Annual Report - Privacy Act, 2020-2021

Title: Privacy Act – The Right to Know! Annual Report, 2020-2021

Introduction
Organizational structure
Delegation Order
Highlights of the statistical report

Time limitations
Extensions
Consultations received from other institutions and organizations
Impact of Covid-19 and mitigation measures
Formal/informal interface

Training and Awareness
Policies, Guidelines, Procedures and Initiatives
Summary of Key Issues and Actions Taken on Complaints
Monitoring Compliance
Material Privacy Breaches
Privacy Impact Assessments
Public Interest Disclosures
2020-2021 Statistical Report on the Privacy Act

Introduction

The Privacy Act protects the privacy of individuals with respect to personal information about themselves held by a government institution and provides individuals with a right of access to that information.

This report has been prepared and will be tabled in Parliament in accordance with Section 72 of the Privacy Act. The information contained in this report pertains to the administration of the Privacy Act within the Parks Canada Agency.

The Parks Canada Agency’s mandate is to protect and present nationally significant examples of Canada’s natural and cultural heritage and to foster public understanding, appreciation and enjoyment in ways that ensure their ecological and commemorative integrity for present and future generations. The Agency is responsible for operations under multiple pieces of federal legislation and protects approximately 450 000 km² of Canada’s terrestrial, marine and freshwater ecosystems. It is the steward of 47 national parks, one national urban park, four national marine conservation areas and 171 national historic sites, including nine heritage canals. The Agency is highly decentralized with team members located across the country and often in remote areas.

Organizational Structure

Parks Canada’s Access to Information and Privacy Office is comprised of six (6) full-time employees. Internal policies and procedures have been developed in order to meet its obligations in compliance with the Privacy Act, regulations and Treasury Board policies, and those continue to be improved on a regular basis.

Parks Canada did not enter in any service agreements under section 73.1 of the Privacy Act during the reporting period.

Delegation Order

Arrêté sur la délégation en vertu de la Loi sur l'accès à l'information et de la Loi sur la protection des renseignements personnels	Access to Information Act and Privacy Act Delegation Order
En vertu de l'article 95 de la Loi sur l'accès à l'information et de l'article 73 de la Loi sur la protection des renseignements personnels, le directeur général et président de l'Agence Parcs Canada délègue aux titulaires de postes mentionnés à l'annexe ci-après, ainsi qu'aux personnes occupant à titre intérimaire lesdits postes, les attributions dont il est, en qualité de responsable de l'Agence Parcs Canada, désigné par le Décret sur la désignation des responsables d'institutions fédérales (Loi sur l'accès à l'information) et le Décret sur la désignation des responsables d'institutions fédérales (Loi sur la protection des renseignements personnels), investi par les articles de ces lois mentionnés en regard de chaque poste. Le présent arrêté sur la délégation remplace et annule tout arrêté sur la délégation pris précédemment.	The Chief Executive Officer and President of the Parks Canada Agency, pursuant to section 95 of the Access to Information Act and the section 73 of the Privacy Act and his capacity as the head of the Parks Canada Agency designated by the Access to Information Act Heads of the Government Institutions Designation Order and the Privacy Act Heads of Government Institutions Delegation Order, hereby designates the persons holding the positions set out in the schedule hereto, or the persons occupying on an acting basis those positions, to exercise the powers and functions pursuant to the provisions of the aforementioned Acts set out in the schedule below opposite each position. This Delegation Order replaces any delegation order made previously.
Daté, à la Ville de Gatineau, ce 26e jour de mars 2020	Dated, at the City of Gatineau, this 26th day of March, 2020
L'original a été signé par Ron Hallman Président et Directeur général, Agence Parcs Canada	Original signed by Ron Hallman President & Chief Executive Officer, Parks Canada Agency

