Access to Information Act — Annual Report — April 1, 2015, to March 31, 2016

Table of contents

• Introduction
• Part I — General information on the Public Service Commission of Canada
  • 1. Raison d'être and mandate
  • 2. Strategic outcome and Program Alignment Architecture
• Part II — Report on the Access to Information Act
  • 1. Organization of Delegation and Activities
    • 1.1 Delegation order
    • 1.2 The Access to Information and Privacy Coordinator
    • 1.3 The Access to Information and Privacy Directorate
    • 1.4 Access to Information and Privacy liaison officers
  • 2. Statistical Report: Interpretation
    • 2.1 Requests under the Access to Information Act
    • 2.2 Nature of requests
    • 2.3 Inter-organizational consultations
    • 2.4 Informal requests
    • 2.5 Disposition of requests completed
    • 2.6 Exemptions invoked
    • 2.7 Exclusions invoked
    • 2.8 Extension of time limits
    • 2.9 Completion time
    • 2.10 Translation
    • 2.11 Format of information released
    • 2.12 Fees
    • 2.13 Costs
  • 3. Summary of Access to Information and Privacy Directorate activities
    • 3.1 Development of policies, directives, guidelines and other key documents
    • 3.2 Advice and training
    • 3.3 Tracking system and imaging software
  • 4. Complaints
    • 4.1 Number of complaints
    • 4.2 Nature of complaints
    • 4.3 Complaints closed
• Annex A — Delegation Instrument
• Annex B — 2015–2016 Annual Access to Information Act Statistical Report
• Appendix I — Historical Comparisons

Introduction

The Access to Information Act (Revised Statutes of Canada, Chapter A-1, 1985) came into force on July 1, 1983. It was amended as a result of the Royal Assent of the Federal Accountability Act on December 12, 2006. Certain provisions came into force on December 12, 2006 and others took effect on April 1, 2007 and September 1, 2007.

The Access to Information Act (the Act) gives Canadian citizens and individuals present in Canada a broad right of access to information contained in government records, subject to certain specific and limited exceptions.

Section 72 of the Act requires that the head of every federal government institution prepare an Annual Report, for submission to Parliament, on the administration of the Act within the institution. Every report shall be laid before each House of Parliament within three months after the financial year in respect of which it is made or, if that House is not then sitting, on any of the first 15 days next thereafter that it is sitting.

This Annual Report provides a summary of the management and administration of the Act within the Public Service Commission of Canada (PSC) for the fiscal year 2015–2016.

The PSC’s Access to Information Act Annual Report is also available on the PSC website.

Part I — General Information on the Public Service Commission of Canada

1. Raison d'être and mandate^{Footnote 1} 

Raison d'être

The mandate of the Public Service Commission (PSC) is to promote and safeguard merit-based appointments and, in collaboration with other stakeholders, to protect the non-partisan nature of the public service. The PSC reports independently on its mandate to Parliament.

Under the delegated staffing system set out in the Public Service Employment Act (PSEA), the PSC fulfills its mandate by providing policy guidance and expertise as well as by conducting effective oversight. In addition, the PSC delivers innovative staffing and assessment services.

Responsibilities

The PSC is responsible promoting and safeguarding merit-based appointments that are free from political influence and, in collaboration with other stakeholders, for protecting the non-partisan nature of the public service.

The PSC is mandated to:

• Make appointments to and within the public service, based on merit and free from political influence. The PSEA provides the authority to the Commission to delegate to deputy heads its authority to make appointments to positions in the public service. This authority is currently delegated to the deputy heads subject to the PSEA, across the federal government.
• Administer the provisions of the PSEA that are related to the political activities of employees and deputy heads. Part 7 of the PSEA recognizes the right of employees to engage in a political activity, while maintaining the principle of political impartiality in the public service. It also sets out specific roles and responsibilities related to political activities for employees and for the PSC; and
• Oversee the integrity of the staffing system and, in collaboration with other stakeholders, ensure non-partisanship. This oversight role includes: The regulatory authority and policy-setting function, the ongoing support and guidance and the monitoring of the staffing performance of delegated organizations, the conduct of audits that provide an independent assessment of the performance and management of staffing activities and the conduct of investigations of staffing processes and improper political activities by public servants.

