 requests received during the reporting period, 110 (30%) were from the public, followed by 95 (26%) from businesses, and 84 (23%) from the media (Table 1.2). In previous years, those who declined to identify were the main source of requests.

	Public	Media	Business	Organization	Academia	Decline to Identify
2020-2021	143	21	81	5	97	11
2021-2022	105	76	87	7	45	124
2022-2023	84	71	71	3	28	155
2023-2024	110	84	95	7	37	30

1.3 Channels of requests

The channels of requests serve to identify the mechanism used by the Canadian public to request records from the Department: Open Government of Canada Portal, e-mail, mail, phone or fax. The Government of Canada Online Portal was the most used mechanism to request records from the Department.

Table 1.3 Channels of requests
Channel	Number of Requests
Online	330
E-mail	20
Mail	12
In person	0
Phone	0
Fax	1
Total	363

2. Informal requests

An informal request is defined as a request for copies of previously released access to information requests. As per Treasury Board of Canada (TBS) policies, institutions are required to publicly post titles of summaries of completed requests. Government departments do not charge any application fees for the informal requests and there are no timelines for responding to the requesters. In addition, the requesters have no statutory right of complaint to the Office of the Information Commissioner of Canada (OIC).

2.1 Number of informal requests

During the 2023-2024 reporting period, ISC received 327 informal requests, an decrease of 64% compared to the 915 requests received in 2022-2023. With the addition of the 489 requests that were carried over from the previous year, this reflected a total of 816 informal requests to be processed. The Department completed 737 informal requests (90% of the informal requests) and carried 79 requests into the next reporting period 2024-2025. That represents an 84% drop in carried forward informal requests.

Year	Number of Requests
2020-2021	144
2021-2022	231
2022-2023	915
2023-2024	327

2.2 Channels of informal requests

The channels of requests serve to identify the number and mechanism used by the Canadian public for informal requests: Government of Canada Online Portal, e-mail, mail, phone or fax. The channels of requests are a new reporting requirement. All informal requests this reporting fiscal year were received through the Government of Canada Online Portal or by e-mail.

Table 2.2 Channels of requests
Channel	Number of Requests
Online	295
E-mail	32
Mail	0
In person	0
Phone	0
Fax	0
Total	327

2.3 Completion time of informal requests

Table 2.3 (below), reports the number of requests/completion time for the 737 informal requests closed during the 2023-2024 reporting period. The table demonstrates the percentage of informal requests closed during the reporting period and the number of days it took to process and close them.

Days	Number of Requests
0 to 15 days	50
16 to 30 days	36
31 to 60 days	51
61 to 120 days	64
121 to 180 days	53
181 to 365 days	367
> 365 days	116

2.4 Pages released informally

This section provides information on the number of informal requests closed in relation to pages released. Table 2.4 provides information on the number of informal requests that were closed during the 2023-2024 reporting period that fall under each range of pages released. Of the 737 requests completed, 416 were requests for copies of records previously processed through a formal access to information request.

Table 2.4 Pages released informally
Pages Released	Number of Requests	Pages Released
Less than 100	330	4,671
100 to 500	66	15,240
501 to 1000	10	7,406
1001 to 5000	10	17,714
Greater than 5000	0	0
Total	416	45,031

2.5 Pages re-released informally

Of the 737 informal requests completed, 321 requests were processed as re-releases. These requests were for copies of records previously processed through a formal access to information request that have had copies provided to the public informally in previous instances.

Table 2.5 Pages re-released informally
Pages Released	Number of Requests	Pages Released
Less than 100	220	5,980
100 to 500	70	17,167
501 to 1000	21	13,505
1001 to 5000	9	19,828
Greater than 5000	1	54,622
Total	321	111,102

3. Applications to the Information Commissioner on Declining to Act on Requests

As per the ATIA, Departments may submit an application to the Information Commissioner to decline to act on a request considered to be vexatious, made in bad faith or considered to be an abuse of rights. However, this application must be approved by the Information Commissioner of Canada (OIC) pursuant to section 6 of the ATIA. ISC has not submitted any application to decline to act pursuant to section 6, as no requests met the set criteria for such an application during the 2023-2024 reporting year.