Annexe / Schedule
Poste / Position	Loi sur l'accès à l'information et règlements / Access to information Act and Regulations	Loi sur la protection des renseignements personnels et règlements / Privacy Act and Regulations
Vice-Président, Direction générale des relations externes et de l'expérience du visiteur / Vice-President, External Relations and Visitor Experience Directorate	Autorité absolue / Full authority	Autorité absolue / Full authority
Gestionnaire, Bureau de l'Accès à l'information et à la protection des renseignements personnels (AIPRP) / Manager, Access to Information and Privacy (ATIP) Office	Autorité absolue / Full authority	Autorité absolue / Full authority
Analyste principal (PM-05) / Senior analyst (PM-05)	Articles 7 et 9 de la Loi sur l'accès à l'information / Sections 7 and 9 of the Access to Information Act	Articles 14 et 15 de la Loi sur la protection des renseignements personnels / Sections 14 and 15 of the Privacy Act

Highlights of the statistical report

The following report presents an overview of activities carried out within the Agency during the reporting period of April 1, 2020 to March 31, 2021. The Statistical Report (Appendix A) contains detailed statistics on the information requests processed under the Privacy Act.

Twenty (20) personal information requests were received under the Privacy Act. One request was carried over to next reporting period.

One (1) requests was fully disclosed, fifteen (15) requests resulted in the partial disclosure of the records. Four (4) requests had no records in response to them and one (1) request was abandoned.

The following is a percentage breakdown by disclosure types for privacy requests processed in 2020-2021:

5%	All disclosed
71%	Disclosed in part
19%	No records located
5%	Requests abandoned

Time limitations

100% of requests were processed within legislated timelines.

Extensions

Section 15 of the Privacy Act permits the statutory time limits to be extended if consultations are necessary, if translation is required or if the request is for a large volume of records and processing it within the original time limit would unreasonably interfere with the operations of the institution.

Parks Canada invoked a total of eight (8) extensions during the 2020-21 reporting period. Of these, seven (7) were deemed necessary to process a large volume of records and one (1) was extended to consult with another institution prior to responding.

Multi-year trend

In the last three (3) years, since fiscal year 2017-2018, there has been a 55% increase in the number of privacy requests received.

Consultations received from other institutions and organizations

The Agency did not receive any consultation requests under the Privacy Act. No consultations were carried forward from the previous reporting period and no consultations were carried forward to the next reporting period.

Impact of Covid-19 and mitigation measures

Exceptional measures have been taken by Parks Canada to support the government's response to COVID-19. The Agency reacted quickly to the Covid-19 challenge. ATIP staff have continued processing requests while working remotely since March 16, 2020.

Initially, due to Agency sites being closed, network access challenges and the shift to telework, some officials had limited to no access to their offices to obtain requested paper records meaning some delays in receiving documents by the ATIP Office. The Agency worked diligently to provide service to clients, and communicated with its clients clearly during the challenge that delays may be possible during the processing of their requests. Despite these challenges, 100 percent of requests were responded to within legislated timelines.

The ATIP Office mitigated potential operational impacts by switching to processing all documents electronically and by receiving electronic submissions on shared drives and importing them into the case management system. The ATIP Office also began delivery of responses electronically via epost connect.

Formal/informal interface

The Agency provides the public with information on an informal basis. Information is provided only when the Agency is satisfied that the information requested concerns the individual making the request or where at least one of the conditions outlined in subsection 8(2) of the Act is met.

ATIP Office also reviews human resources investigation reports and provides strategic advice on human resource issues.

Training and Awareness

Facilitating efficient and transparent access to information and personal information for Canadians is a priority for Parks Canada.

Ten (10) training sessions were given to Agency employees across Canada in 2020-2021. In total, two hundred and twenty-four (224) employees attended these sessions.

To ensure that all employees of the Agency are aware of the legislation and their obligations, general awareness sessions are also given periodically to provide basic information on the provisions of the Privacy Act. Furthermore, there is a comprehensive section on Access to Information and Privacy on the Parks Canada’s Intranet site that is available to all employees.

Policies, Guidelines, Procedures and Initiatives

During the reporting period, the ATIP Office was continuously ensuring that its policies and procedures for processing requests made pursuant to the Privacy Act were up to date and that adjustments were made to areas where the need for improvement was identified.