2. Strategic outcome and Program Alignment Architecture

The PSC Program Alignment Architecture consists of one strategic outcome and four programs.

Public Service Commission strategic outcome

To provide Canadians with a highly competent, non-partisan and representative public service, able to provide service in both official languages, in which appointments are based on merit and the values of fairness, access, transparency and representativeness.

Program activity — Staffing System Integrity and Political Impartiality

The Staffing System Integrity and Political Impartiality program is focused on independently safeguarding merit and non-partisanship in the federal public service. This program includes developing and advancing strategic policy positions and directions; conducting policy research; establishing PSC policies and standards; providing advice, interpretation and guidance; and administering delegated and non-delegated authorities, including official languages, the political activities regime and Priority Administration.

Program activity — Staffing Services and Assessment

The Staffing Services and Assessment program maintains the systems that link Canadians and public servants seeking employment opportunities in the federal public service with hiring departments and agencies. It provides assessment-related products and services in the form of research and development, consultation, assessment operations and counselling for use in recruitment, selection and development throughout the federal public service. This program also includes delivering staffing services, programs and products to departments and agencies, to Canadians and public servants, through client service units located across Canada.

Program activity — Oversight of Integrity in Staffing and of Non-partisanship

The Oversight of Integrity in Staffing and of Non-partisanship program provides an accountability regime for the implementation of the Appointment Policy and regulatory framework for safeguarding the integrity of public service staffing and ensuring staffing is free from political influence. This program includes monitoring departments' and agencies' staffing performance and compliance with legislative requirements, conducting audits and studies, carrying out investigations and reporting to Parliament on the integrity of public service staffing and the non-partisanship of the public service.

Program activity — Internal Services

Internal Services are groups of related activities and resources that support the needs of programs and other corporate obligations of an organization. Internal Services includes only those activities and resources that apply across an organization and not those provided to a specific program. The services are:

• Management and Oversight;
• Communications;
• Legal;
• Human Resources Management;
• Financial Management;
• Information Management;
• Information Technology;
• Real Property;
• Materiel; and
• Acquisition.

Part II — Report on the Access to Information Act

1. Organization of delegation and activities

1.1 Delegation order

Under section 3 of the Access to Information Act (the Act), the President of the Public Service Commission (PSC) is designated as the head of the government institution for the administration of the Act.

Pursuant to section 73 of the Act, deputy heads may delegate any of their powers, duties or functions under the Act by signing an order authorizing one or more officers or employees of the institution, who are at the appropriate level, to exercise or perform the powers, duties or functions of the head specified in the order.

The powers, duties and functions of the PSC President, under the Act, are delegated to the Director of Access to Information, Privacy and Transition Projects, who is the PSC’s Access to Information and Privacy (ATIP) coordinator (see Annex A — Delegation Instrument).

1.2 The Access to Information and Privacy Coordinator

The ATIP coordinator is responsible and accountable for the development, coordination and implementation of effective policies, guidelines, systems and procedures to enable the efficient processing of requests under the Access to Information Act and the Privacy Act.

The coordinator is also responsible for the development, coordination and implementation of policies, systems and procedures that are required by both Acts as well as Treasury Board of Canada policies and directives. The activities of the coordinator include:

• Processing requests made under both Acts;
• Acting as spokesperson for the PSC in dealings with Treasury Board Secretariat (TBS), the Office of the Information Commissioner (OIC) and other government departments and agencies on matters related to the Act;
• Responding to consultation requests submitted by other federal institutions for PSC documents;
• Reviewing information collection in accordance with the Communications Policy of the Government of Canada and the Procedures for the Management of Public Opinion Research;
• Preparing the Annual Report to Parliament and other statutory reports, as well as other material that may be required by central agencies;
• Promoting awareness and providing advice to PSC employees to ensure responsiveness to the obligations of both acts, TBS policies and their impact on various program initiatives; and
• Monitoring the PSC's compliance with both Acts, Regulations and relevant policies and procedures.

1.3 The Access to Information and Privacy Directorate

The Access to Information and Privacy Directorate (the Directorate) supports the ATIP Coordinator in administering the provisions of the Acts and related TBS policies for the PSC. The Directorate is comprised of a manager and two analysts. Due to an extreme increase in requests during the course of this reporting period, the Directorate hired three consultants and one casual employee to assist with the processing of official requests. The Directorate also received ad hoc support from the Finance and Administration Directorate for updating Info Source.