4. Requests closed during the reporting period

4.1 Disposition and completion time

Of the 421 formal access to information requests closed during the reporting period, ISC was able to fully or partially disclose records in 268 cases (64% of the requests) (Table 4.1.1).

**Table 4.1.1 Percentage of completed files relevant to each disclosures**

Dispositions	Percentage
All disclosed	15%
Disclosed in part	49%
All exempted	1%
All excluded	0%
No records exist	21%
Request transferred	0%
Request abandoned	14%

About 14% percent of requests were abandoned or transferred to the appropriate government institution (60 cases). Only 7 cases (2% of all requests) had the relevant records fully exempted or excluded under provisions of the Act. Finally, there were no records that existed in response to 86 cases or 20% of the requests (Table 4.1.2).

Table 4.1.2 Disposition and completion time
Disposition of requests	Completion Time (days)
Disposition of requests	1 to 15	16 to 30	31 to 60	61 to 120	121 to 180	181 to 365	> 365	Total
All disclosed	2	13	19	16	4	5	3	62
Disclosed in part	1	4	20	41	31	52	57	206
All exempted	0	0	1	2	1	1	1	6
All excluded	0	0	0	0	0	0	1	1
No records exist	23	38	15	6	3	1	0	86
Request transferred	1	0	0	0	0	0	0	1
Request abandoned	31	10	5	2	1	1	9	59
Neither confirmed nor denied	0	0	0	0	0	0	0	0
Decline to act with the approval of the Information Commissioner	0	0	0	0	0	0	0	0
Total	58	65	60	67	40	60	71	421

4.2 Exemptions

The most commonly invoked exemption applied were pursuant to section 20(1) (third party) which was applied in 278 instances. The next most commonly applied exemption was section 21(1) (advice or deliberations), was applied in 199 instances. The third most applied exemption, section 19(1) (personal information) was applied in 164 instances. Each request under the ATIA can have more than one exemption applied (Table 4.2).

Table 4.2 Number of requests closed where exemption provisions were invoked
Section	Number of requests
13(1)(c)	10
13(1)(d)	2
13(1)(e)	6
14	6
14(a)	10
14(b)	1
16(1)c)	1
16(2)	15
16(2)(c)	14
16(3)	1
16.1(1)(c)	2
18(a)	3
18(b)	2
18(d)	1
19(1)	164
20(1)(a)	2
20(1)(b)	129
20(1)(b.1)	57
20(1)(c)	45
20(1)(d)	45
20.1	7
21(1)(a)	71
21(1)(b)	85
21(1)(c)	40
21(1)(d)	3
22	1
22.1(1)	3
23	33
26	1

4.3 Exclusions

In 2023-2024, the Department applied 7 (seven) mandatory exclusion provisions on requests completed. (Table 4.3)

Table 4.3 Number of requests closed where exclusion provisions were applied
Section	Number of requests
68(a)	1
68.1	1
68.2(a)	1
68.2(b)	1
69(1)	1
69(1)(a)	1
69(1)(e)	1

4.4 Format of information released

Over the course of this reporting period, the majority of responses were provided to the requesters electronically through E-post Connect or through e-mail. On two (2) occasions, individuals who did not have access to retrieve records electronically were provided with paper copies through regular mail. (Table 4.4)

Table 4.4 Format of information released
Paper	Electronic				Other
Paper	E-Record	Data Set	Video	Audio	Other
2	266	0	0	0	0

4.5 Complexity

The following sections details several factors affecting the complexity of requests that were completed throughout 2023-2024.

4.5.1 Relevant pages processed and disclosed

Of the 421 requests closed, 334 requests generated a total of 150,556 pages processed. The total amount of pages disclosed during the reporting year was 71,741, a 35% decrease from the 110,811 pages disclosed in the previous reporting period. (Table 4.5.1)

Table 4.5.1 Relevant pages processed and disclosed
Number of Pages Processed	Number of Pages Disclosed	Number of Requests
150,556	71,741	334

4.5.2 Relevant pages processed per request disposition for paper and e-records formats by size of requests

Of the 334 requests, 192 requests (57%) required the processing of 100 pages or less. 101 requests contained 101-1000 pages to be processed. However 41 requests (12%) had more than 1,001 pages to be reviewed accounting for 109,023 pages of records processed. (Table 2.5.2)