The ATIP Office has added a full-time resource to its team to analyze privacy management and provide recommendations to programs responsible for the national parks and national marine and conservation areas systems that provide many of Parks Canada's visitor services and activities. This allows for the establishment of consistent and compliant privacy governance processes to support effective decision making on privacy issues.

Summary of Key Issues and Actions Taken on Complaints

No complaints were filed with the Office of the Privacy Commissioner of Canada during the reporting period under review. There have been no audits or investigations.

Monitoring Compliance

The Agency monitors the time required to process personal information requests. When the need for improvements are identified, internal processes are adjusted. No requests for correction of personal information were received during the reporting period.

Material Privacy Breaches

There were no material privacy breaches reported to the Office of the Privacy Commissioner and to the Information and Privacy Policy Division, Treasury Board of Canada Secretariat during this period.

Privacy Impact Assessments

Between April 1, 2020 and March 31, 2021, four (4) privacy impact assessments were still underway and are scheduled to be completed in the future.

Public Interest Disclosures

There were no disclosures of personal information made pursuant to 8(2)(m) of the Privacy Act during the reporting period.

2020-2021 Statistical Report on the Privacy Act

Name of institution:Parks Canada Agency

Reporting period: 2020-04-01 to 2021-03-31

Section 1: Requests Under the Privacy Act

1.1 Number of requests

	Number of Requests
Received during reporting period	20
Outstanding from previous reporting period	1
Total	21
Closed during reporting period	21
Carried over to next reporting period	0

Section 2: Requests Closed During the Reporting Period

2.1 Disposition and completion time

Disposition of Requests	Completion Time
Disposition of 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
All disclosed	1	0	0	0	0	0	0	1
Disclosed in part	2	5	8	0	0	0	0	15
All exempted	0	0	0	0	0	0	0	0
All excluded	0	0	0	0	0	0	0	0
No records exist	4	0	0	0	0	0	0	4
Request abandoned	1	0	0	0	0	0	0	1
Neither confirmed nor denied	0	0	0	0	0	0	0	0
Total	8	5	8	0	0	0	0	21

2.2 Exemptions

Section	Number of Requests	Section	Number of Requests	Section	Number of Requests
18(2)	0	22(1)(a)(i)	1	23(a)	0
19(1)(a)	0	22(1)(a)(ii)	0	23(b)	0
19(1)(b)	0	22(1)(a)(iii)	0	24(a)	0
19(1)(c)	1	22(1)(b)	4	24(b)	0
19(1)(d)	0	22(1)(c)	0	25	0
19(1)(e)	0	22(2)	0	26	14
19(1)(f)	0	22.1	0	27	2
20	0	22.2	0	27.1	0
21	0	22.3	0	28	0
		22.4	0

2.3 Exclusions

Section	Number of Requests	Section	Section
69(1)(a)	0	70(1)	70(1)(d)
69(1)(b)	0	70(1)(a)	70(1)(e)
69.1	0	70(1)(b)	70(1)(f)
		70(1)(c)	70.1

2.4 Format of information released

Paper	Electronic	Other
2	14	0

2.5 Complexity

2.5.1 Relevant pages processed and disclosed

Number of Pages Processed	Number of Pages Disclosed	Number of Requests
9223	8212	17

2.5.2 Relevant pages processed and disclosed 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
Disposition	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
All disclosed	1	2	0	0	0	0	0	0	0	0
Disclosed in part	2	125	4	514	7	4234	2	3337	0	0
All exempted	0	0	0	0	0	0	0	0	0	0
All excluded	0	0	0	0	0	0	0	0	0	0
Request abandoned	1	0	0	0	0	0	0	0	0	0
Neither confirmed nor denied	0	0	0	0	0	0	0	0	0	0
Total	4	127	4	514	7	4234	2	3337	0	0

2.5.3 Other complexities

Disposition	Consultation Required	Total
All disclosed	0	0
Disclosed in part	3	3
All exempted	0	0
All excluded	0	0
Request abandoned	0	0
Neither confirmed nor denied	0	0
Total	3	3