The analysts are responsible for processing Access to Information Act and Privacy Act consultations and requests, preparing responses to complaints, reviewing the PSC’s Info Source chapter and supporting all other ATIP responsibilities.

The Directorate updates its intranet site on a regular basis and uses it as the primary vehicle for communicating with PSC employees. In addition, the Directorate delivers training sessions for PSC employees.

The Directorate also reviews policies and procedures to improve the support it provides to its branch liaison officers and promote a better understanding of their roles, responsibilities and obligations related to the processing of requests under both Acts.

1.4 Access to Information and Privacy liaison officers

The Directorate processes requests with the assistance of ATIP liaison officers who are employees knowledgeable of their branch's activities. There is one liaison officer and one back-up for each branch as well as for the Corporate Secretariat. In addition to acting as the point of contact between their branch and the Directorate, ATIP liaison officers are responsible for:

• Tasking the appropriate program experts within their branch to search for relevant records;
• Advising if there are other offices of primary interest;
• Keeping the Directorate apprised of any issues in relation to specific requests (e.g., excessive search time, interference with operations, consultations required); and
• Duly delivering to the Directorate the relevant records, complete with branch recommendations. Liaison officers play an important role in ensuring that the Commission conducts a thorough and complete search of its record holdings when processing information requests.

2. Statistical report: Interpretation

During this reporting period, the PSC experienced an unprecedented increase of 1,200% in the number of requests received under both Acts. The total number of complaints to the offices of the Information Commissioner and the Privacy Commissioner increased even more drastically.

Most of the increase in the number of ATIP requests can be attributed to a small number of requesters who submitted multiple requests. The PSC took significant steps and allocated temporary funding to manage the major increase in the number of ATIP request and respect the rights of all applicants. The PSC looks forward to participating in the upcoming TBS-led consultations for the review of the Access to Information Act, especially on issues related to the management of multiple requests coming from unique requesters.

If the total number of requests submitted by unique requesters is not included, the total number still represents an increase of a little less than 200% in the requests received under both Acts, compared with the previous reporting period.

2.1 Requests under the Access to Information Act

From April 1, 2015, to March 31, 2016, the PSC received 180 new requests under the Act in addition to the 10 that were carried over from the previous period. This represents a 350% increase in requests received, compared with the previous year and a 214% increase compared with the average number of requests received over the previous ten years.

If we ignore the multiple requests submitted by unique requesters, the PSC received 100 requests under the Act, which represents a 150% increase over the previous period.

The PSC completed its response to 178 requests during the reporting period, requiring the review of 47,331 pages of records. Twelve requests were ongoing at the end of the reporting period and were carried forward to the next one.

2.2 Nature of requests

As in previous years, the 178 closed requests covered a wide range of PSC activities:

• Thirty-nine requests (21.9%) pertained to investigations and audits conducted under the PSEA;
• Twenty-six requests (14.6%) dealt with staffing activities. Most requesters were seeking information related to staffing documents, Priority Administration and assessments;
• Twenty-six requests (14.6%) were related to contracts, call-ups and temporary help;
• Twenty-one (11.8%) requests were to obtain statistical information or raw data related to the PSC's program activities;
• Sixteen requests (9%) were for records related to the processing of other ATIP requests; and
• The remaining 50 requests (28.1%) were on a variety of subjects.

This represents a shift in the nature of requests when compared with the previous reporting period. A smaller proportion of requests dealing with staffing activities and contracts were reported during this period. An increase in the proportion of requests dealing with PSC investigations, statistics and other ATIP requests were also reported.

If we ignore the multiple requests submitted by unique requesters, the nature of the remaining 95 requests closed during the reporting period more closely resembles the distribution of requests that characterized previous years:

• Twenty-five (26.3%) related to contracts, call-ups and temporary help;
• Nineteen (20%) requests were to obtain statistical information or raw data related to the PSC's program activities;
• Seventeen requests (17.9%) dealt with staffing activities. For the most part, requesters were seeking information related to staffing documents, Priority Administration and assessments;
• Four requests (4.2%) pertained to investigations and audits conducted under the PSEA;
• One request (1.1%) was for records related to the processing of other ATIP requests; and
• The remaining 29 requests (30.5%) were on a variety of subjects.

