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Evaluation of Proactive Publication under the Access to Information Act

From: Treasury Board of Canada Secretariat

Introduction

This document presents the results of an evaluation of proactive publications under the Access to Information Act (ATIA) at the Treasury Board of Canada Secretariat (TBS). The evaluation was undertaken by the Internal Audit and Evaluation Bureau at TBS, with the assistance of Goss Gilroy Inc. It was conducted in accordance with the Treasury Board Policy on Results.

The evaluation assessed the efficiency and effectiveness of proactive publication, with an emphasis on the immediate outcomes of the program. The evaluation was undertaken between January and August 2021 and covered the period from 2019–20 to 2021–22.

Results at a glance

In June 2019, Bill C-58, an Act to amend the Access to Information Act and the Privacy Act and to make consequential amendments to other Acts received royal assent. Bill C-58 brought into effect proactive publication requirements, which represented an additional business line for institutions and added to the already complex proactive disclosure process. Early implementation of Bill C-58 posed considerable challenges for institutions. The implementation of the bill challenged the capacity of institutions, required them to coordinate multiple players (many of whom were new to the role), and caused institutions to develop processes to ensure that legislative timelines were met.

Despite these challenges, institutions largely implemented proactive publication successfully. Institutions today are more efficient in implementing proactive publication, and they have improved their processes over time. TBS supported the implementation of proactive publication by providing advice, guidance and training.

Proactive publication activities and responsibilities are decentralized among various units (for example, Access to Information and Privacy (ATIP), Corporate, Finance and Human Resources directorates). The Information and Privacy Policy Division (IPPD) and the Open Government (OG) Division, two small divisions in TBS, provide support to institutions and set out how the institutions implement proactive publication. Looking to the future, to keep up momentum at institutions, TBS’s ability to share best practices and coordinate training could be harnessed to support proactive publication stakeholders, including employees outside of ATIP in institutions subject to the Part 2 of the ATIA.

One notable efficiency is the Open Government portal, which provides economies of scale. Its efficiency would be amplified if TBS promoted the portal’s accessibility and discouraged proactive publication by institutions on their own websites.

The most significant area for TBS’s future focus is institutional monitoring. Current practices are inconsistent, being led by institutions themselves. Monitoring approaches are set and administered by diverse units within each institution, making the processes unique, ad hoc and uneven across the board. Though the OG Division conducts spot checks, there is no formal or centralized monitoring of compliance or performance by TBS.

A benefit to monitoring is data. Currently there is no data on the public’s use of proactive publications, so the degree to which proactively published information meets user needs or whether government accountability is strengthened by proactive publication is unclear. While Canada fares well compared to other jurisdictions on the availability and accessibility of proactive publications, better monitoring would assess compliance and ensure that the legislation is relevant, understood and effective.

While proactive publication requirements may have stretched institutions’ capacities to their limits, institutions have borne the requirements well by making critical changes. The extent to which institutions will be able to further optimize their capacities without additional resources is doubtful. This is particularly true if there are further enhancements to the requirements pertaining to proactive publication.

There is an important link between institutions’ capacities and those of TBS; the capacity limits of institutions will work against any efforts to grow proactive publication if resourcing remains at its current level.

Background

The Access to Information Act (ATIA) provides Canadian citizens, permanent residents, individuals, and corporations with the right to access records under the control of government institutions.

The purpose of the ATIA is to enhance the accountability and transparency of federal institutions to promote an open and democratic society, and to enable public debate on the conduct of those institutions.Footnote 1

Before the update to the ATIA in June 2019, the Government of Canada had implemented proactive disclosure requirements under various policies for certain types of expenses or management actions including:

In 2015, the Prime Minister mandated the President of the Treasury Board to work with the Minister of Justice and the Minister of Democratic Institutions to enhance the openness of government. This mandate included leading a review of the ATIA to ensure that:

In 2016, the government committed to revitalizing the ATIA in two phases. The first phase was meant to address the 2015 mandate commitments and included other targeted changes. The targeted changes from the first phase became Bill C-58, an Act to amend the Access to Information Act and the Privacy Act and to make consequential amendments to other Acts. The bill received royal assent on June 21, 2019. The second phase was a full review of the ATIA, which was launched in June 2020.