Table 4.5.2 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		> 5000 pages
Disposition	Requests	Pages	Requests	Pages	Requests	Pages	Requests	Pages	Requests	Pages
All disclosed	44	1,048	8	1,479	6	3,889	4	6,668	0	0
Disclosed in part	93	3,067	62	15,288	18	12703	32	67,933	1	10,485
All exempted	5	233	0	0	1	728	0	0	0	0
All excluded	1	7	0	0	0	0	0	0	0	0
Abandoned	49	102	3	872	3	2,117	3	6,555	1	17,382
Neither confirmed nor denied	0	0	0	0	0	0	0	0	0	0
Declined to act with the approval of the Information Commissioner	0	0	0	0	0	0	0	0	0	0
Total	192	4,457	73	17,639	28	19,437	39	81,156	2	27,867

4.5.3 Relevant minutes processed and disclosed for audio formats

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

4.5.4 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.

4.5.5 Relevant minutes processed and disclosed for video formats

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

4.5.6 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.

4.5.7 Other complexities

During the reporting period, the Department consulted other federal institutions 49 times and non-federal government organizations 57 times. The most frequently consulted institutions included Department of Justice, Public Safety, and Privy Council Office. Consultations with third parties were required in 516 instances with First Nations, organizations, and businesses. More than one institution can be consulted per request. Other complexities included requests with high profile subject matter, requests for contents of a database, and instances where records needed to be retrieved from other regions (Table 4.5.7).

Table 4.5.7 Other complexities
Disposition	Consultation required	Legal advice sought	Other	Total
All disclosed	10	0	20	30
Disclosed in part	98	17	59	174
All exempted	6	0	0	6
All excluded	0	1	0	1
Abandoned	5	0	20	25
Neither confirmed nor denied	0	0	0	0
Declined to act with the approval of the Information Commissioner	0	0	0	0
Total	119	18	99	236

4.6 Closed Requests

4.6.1 Number of requests closed within legislated timelines

The following section reports the number and percentage of requests closed within legislated timelines with or without extensions during the current reporting period. Overall, 245 requests, representing 58% of the 421 requests, were closed within the legislative timelines. Compliance has decreased with a 17% variance compared to the previous reporting period.

Table 4.6.1 Requests closed within legislated timelines
Number of requests closed within legislated timelines	245
Percentage of requests closed within legislated timelines (%)	58.19

4.7 Deemed refusals

4.7.1 Reasons for not meeting legislated timelines

During the reporting period, ISC did not respond within the statutory timelines on 176 occasions. The majority of deemed refusals (late) were a result of challenges in the Department's ability to retrieve records and process requests with existing resource levels. Other challenges experienced by the ATIP Office included: finding and hiring staff at junior levels for the Developmental Program meeting the basic requirements; large volume of records for a few files; and a large volume of files received in a short time frame, which contributed to surges in workload that was not manageable with existing resources. This receipt of Orders from the Information Commissioner also necessitated the reassignment of senior analysts and sector specialists. Additionally, external consultations with Indigenous organizations and other institutions create additional pressures. All of these factors affected the workload and overall performance for the Department.

Table 4.7.1 Reasons for not meeting legislated timelines
Number of requests closed past the legislated timelines	Principal Reasons
Number of requests closed past the legislated timelines	Interference with Operations / Workload	External Consultation	Internal Consultation	Other
176	114	44	5	13

4.7.2 Requests closed beyond legislated timelines (including any extension taken)

Requests closed beyond legislated timelines include files where an extension was requested. For the current reporting period the total number of closed requests that were deemed refusals (late) is broken down by the number of days that elapsed past the legislated timelines. During this reporting period 60 requests had no extensions applied and were closed beyond the legislated timelines. 116 requests applied extensions pursuant to section 9(1) of the Act and were closed beyond the legislated timelines.