2.6 Closed requests

2.6.1 Number of requests closed within legislated timelines

	Requests closed within legislated timelines
Number of requests closed within legislated timelines	21
Percentage of requests closed within legislated timelines (%)	100

2.7 Deemed refusals

2.7.1 Reasons for not meeting legislated timelines

Number of Requests Closed Past the Legislated Timelines	Principal Reason
Number of Requests Closed Past the Legislated Timelines	Interference with Operations / Workload	External Consultation	Internal Consultation	Other
0	0	0	0	0

2.7.2 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 Timelines Where an Extension Was Taken	Total
1 to 15 days	0	0	0
16 to 30 days	0	0	0
31 to 60 days	0	0	0
61 to 120 days	0	0	0
121 to 180 days	0	0	0
181 to 365 days	0	0	0
More than 365 days	0	0	0
Total	0	0	0

2.8 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 3: Disclosures Under Subsections 8(2) and 8(5)

Paragraph 8(2)(e)	Paragraph 8(2)(m)	Subsection 8(5)	Total
0	0	0	0

Section 4: Requests for Correction of Personal Information and Notations

Disposition for Correction Requests Received	Number
Notations attached	1
Requests for correction accepted	0
Total	1

Section 5: Extensions

5.1 Reasons for extensions and disposition of requests

Number of requests where an extension was taken	15(a)(i) Interference with operations				15 (a)(ii) Consultation			15(b) Translation purposes or conversion
Number of requests where an extension was taken	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	15(b) Translation purposes or conversion
8	0	7	0	0	0	1	0	0

5.2 Length of extensions

Length of Extensions	15(a)(i) Interference with operations				15 (a)(ii) Consultation			15(b) Translation purposes or conversion
Length of Extensions	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	15(b) Translation purposes or conversion
1 to 15 days	0	0	0	0	0	0	0	0
16 to 30 days	0	7	0	0	0	1	0	0
31 days or greater								0
Total	0	7	0	0	0	1	1	0

Section 6: Consultations Received From Other Institutions and Organizations

6.1 Consultations received 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
Closed during the reporting period	0	0	0	0
Carried over to the next reporting period	0	0	0	0

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

Recommendation	Number of Days Required to Complete Consultation Requests
Recommendation	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	0	0	0	0	0	0	0	0
Disclosed in part	0	0	0	0	0	0	0	0
All exempted	0	0	0	0	0	0	0	0
All excluded	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

6.3 Recommendations and completion time for consultations received from other organizations

Recommendation	Number of Days Required to Complete Consultation Requests
Recommendation	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	0	0	0	0	0	0	0	0
Disclosed in part	0	0	0	0	0	0	0	0
All exempted	0	0	0	0	0	0	0	0
All excluded	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 7: Completion Time of Consultations on Cabinet Confidences

7.1 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 Days	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

7.2 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 Days	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 8: Complaints and Investigations Notices Received

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

Section 9: Privacy Impact Assessments (PIA) and Personal Information Banks (PIB)

9.1 Privacy Impact Assessments

Number of PIA(s) completed

9.2 Personal Information Banks

Personal Information Banks	Active	Created	Terminated	Modified
	0	0	0	0

Section 10: Material Privacy Breaches

Number of material privacy breaches reported to TBS	0
Number of material privacy breaches reported to OPC	0

Section 11: Resources Related to the Privacy Act

11.1 Costs

Expenditures		Amount
Salaries		$87 053
Overtime		$0
Goods and Services		$0
• Professional services contracts	$0
• Other	$0
Total		$87 053

11.2 Human Resources

Resources	Person Years Dedicated to Privacy Activities
Full-time employees	1.000
Part-time and casual employees	0.000
Regional staff	0.000
Consultants and agency personnel	0.000
Students	0.000
Total	1.000

Organizational contact information

Parks Canada National Office
30 Victoria Street
Gatineau, Quebec
Canada
J8X 0B3

Email: information@pc.gc.ca

Telephone:888-773-8888 (General inquiries)

Telephone — international:819-420-9486 (General inquiries — international)

Parks Canada Agency