Included in the changes made in 2019 was the creation of Part 2 of the ATIA. Federal institutions and entities not previously subject to the ATIA became subject to Part 2, including institutions that support Parliament and the courts, as well as the offices of ministers, senators, and members of Parliament. Part 2 of the ATIA requires federal institutions and entities to proactively publish specific information known to be of interest to the public, such as:

Part 2 of the ATIA also provides the President of the Treasury Board with the authority to specify the form of publications and issue directives and guidelines. TBS has issued guidance to institutions with respect to the form of publications, including requiring or encouraging the use of the Open Government portal and associated timelines.

Proactive publication does not require the release of information that would be properly withheld in response to an access to information request under Part 1 of the ATIA. The changes introduced in 2019 put into law some proactive disclosure practices previously only covered by federal policy, while introducing some new requirements.

Roles and responsibilities

The major internal stakeholders are outlined in this section.

Federal institutions

There are more than 265 federal institutions subject to the ATIA:

Information and Privacy Policy Division, Office of the Chief Information Officer, TBS

The Information and Privacy Policy Division (IPPD) supports the President of the Treasury Board in the administration of the ATIA and the Privacy Act. IPPD does so by providing policy guidance and advice to government institutions on issues concerning access to information, including proactive publication initiatives, and privacy. IPPD also prepares and publishes the statistical report on the government-wide administration of the ATIA and the Privacy Act.

Office of the Chief Human Resources Officer, TBS

The Office of the Chief Human Resources Officer (OCHRO) is responsible for establishing the framework for work force organization and job classification for the core public administration. OCHRO is responsible for the Policies for Ministers’ Offices as well as for the policies underpinning the requirement to proactively publish position reclassifications.

Office of the Comptroller General, TBS

The Office of the Comptroller General (OCG) is responsible for government-wide direction and leadership of financial management, internal audit, federal assets and acquired services. OCG is responsible for the policies underpinning the requirements to proactively publish financial information set out in the ATIA.

Open Government Division, Office of the Chief Information Officer, TBS:

The Open Government (OG) Division is the business owner of open.canada.ca (the Open Government portal), which serves as the government’s central publishing repository of open data and information. Proactive disclosures, including most proactive publications pursuant to the ATIA, are either linked or published on the portal. The OG Division:

Other stakeholders are outline in the following paragraphs.

Governance committees include the committee of the assistant deputy ministers responsible for access to information and privacy (ADM ATIP) and the ATIP community. TBS participates in, but does not lead, the ATIP coordinators working group.

The Clerk of the Privy Council is responsible for policies on the administration of the confidences of the Queen’s Privy Council for Canada and determines what information constitutes a confidence of the Queen’s Privy Council for Canada.

Heads of government institutions are defined in the ATIA and are responsible for meeting their proactive publication obligations under the ATIA. Heads of government institutions are responsible for monitoring compliance with the requirements of the ATIA. Accordingly, each institution is responsible for implementing the appropriate governance and processes for proactive publication within their institution, including monitoring compliance.

Institutional chief information officers or their delegates are responsible for approving information that will be published on the Open Government portal when there is no template available to support publication, such as a briefing package for a minister’s appearance before a parliamentary committee.

The President of the Treasury Board,as designated minister, is responsible for overseeing the government-wide administration of the ATIA.

The Information Commissioner is an officer of Parliament, reporting directly to the House of Commons and the Senate. The Office of the Information Commissioner of Canada ensures that the rights conferred by the ATIA are respected. Part 2 of the ATIA, which covers proactive publication, does not specify any role for the Information Commissioner with respect to proactive publication.