Table 4.7.2 Requests 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
1 to 15 days	8	12
16 to 30 days	6	8
31 to 60 days	9	13
61 to 120 days	14	18
121 to 180 days	4	10
181 to 365 days	8	15
> 365 days	11	40
Total	60	116

4.8 Requests for translation

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

5. Extensions

5.1 Reasons for extensions and disposition of requests

With a workload of 675 formal access to information requests for 2023-2024, reflecting both requests received and carried over from previous fiscal year, a total of 324 extensions were applied pursuant to section 9(1) of the Act. The most prevalent reason for extending deadlines during this reporting period was for interference with operations (high workload) which was applied 201 times, representing 62% of all extensions. In addition, 13% (42 extensions) were taken due to necessary consultations with other departments and another 25% (81 extensions) due to necessary consultations with third-parties including but not limited to First Nations.

In cases where extensions were applied pursuant to section 9(1)(a), due to volume/interference, it resulted in a full or partial disclosure in 171 times. Where an extension was taken pursuant to either 9(1)(b) or 9(1)(c) due to necessary consultations, records were disclosed in full or in part in 111 out of 117 instances representing 95% (Table 5.1).

5.1 Reasons for extensions and disposition of requests
Disposition of Requests Where an Extension Was Taken	9(1)(a)	9(1)(b)		9(1)(c)
	Interference Operations / Workload	Consultation		Third-Party Notice
	Interference Operations / Workload	Section 69	Other	Third-Party Notice
All disclosed	29	0	2	4
Disclosed in part	142	7	30	68
All exempted	4	0	2	3
All excluded	0	0	0	0
Request abandoned	15	0	1	0
No records exist	11	0	0	0
Declined to act with the approval of the Information Commissioner	0	0	0	0
Total	201	7	35	81

5.2 Length of extensions

The majority of extensions, more specifically 282 extensions or 87%, requested and applied during the reporting period were for a length of time of 120 days or less (Table 5.2).

More than one type of extension may be taken for a single request. The number of extensions reported is not necessarily equal to the number of requests involved.

Table 5.2 Length of extensions
Length of extensions	9(1)(a)	9(1)(b)		9(1)(c)
	Interference Operations / Workload	Consultation		Third party notice
	Interference Operations / Workload	Section 69	Other	Third party notice
30 days or less	51	0	6	4
31 to 60 days	47	4	12	36
61 to 120 days	78	3	16	25
121 to 180 days	19	0	0	10
181 to 365 days	6	0	1	6
365 days or >	0	0	0	0
Total	201	7	35	81

6. Fees

The Service Fees Act requires a responsible authority to report annually to Parliament on the fees collected by the institution.

In accordance with the changes to the ATIA that came into force on June 21, 2019, ISC may only charge an application fee of $5, as set out in paragraph 7(1)(a) of the Regulations. Pursuant to section 11 of the ATIA, institutions can waive this application fee as deemed appropriate.

In November 2023, ISC made the decision to eliminate the $5 fee for all applicants when submitting a formal request under the ATIA for the purpose of advancing Indigenous reconciliation. As of December 1, 2023, this took effect meaning that all requests submitted to our department through the ATIP Online request portal no longer required payment.

With respect to fees collected under the ATIA, the information below is reported in accordance with the requirements of section 20 of the Service Fees Act.

Under the authority of the ATIA, prior to the decision to eliminate all application fees, the Department collected a $5 application fee for 219 requests, a total of $1,095 (Table 6). 144 requests did not require fees and therefore a total of $720.00 was not collected.

Fees Collected	Fees Waived
$1,095.00	$720.00

7. Consultations Received from other Institutions and Organizations

The Access to Information and Privacy Office communicates with other departments in order to ensure legislative timelines are met.

7.1 Consultations received from other Government of Canada institutions and organizations

The Department received 71 consultations from other government institutions for a total of 2,966 pages and 16 consultations from other organizations with another 1,358 pages to review. 12 files from the previous year were carried over, for a total of 99 consultations in 2023-2024 (Table 7.1a and Table 7.1b). A total of 92 consultations were completed, which included the review and release of 6,345 pages.

Consultation received from Other Government of Canada institutions are other government institutions subject to the Act and Other organizations includes provincial governments, territories, and municipalities in addition to consultations received from other countries.