2.3 Inter-organizational consultations

The PSC received 44 requests for consultation from other government departments and agencies. The processing of these requests required a review of 1,693 pages of documents. All consultation requests were closed and none were carried over into the 2016–2017 reporting period.

In response to these 44 consultation requests, the PSC determined that information should be:

• Disclosed in full for 31 requests;
• Disclosed in part for 12 requests; and
• Exempted in full for 1 request.

The PSC consulted other government departments and agencies 110 times in relation to the processing of 17 of the requests completed during the reporting period.

2.4 Informal requests

In an attempt to increase and facilitate access, the PSC provides copies of previously released requests that are not of a personal nature. During the reporting period, 17 such informal requests were made and completed.

Summaries of completed Access to Information Act requests are available at the Open Data Portal.

In response to the increase in new requests and to expedite and facilitate the management of some of these requests, the PSC implemented a process for providing informal access to records related to the processing of ATIP requests. During the reporting period, informal access was provided to 78 of such files.

2.5 Disposition of requests completed

For the 178 closed requests, information was released either in whole or in part in 98 cases, representing 55.1% of total requests.

When compared to the previous reporting period, there are apparent increases in the proportion of requests that were abandoned and/or transferred. This is accompanied by a corresponding drop in the number of requests where the records were fully disclosed.

2.6 Exemptions invoked

Sections 13 through 24 of the Act set out the exemptions intended to protect information pertaining to a particular public or private interest. Whenever the PSC invoked exemptions, the principle of severing, as described in section 25 of the Act, was applied in order to release as much information as possible. During the reporting period, the most frequently invoked exemptions were subsection 19(1) [personal information], paragraph 16(1)(c) [law enforcement and investigations] and section 23 [solicitor-client privilege].

There was a noticeable increase in the use of paragraph 16(1)(c) due to the number of requests related to active PSC investigations. A historical comparison of exemptions used is presented in Appendix I.

2.7 Exclusions invoked

Sections 68 to 69 of the Act outline certain types of information to which the Act does not apply. These exclusions relate to published material, library and museum material, material placed in Library and Archives Canada by or on behalf of third parties, some materials relating to Atomic Energy of Canada Limited, the Canada Broadcasting Corporation and Cabinet Confidences.

During the reporting period, the PSC excluded some information, pursuant to paragraphs 68(a) [published material or material available for purchase] three times and 68(b) [library or museum material] once.

2.8 Extension of time limits

Extensions of the 30-day statutory response time are permissible under subsection 9(1) of the Act. A request may be extended in accordance with multiple provisions of this subsection. During the reporting period, a total of 58 extension provisions were invoked in the processing of 45 (25%) requests completed during the reporting period. This represents a reduction in the proportion of requests that were extended when compared to the previous year (31%).

2.9 Completion time

Of the 178 closed requests, the PSC responded to 133 within 30 days or less, representing 75% of all the requests completed. Eighteen requests (10%) were completed within 31 to 60 days, 15 (8%) within 61 to 120 days and 12 (7%) required more than 120 days to process.

Of these, 168 (94.4%) were closed within the allowable time limit.

2.10 Translation

The PSC did not receive any valid requests for the translation of records, in accordance with subsection 12(2) of the Act.

2.11 Format of information released

Regarding the 98 requests for which information was released in whole or in part, records for 30 requests (31%) were provided on paper and 68 (69%) were provided electronically.

2.12 Fees

Under the Act, fees for certain activities related to the processing of formal requests can be levied. In addition to the $5 application fee, other charges may also apply for search, preparation and reproduction of the various records, as specified in the Access to Information Regulations. No fees are imposed for reviewing records, overhead or shipping.

In accordance with section 11 of the Act, no fees are charged for the first five hours required to search for a record or to prepare any part of it for disclosure. However, in one case, a search through a vast number of paper records would have been required to respond to one request. As electronic documents could not provide the answer sought, a search fee estimate was prepared and the request was abandoned.

The fees collected during this reporting period totaled $770, while fees waived in accordance with subsection 11(6) of the Act amounted to $125. Fees collected for this reporting period are estimated to represent approximately 1% of the direct cost of administering the Act.