Expected outcomes

The expected outcomes of proactive publication under the Access to Information Act (ATIA), as shown in its logic model (see Appendix), are as follows:

Immediate outcomes

Intermediate outcomes

Long-term outcomes

Evaluation methodology and scope

Because proactive publication is a recent requirement, the focus of the evaluation was to assess the efficiency of proactive publication processes using multiple lines of evidence. The evaluation also focused on the achievement of immediate outcomes. The lines of evidence included:

Use of quantifiers in the evaluation

In this report:

It should be mentioned that when minority statements are identified, it does not necessarily mean that most of the respondents shared an opposite view (due to the fact that many did not respond or were neutral).

Limitations of the evaluation

To assess the impacts of proactive publication, the evaluation examined statistics relating to access to information government-wide. However, statistics were not yet available for 2020–21; only data from 2014–15 to 2019–20 could be analyzed.

Part of the fieldwork was conducted during the 2021 federal election. Interviews with external respondents to gauge the impact on users, such as the media, were not conducted in light of the Caretaker Convention.

Findings

Clarity of roles and responsibilities

Conclusion: The roles and responsibilities within TBS are clear. No gaps or redundancies were identified.

When asked about the extent to which roles and responsibilities were clear within TBS, all TBS respondents and most federal institutions deemed them clear. Respondents also said that team members from the Open Government (OG) Division and the Information and Privacy Policy Division (IPPD) engaged in talks regularly.

Resource use at TBS

Conclusion: Proactive publication activities are efficient within TBS.

According to documentation, the budget for the implementation of the first phase of proactive publication (within TBS) was $7 million, including $1 million for ongoing expenditures.

However, within TBS, guidance and Open Government portal activities for proactive publication required more resources than expected to meet the legislated requirements. For example, IPPD has been called on to provide guidance in situations that were not anticipated in the ATIA, such as the publication of Question Period notes when the House of Commons did not adhere to its regular sitting schedule during the COVID-19 pandemic. Questions falling outside the more “normal” spectrum of government activities will tend to require many resources, including multiple analysts, executives, and legal counsel. Since proactive publication was implemented, additional resources were provided to support the OG Division. TBS activities were deemed efficient by the respondents, both within TBS and externally.

Achievement of outcomes

Expected outcome: institutions monitor their performance of proactive publication

Conclusion: Institutions monitor practices inconsistently and, in some cases, not at all.

Monitoring is assigned to heads of institutions, which is consistent with most (77%) OECD countries. With the exception of spot checks, TBS does not monitor institutional performance or compliance given that there is no policy framework for ongoing monitoring. Nor are there any specific guidelines or tools that would support monitoring activities within institutions. Likewise, the Information Commissioner’s role does not include specific duties related to proactive publication.

The OG Division does not currently track whether institutions are uploading all required publications. The OG Division conducts spot checks of information submitted by federal institutions to be published on the portal. The spot checks identify and correct a high volume of compliance issues that would otherwise have gone unaddressed, according to interview respondents. With some institutions publishing on their own websites and some publishing on the portal, there is no way to know the extent to which institutions across government are proactively publishing as required.

Interview respondents and case studies of institutions indicated that for the most part, the institutional Access to Information and Privacy (ATIP) unit is only responsible for coordinating proactive publication, while the business owners are responsible for uploading information to the portal. Typically, Finance is responsible for contract information, Human Resources for reclassifications, and ATIP for briefing notes. In some institutions, the process can be led by another unit entirely – for example, Information Management, Information Technology, or the director of operations – or the process is completely decentralized. Institutions establish proactive publication processes that are unique to them and their contexts. Institutional case studies highlighted a few different models, refer to the following text box for more details.