Table 7.1a Consultation received and carried over from the previous reporting period from other Government of Canada institutions and organizations
Consultations	Other Government of Canada Institutions	Pages to Review	Other Organizations	Pages to Review
Received during reporting period	71	2,966	16	1,358
Outstanding from the previous reporting period	12	2,765	0	0
Total	83	5731	16	1358

Table 7.1b Consultation received from other Government of Canada institutions and organizations closed and carried over to next reporting period
Consultations	Other Government of Canada Institutions	Pages to Review	Other Organizations	Pages to Review
Closed during the reporting period	78	5,084	14	1,261
Carried over to next reporting period	5	647	2	97

7.2 Recommendations and completion time for consultations received from other Government of Canada institutions

In 2023-2024, of the 78 consultations completed for other Government of Canada institutions, 57 consultations or 73% were recommended by the Department for full disclosure (Table 7.2). 62 consultations or 79%, were completed within 60 days of their receipt. There were 9 occurrences or 12% where the Department required longer than 120 days to provide a response to their request.

**Table 7.2 Consultation and completion time for consultations received from other Government of Canada institutions**

	1 to 15	16 to 30	31 to 60	61 to 120	121 to 180	181 to 365
Disclose entirely	12	21	15	3	4	2
Disclose in part	3	3	4	1	1	0
Exempt entirely	0	1	0	1	1	0
Exclude entirely	0	0	0	0	0	0
Consult other institution	2	0	1	2	1	0
Other	0	0	0	0	0	0

7.3 Recommendations and completion time for consultations received from other organizations outside the Government of Canada

In 2023-2024, the Department received 16 new consultation requests from other organizations and a total of 14 consultations were closed in the course of the same period. Of the 14 consultations, 11 or 78% were recommended by the Department to be disclosed in their entirety as we had no objections to the release of the relevant records provided.

**Table 7.3 Recommendations and completion time for consultations received from other organizations**

	1 to 15	16 to 30	31 to 60	121 to 180
Disclose entirely	0	4	5	2
Disclose in part	1	1	0	0
Exempt entirely	0	0	1	0
Exclude entirely	0	0	0	0
Consult other institution	0	0	0	0
Other	0	0	0	0

8. Completion time of Consultations on Cabinet Confidences

This section provides details on the number of completed consultations during the current reporting period in regards to the application of Section 69 (cabinet confidences) of the Act. In some instances, a file may have required more than one consultation concerning the application of Section 69. For this reason, the number of consultations may not necessarily reflect the total number of closed requests where consultations on Section 69 were completed.

8.1 Requests with Legal Services

In 2023-2024, 18 consultations were sent for the application of Section 69 of the Act to the Departmental Legal Services Unit, due to possible Cabinet confidences (Table 8.1). A response was received within 60 days in 15 instances, with two (2) taking up to 120 days to obtain a response. A total of 206 pages were recommended to be disclosed.

Table 8.1 Requests with Legal Services
Number of Days	< 100 Pages Processed		100‒500 Pages Processed		501‒1,000 Pages Processed		1,001‒5,000 Pages Processed		> 5,000 Pages Processed
Number of Days	Requests	Pages Disclosed	Requests	Pages Disclosed	Requests	Pages Disclosed	Requests	Pages Disclosed	Requests	Pages Disclosed
1 to 15	3	14	0	0	0	0	0	0	0	0
16 to 30	1	0	0	0	0	0	0	0	0	0
31 to 60	12	84	0	0	0	0	0	0	0	0
61 to 120	2	108	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
> 365	0	0	0	0	0	0	0	0	0	0
Total	18	206	0	0	0	0	0	0	0	0

8.2 Requests with Privy Council Office

In 2023-2024, ISC did not send any consultation requests to the Privy Council Office.

9. Complaints and Investigations

A Complaint Coordinator has been identified who oversees the processing of complaints with the Office of the Information Commissioner (OIC) and tracks the progress made on complaints. Regular meetings are held with the OIC where the progress and status of complaint files are discussed for resolution. These meetings have assisted with the closing of numerous complaints files during the reporting period.

The annual statistical report requires institutions to identify sections of the ATIA under complaint (section 32, 30(5) 35 and 37).

Section 32 captures a new formal complaint from the OIC;
Section 30(5) captures when a complaint is discontinued or abandoned;
Section 35 requires the institution to make representations against a complaint to the OIC; and
Section 37 is the formal finding of the OIC and closure of the complaint.