2.13 Costs

During the reporting period, the ATIP Directorate spent $54,059 on salaries and $19,583 on goods and services, including $8,543 for professional service contracts, for the administration of the Act.

The salary and professional services costs represented 0.73 full-time equivalent positions.

3. Summary of Access to Information and Privacy Directorate activities

3.1 Development of policies, directives, guidelines and other key documents

In response to the surge of requests received during the reporting period, the ATIP Directorate consulted other government departments and agencies, the OIC and the Office of the Privacy Commissioner in order to identify best practices to manage the situation. Based on this consultation, the ATIP Directorate developed standardized categories in order to better respond to incoming requests.

Furthermore, the ATIP Directorate also changed its practices for requests involving records concerning ongoing PSC investigations and application of the exemption related to administrative investigations, paragraph 16(1)(c). This new approach allows for greater discretion in the application of this exemption and will result, in many cases, in the release of more information to requesters.

3.2 Advice and training

Advice

In addition to processing Access to Information Act and Privacy Act requests, the Directorate provides advice to PSC managers and employees, as well as from other organizations and members of the public regarding a variety of issues and questions related to both Acts.

Requests for guidance and advice were of the following nature:

• Reviewing MOUs, information-sharing agreements to ensure compliance with the requirements of the Acts and associated policies;
• Reviewing audit reports, responses to parliamentary questions and other documents prior to publication to ensure that information is released in accordance with the Acts;
• Reviewing administrative investigation reports (such as reports on violence in the workplace or harassment reports) prior to disclosure to the concerned parties to ensure that information is released in accordance with the principles of exemptions defined in the Acts; and
• Answering general written and telephone inquiries from the public.

Participation in the governance process

The ATIP coordinator is a member of the Information Management, Information Technology Committee and the Resource Management Committee. The ATIP manager is a member of the Project Review Committee, the Security Committee and the Open Data Core Project Team. Active participation in these committees and various other working groups allows the Directorate to:

• Be aware of upcoming issues, initiatives and projects that may have ATIP implications; and
• Integrate ATIP considerations in the planning for and implementation of initiatives and projects.

Training

The Directorate delivered an ongoing mandatory training program for supervisors and managers of the PSC. The primary goal of the program is to ensure that managers are fully aware of their responsibilities under both Acts and related policies. The Directorate delivered 14 training sessions. A total of 72% of PSC managers and supervisors attended these sessions.

In addition to this formal training program, the Directorate delivered two ad hoc training sessions to 25 employees on the provisions of both Acts and their impact on programs and initiatives.

The ATIP Liaison Working Group met six times during the reporting period to discuss best practices, address gaps and to provide training opportunities.

3.3 Tracking system and imaging software

The Directorate continued to use AccessPro Case Management and AccessPro Redaction software. These systems are upgraded once a year to the newest versions available.

4. Complaints

4.1 Number of complaints

The OIC received 107 complaints regarding Access to Information Act requests presented to the PSC during the reporting period. This sharp increase in the number of complaints submitted to the Information Commissioner is tied to the increase in the number of requests. All but one of the complaints received during the reporting period originated from a small group of individuals who submitted multiple requests. As discussed below, most of these investigations are ongoing.

There were also three complaints carried over from the 2014–2015 reporting period.

4.2 Nature of the complaint

The complaint received during the reporting period concerned the following issues:

• Nineteen complaints regarding the use of extensions;
• Forty-five complaints that the PSC did not respond within the statutory deadline;
• One complaint related to fees;
• Thirty-five complaints regarding the use of exemptions; and
• Seven complaints alleging that the some records were missing from the response.

4.3 Complaints closed

During the reporting period the OIC confirmed that three investigations were discontinued, with the consent of the complainant. One such investigation had been outstanding since 2011 and related to missing records. The other two discontinued investigations related to the use of exemptions.

The OIC deemed that five extension complaints were not well founded.

Fourteen extension complaint investigations were deemed by the OIC to be well founded. All fourteen complaints were deemed resolved by the OIC and no further action was required.

As a result of these investigations, the Directorate changed its procedure for documenting and justifying extensions under subsection 9(1) of the Act. The PSC also changed its process in regards to requests related to ongoing PSC investigations, as described in section 3.1 of this report.

The remaining 88 investigations were carried over to the next reporting period.