Institutional approaches to proactive publication

  • At the Department of Justice Canada, the ATIP Office and Communications Branch jointly coordinate proactive publication activities with business owners
  • At Health Canada, there is a more decentralized approach, where the proactive disclosure requirements are led by the team responsible for overseeing the function or products:
    • the Strategic Policy Branch manages and coordinates new proactive publication requirements and plays a coordination role across the Health portfolio for some products
    • the Chief Financial Officer Branch is responsible for travel and hospitality, contracts and grants and contributions
    • the Human Resources Directorate is responsible for reclassifications
  • At Global Affairs Canada, while proactive disclosure is the responsibility of the process owners, the Transparency Innovation and Compliance Team leads on implementation and provides guidance and support to process owners
  • At The National Battlefields Commission, the Institutional Affairs unit coordinates the collection of information, which is sent to Canadian Heritage for posting

Monitoring activities varied significantly between institutions. Many respondents said that their institution monitors the performance of proactive publication activities. Some institutions have internal reports indicating what has been uploaded. Some respondents said that only a few publication activities were actively monitored. Finally, others said that there are no monitoring activities in their institution. Thus, the most typical situation is what can be considered “self-monitoring,” where each unit or business owner (for example, Finance, Human Resources) is responsible for monitoring their own proactive publications and there is no central unit overseeing or monitoring the process within the institution.

The absence of a government-wide mechanism for monitoring has implications for proactive publication processes in terms of a lack of:

Expected outcome: institutions are more able to implement proactive publication provisions efficiently

Conclusion: Institutions are better able to implement proactive publication efficiently. Nonetheless, there is room for TBS to improve its support.

The Information and Privacy Policy Division’s contribution to efficiency

In accordance with its roles and responsibilities, the Information and Privacy Policy Division (IPPD) prepared guidance for institutions to help them meet proactive publication requirements. This guidance included documents, tools, and questions and answers posted on the federal government intranet. In addition, IPPD held a series of workshops during the implementation phase of the legislation and answered queries about unanticipated situations.

According to interviews, most institutions were satisfied with IPPD’s support, especially in the first months of the implementation of proactive publication. Most (over 70%) were satisfied with the training and almost all were satisfied with the clarity of the advice and guidance.

The main area of dissatisfaction was with the timeliness of the supports. Only 53% of the respondents said that they were satisfied with this aspect. According to the respondents, the guidelines were delivered late, and responses to queries were often late as well. IPPD did not have a service standard for response times. This aspect is especially sensitive given the legislated timelines for proactive publication. Some respondents also pointed out that no document of best practices was made available by IPPD. Nonetheless, during the evaluation, IPPD was in the process of setting up a client-management system.

According to the institutions that were dissatisfied with the guidance (between 20% and 25%), IPPD provided advice that was, at times, too generic and apparently ill-adapted to an institution’s situation or context. In some instances, institutional representatives were told to consult their own legal team. Documentation indicates that additional guidance on the use of technological formats to load information on the Open Government portal would promote consistency among government institutions in their processing of proactive publication materials. To date, there have been inconsistencies among institutions that may confuse stakeholders and the public, according to the document review.

In addition, while ATIP Community meetings are used by some institutions to obtain information about proactive publication, some respondents pointed out that these meetings are intended for those working in ATIP, despite the fact that proactive publication is often managed by non-ATIP staff. As indicated in the documentation, the numerous institutional stakeholders involved in proactive publication include (but are not limited to) senior management, Parliamentary Affairs, the chief information officer, Ministerial Correspondence and Briefing, Information Management, Access to Information and Privacy, Finance, Human Resources, Web Services, Communications and offices of primary interest (for example, program officials and subject matter experts). In the absence of a coordinating body for proactive publication, this means that target audiences who would most benefit are missing out on information sessions.

The Open Government Division’s contribution to efficiency

As part of its role, the Open Government (OG) Division supports institutions that publish information on the portal. According to respondents, the OG Division provided training during the implementation stage of Bill C-58. Their ongoing support is mostly in responding to queries.

Most respondents were satisfied with the support received from the OG Division. Those who were dissatisfied mentioned either that the training was offered long ago and given to staff who had since departed, or that the training was overly generic and lacked guidance specific to different contexts. Respondents felt it would be helpful if training were ongoing and offered more tailored content to institutions.

Most respondents were satisfied with the tools and templates. Yet, among those who were dissatisfied, it was mentioned that:

With institutions being stretched to their limits to deliver proactive publication on time, the inefficiencies noted above posed considerable threats to program performance.

Most respondents were satisfied with the guidelines and guidance provided by the OG Division. Many key informants said that guidance needed to be more tailored to their queries.