9.1 Investigations

During the 2023-2024 reporting period, 40 new complaints were registered with the OIC. The ATIP office processed a total of 22,846 pages under complaint during this reporting period. A majority of complaints received were regarding requests in deemed refusal, having not met the legislated timelines to respond. The department received 23 notices pursuant to subsection 30(5), ceased to investigate and 2 (two) request pursuant to section 35 Formal Representations.

Table 9.1 Investigations
Section 32 Notice of intention to investigate	SubSection 30(5) Ceased to investigate	Section 35 Formal Representations
40	23	2

9.2 Reports of findings

During the current reporting period, the Department worked with the OIC to successfully close 41 complaints. Of the 41 closed complaints, the department received the initial reports for 2 (two) reports and 2 (two) final reports. The additional 37 complaints did not require a report of findings due to having received an early resolution or cease to investigate notice from the OIC.

Table 9.2 Reports of findings
Section 37(1) Initial Reports			Section 37(2) Final Reports
Received	Containing recommendations issued by the Information Commissioner	Containing orders issued by the Information Commissioner	Received	Containing recommendations issued by the Information Commissioner	Containing orders issued by the Information Commissioner
2	0	2	2	0	2

10. Court Action

One application was filed before the Federal Court pursuant to section 41 of the Act during the 2023- 2024 reporting period.

11. Resources related to the Access to Information Act

11.1 Allocated Costs

In 2023-2024, ISC spent a total of $2,058,891 on staffing, overtime, and, goods and services. Of this total, $667,426 was spent for goods and services which included the purchase of a new case management system, developmental training for employees, and professional services contracts. These amounts reflect the level of effort in support of ISC's responsibilities pursuant to the Act (Table 11.1).

Table 11.1 Allocated Costs
Expenditures	Amount
Salaries	$1,340,223
Overtime	$51,242
Goods and Services
Professional services contracts	$477,053
Other	$190,373
Total Goods and Services	$667,426
Total	$2,058,891

11.2 Human Resources

In 2023-2024, ISC allocated a total 15.056 full time employees (FTE), including the services of two consultants and a casual employee, through the course of the reporting period (Table 11.2).

roman numeral 5. Monitoring Compliance

The ATIP Office does weekly, monthly, quarterly and ad hoc reporting on all aspects of ATIP Operations and compliance with all levels of staff. During the reporting period there were weekly meetings with Minister's Office, Deputy Minister's Office, Parliamentary Affairs and Communications in order to present the incoming and outgoing requests. Monthly statistical reporting of ATIP Operations is completed and presented to the Corporate Secretary, as well as quarterly reporting on the compliance of sectors and regions that were tasked to retrieve or review records. The Director of ATIP meets on an ad hoc basis to discuss non-compliance with the sector heads. The System Administrator is responsible for all reporting functions including the time taken to process access to information requests and Operations Unit compliance.

All levels of analysts prepare consultations with other government departments, however a Team Leader will review and send the consultation only when there is an intention to disclose in order to limit inter-institutional consultations. Discretion is appropriately exercised and reviewed by a Team Leader each time a consultation is required.

When a request is received by the Intake Unit, a search is done to ensure that the request is unique or novel. Duplicate or similar requests are offered informally to improve access. For frequently requested types of information, the Intake Unit maintains an evergreen list of topics and subjects for ease of reference. This process repeated for each request received to reduce the workload of the Operations unit and sectors, thereby easing the burden on the Department as a whole and improving access for the public.

The ATIP Office has included contracts, information sharing agreements and information sharing arrangements in its process for publishing of programs and activities, and the information holdings related to programs and activities, of government institutions (InfoSource).

roman numeral 6. Training and Awareness

During the reporting period, the ATIP Office provided ATIP 101 and 102 training sessions consisting of ATIP awareness and information and specific ATIP Liaison Officer training, respectively. These training sessions provide general ATIP information such as purpose of the Access to Information and Privacy Acts, history, as well as general applications of the Acts. Included is departmental specific information, such as most commonly applied exemptions and information on working effectively with Indigenous partners. The ATIP Liaison Officer training addresses common practices and processes for each sector, compliance and internal service standards. In addition to these training sessions, the ATIP Office meets bi-yearly with ATIP Liaison Officers for a Town Hall session in order to establish open and transparent communication with our internal partners. This past fiscal year, a total of 160 ISC staff were trained in ATIP 101 and 102 sessions.