Annex A — Delegation Instrument

Access to Information Act — Delegation Order

The President of the Public Service Commission of Canada, as the head of the government institution, hereby designates pursuant to section 73 of the Access to Information Act, the persons holding the positions set out below, or the persons occupying on an acting basis those positions, to exercise or perform any of the powers, duties or functions of the Head of the government institution vested in him by the Access to Information Act.

This delegation is effective as of April 7^th, 2014.

Anne-Marie Robinson
President
Date: May 05, 2014

Appendix A

Access to Information Act

4(2.1)

Responsibility of government institutions

7(a)

Notice when access requested

7(b)

Giving access to record

8(1)

Transfer of request to another government institution

9

Extension of time limits

11(2), 11(3), 11(4), 11(5), 11(6)

Fees

12(2)

Language of access

12(3)

Access in an alternative format

13

Exemption - Information obtained in confidence

14

Exemption - Federal-provincial affairs

15

Exemption - International affairs and defence

16

Exemption - Law enforcement and investigations

16.5

Exemption - Public Servants Disclosure Protection Act

17

Exemption - Safety of individuals

18

Exemption - Economic interests of Canada

18.1

Exemption - Economic interest of the Canada Post Corporation, Export Development Canada, the Public Sector Pension Investment Board and VIA Rail Canada Inc.

19

Exemption - Personal information

20

Exemption - Third-party information

21

Exemption - Operations of Government

22

Exemption - Testing procedures, tests and audits

22.1

Exemption - Audit working papers and draft audit reports

23

Exemption - Solicitor-client privilege

24

Exemption - Statutory prohibitions

25

Severability

26

Exception - Information to be published

27(1), 27(4)

Third-party notification

28(1), 28(2), 28(4)

Third-party notification

29(1)

Where the Information Commissioner recommends disclosure

33

Advising Information Commissioner of third-party involvement

35(2)

Right to make representations

37(4)

Access to be given to complainant

43(1)

Notice to third party (application to Federal Court for review)

44(2)

Notice to applicant (application to Federal Court by third party)

52(2), 52(3)

Special rules for hearings

69

Identify records of parts of records that contain confidences of the Queen's Privy Council for Canada which are excluded from the application of the Act in consultation with Legal Services.

71

Manuals may be inspected by public; exempt information may be excluded

72

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 in the above

Access to Information Regulations

6(1)

Procedures relating to transfer of access request to another government institution under 8(1) of the Act

7(2)

Search and preparation fees

7(3)

Production and programming fees

8

Providing access to record(s)

8.1

Limitations in respect of format

Annex B - 2015–2016 Annual Access to Information Act Statistical Report

Statistical Report on the Access to Information Act
Name of institution: Public Service Commission of Canada
Reporting period: 2015-04-01 to 2016-03-31

Part 1 - Requests under the Access to Information Act

1.1 Number of requests

1.2 Sources of requests

1.3 Informal requests

Note: All requests previously recorded as “treated informally” will now be accounted for in this section only.

Part 2 – Requests Closed During the Reporting Period

2.1 Disposition and completion time

2.2 Exemptions

2.3 Exclusions

2.4 Format of information released

2.5 Complexity

2.5.1 Relevant pages processed and disclosed

2.5.2 Relevant pages processed and disclosed by size of requests

2.5.3 Other complexities

2.6 Deemed refusals

2.6.1 Reasons for not meeting statutory deadline

2.6.2 Number of days past deadline

2.7 Requests for translation

Part 3 - Extensions

3.1 Reasons for extensions and disposition of requests

3.2 Length of extensions

Part 4 — Fees

Part 5 — Consultations received from other institutions and organizations

5.1 Consultations received from other Government of Canada institutions and organizations

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

5.3 Recommendations and completion time for consultations received from other organizations

Part 6 — Completion time of consultations on cabinet confidences

6.1 Requests with Legal Services

6.2 Requests with Privy Council Office

Part 7 – Complaints and investigations

Part 8 - Court action

Part 9 - Resources related to the Access to Information Act

9.1 Costs

9.2 Human Resources

Appendix I — Historical Comparisons

Requests received

Exemptions

* If five different exemptions are used in the processing of one request, one exemption under each relevant section is reported, for a total of five exemptions. If the same exemption is used several times in relation to the same request, it is reported only once.

Exclusions

Footnotes