Ad hoc training sessions are often provided by ATIP Team Leaders and the Deputy Directors with all levels of staff, including but not limited to, senior management, Deputy Minister's and Minister's offices. These sessions range from ATIP awareness sessions, informal briefings on the Acts or a topics of interest related to ATIP. One-on-one training sessions are also done with senior manager and the Director and Deputy Directors. These types of training and awareness is to ensure consistency with the application of the Acts and create open and transparent dialogue within the Department

roman numeral 7. Policies, Guidelines, and Procedures

The ATIP Office strives to update their internal policies and procedures in order to comply with new Treasury Board of Canada directives and policies. This past fiscal year, the ATIP Office updated their Proactive Publication procedures in order to streamline the process. Due to the influx of orders received by the Office of the Information Commissioner of Canada, the process for informing the Deputy Minister and responding to orders were updated. Guidelines for dealing with medical files, simple privacy requests, and day school requests were also updated during this reporting period. The ATIP Manual, consisting of all policies and procedures within the unit, was also updated. Procedures that were updated include: Closing of Requests; Complaints Procedure; Informal Requests chapters; and Release Chart Procedures.

Proactive Publication

roman numeral 8. Proactive Publication under Part 2 of the ATIA

Proactive publication is a department wide effort with contributions from multiple sectors across both ISC and CIRNAC, including the Corporate Secretariat, Human Resources and Workplace Services, and the Chief Finances, Results and Delivery Officer sector. Certain publications such as briefing binders, briefing note title lists, and packages of briefing material are reviewed by the ATIP office prior to publication. The table below outlines each legislative requirement, section of the Act, publication timeline, the link to the publication, and the overall compliance for the 2023-2024 year (Table 12.1).

Table 12.1a Proactive Publication Requirements: All Government Institutions as defined in Section 3 of the Access to Information Act
Legislative Requirement	Section	Publication Timeline	Link to Publication	Compliance %	Institutional Requirement
Travel Expenses	82	Within 30 days after the end of the month of reimbursement	Government Travel Expenses \| Open Government - Government of Canada	90%	Y
Hospitality Expenses	83	Within 30 days after the end of the month of reimbursement	Government Hospitality Expenses \| Open Government - Government of Canada	90%	Y
Reports tabled in Parliament	84	Within 30 days after tabling	Reports \| Open Government Portal	100%	Y

Table 12.1b Proactive Publication Requirements: Government entities or Departments, agencies, and other bodies subject to the Act and listed in Schedules I, I.1, or II of the Financial Administration Act
Legislative Requirement	Section	Publication Timeline	Link to Publication	Compliance %	Institutional Requirement
Contracts over $10,000	86	Q1-3: Within 30 days after the quarter, Q4: Within 60 days after the quarter	Search Government Contracts over $10,000	100%	Y
Grants & Contributions over $25,000	87	Within 30 days after the quarter	Grants and Contributions	100%	Y
Packages of briefing materials prepared for new or incoming deputy heads or equivalent	88(a)	Within 120 days after appointment	N/A	N/A	Y
Titles and reference numbers of memoranda prepared for a deputy head or equivalent, that is received by their office	88(b)	Within 30 days after the end of the month received	Briefing Note Titles and Numbers	100%	Y
Packages of briefing materials prepared for a deputy head or equivalent's appearance before a committee of Parliament	88(c)	Within 120 days after appearance	Committee Appearances - Briefing Documents	100%	Y

Table 12.1c Proactive Publication Requirements Government institutions that are departments named in Schedule I to the Financial Administration Act or portions of the core public administration named in Schedule IV to that Act
Legislative Requirement	Section	Publication Timeline	Link to Publication	Compliance %	Institutional Requirement
Reclassification of positions	85	Within 30 days after the quarter	Search Government Position Reclassifications \| Open Government - Government of Canada	50%	Y

Table 12.1d Proactive Publication Requirements: Ministers
Legislative Requirement	Section	Publication Timeline	Link to Publication	Compliance %	Institutional Requirement
Packages of briefing materials prepared by a government institution for new or incoming ministers	74(a)	Within 120 days after appointment	Briefing documents	N/A	Y
Titles and reference numbers of memoranda prepared by a government institution for the minister, that is received by their office	74(b)	Within 30 days after the end of the month received	Briefing Note Titles and Numbers	100%	Y
Package of question period notes prepared by a government institution for the minister and in use on the last sitting day of the House of Commons in June and December	74(c)	Within 30 days after last sitting day of the House of Common in June and December	Question Period Notes	100%	Y
Packages of briefing materials prepared by a government institution for a minister's appearance before a committee of Parliament	74(d)	Within 120 days after appearance	Committee Appearances - Briefing Documents	100%	Y
Travel Expenses	75	Within 30 days after the end of the month of reimbursement	Government Travel Expenses \| Open Government - Government of Canada	57%	Y
Hospitality Expenses	76	Within 30 days after the end of the month of reimbursement	Government Hospitality Expenses \| Open Government - Government of Canada	57%	Y
Contracts over $10,000	77	Q1-3: Within 30 days after the quarter Q4: Within 60 days after the quarter	Search Government Contracts over $10,000	100%	Y
Ministers' Offices Expenses	78	Within 120 days after the fiscal year	N/A	N/A	N
*Note: This consolidated report is currently published by TBS on behalf of all institutions.

Highlights

roman numeral 9. 2023-2024 Points of Interest

Since November 30, 2017, the ATIP Office has administered the Access to Information Act as a shared service for both Indigenous Services Canada (ISC) and Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC). This past fiscal year (2023-2024) was the sixth full year of reporting for Indigenous Services Canada under the ATIA and PA.

The Department received 363 ATIA requests and closed 421. It processed 150,556 pages of records under the legislation and carried over 254 files into the new fiscal year (2024-2025).

During this reporting period, there was a considerable increase in the number of requesters who identified themselves as members of the public, which represents 30% of the requests received and a sharp decrease in those requesters that "decline to identify". Requesters self identifying as businesses and media followed at 26% and then 23%, respectively.

In addition, 87 requests for consultation were received from other federal institutions and organizations with a total page count of 6,345 pages processed.

Furthermore, the Department completed 737 informal requests in the course of the 2023-2024 reporting period. This is an increase of 41% from the previous fiscal year where 435 informal request were completed.

The majority of exemptions applied pursuant to the ATIA were subject to section 20 (third party information). The second most applied exemption was section 21(1) (advice or deliberations) and the third was section 19(1) (personal information).

Extensions were requested beyond 30 days, pursuant to Section 9(1)(a) of ATIA, for interference with operations, due to the increase demand on the ATIP Office and the Department and associated workloads.

The Department received 40 complaints from the Office of the Information Commissioner, closed 41 and processed 22,846 pages under complaints.

Pursuant Bill C-58, and the amendments to the ATIA which added a requirement for mandatory proactive publication of specific information produced by government institutions, the Department has remained compliant and continues to ensure publication of all required documents either on the departmental website or Open Canada.

During the fiscal year, the ATIP office provided recommendations to sectors concerning the proactive disclosure of their documents. A total of 32 files were processed and 2,992 pages were reviewed.

ATIP Office also trained a total of 160 employees on the ATIA and the Privacy Act (PA) in 2023-2024.

The ATIP Office continuously monitors progress on all ATIA request files. Reports are prepared monthly to ensure compliance with legislative timelines so that risks can be mitigated. Each quarter reports are produced on the Department's performance in meeting legislative time frames and these are shared with senior management.

In December, 2023, the Department took the initiative to waive all fees for incoming Access to Information requests to remove existing barriers to access for Indigenous requesters.

In 2023-2024, ISC spent a total of $2,058,891 on staffing and goods and services in support of the ATIA. This includes the purchase of a new case management system.

A total of 17.289 people were dedicated to Access to Information Activities. This included 15 full time employees (FTE), 0.278 casual employees, 2 (two) consultants to help reduce backlog files.

Annex A

Order of Delegation of the Access to Information 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

Annex B: Statistical Report on the Access to Information Act

Name of institution: Indigenous Services Canada
Reporting period: 4/1/2023 to 3/31/2024