While most respondents were satisfied with the timing of the responses that they received, they pointed out that some queries remained unanswered. There are no service standards for expected response times, which means such queries may go unanswered indefinitely. With the growing number of queries shown in the program data, the OG Division’s level of responsiveness works against program efficiency. If present trends continue, in line with the first months of implementation, then inefficiencies will increase.

Resource use within institutions

There was no additional funding for institutions following the updates to the ATIA. Instead, institutions were expected to absorb the costs of implementation. Most respondents stated that they did not hire additional staff to meet their proactive publication responsibilities. According to documentation, some, primarily smaller, institutions, did not have processes or resources in place to support proactive publication, since they were never previously subject to such requirements. These institutions had to reallocate resources internally to meet the new requirements.

Some respondents said that their institution did not have difficulty meeting their proactive publication obligations with existing resources; they explained that most of the information was already being published before the changes to the ATIA.

About half of the institutions said that proactive publication required significant effort. For example, one large department estimates that proactive publication requires 5.5 full-time equivalents plus translation costs that are estimated to be in the hundreds of thousands of dollars. According to documentation, the Information Commissioner commented that there is a need for additional resources to meet proactive publication requirements.Footnote 3

Apart from time spent, most respondents from institutions said they faced – and continue to face – many challenges when trying to meet their obligations in terms of proactive publication, including:

The heads of institutions are responsible for establishing effective procedures and systems to meet proactive publication requirements. Although the actual process differs between institutions, the following figure provides an overview of a typical process for proactive publication. This process may also vary according to the type of publication.

Figure: proactive publication process map
Text version below
Figure - Text version

A map of the steps involved in the proactive publication process, starting on day 1 and ending at publication:

  • Production: consolidate content from source material
  • Pre-publication review:
    • identify information that may be subject to valid exceptions, such as ownership, security, privacy and confidentiality
    • consult with key stakeholders
  • Translation: send publication content to translation services
  • Approval: submit content for final review and approval by the senior official responsible for publication
  • Web coding: send approved content that meets accessibility requirements for posting on the Internet
  • Publication deadline: proactive publication of content in accordance with legislative requirements and time limits (on the portal or an institutional website)

Figure adapted from TBS documentation on GCpedia

The legislative review consultations reported that the most common challenges, for 28% of all respondents, related to proactive publication were:

Other challenges identified by the interview respondents include:

While each challenge on its own accounts for perhaps a small delay, cumulatively these challenges take a toll on institutions that need to factor in ways they may or may not meet their legislated timelines for publication. Even with internal optimizations, external factors, such as missing templates and delayed responses from the policy centre, can become performance inhibitors.

Expected outcome: proactive publication processes across institutions are improved

Conclusion: Institutions are improving their proactive publication processes. Transparency and user accessibility can still be enhanced.

Organisation for Economic Co-operation and Development (OECD) reports indicate that Canada’s performance with respect to open data is above average. Based on the criteria of data availability, accessibility and government support for reuse, Canada ranked fourth among 33 OECD countries. A review of the websites and portals of selected jurisdictions (the United Kingdom, the United States, Australia, the province of Ontario) shows that Canada compares favourably overall in terms of the accessibility and quantity of information. The United Kingdom includes information about unique gifts received by ministers. The United Kingdom’s information commissioner also plays a key role in setting the tone for an open publication approach.

Although the document review indicates that the pandemic created delays in Canada’s proactive publication activities, interview respondents indicated that most institutions meet the deadlines prescribed by legislation. A few said that they generally meet the deadlines with few exceptions. The most challenging areas are the transition binders and reports to Parliament. Overall, most respondents who use the Open Government portal said it helps them meet their proactive publication obligations.

Proactive publication requirements apply to all the institutions subject to Part 1 of the ATIA. Part 2 of the ATIA also extends certain proactive publication requirements to a wider range of institutions that are not subject to Part 1.

In total, more than 265 government institutions are subject to proactive publication requirements. Depending on the type of publication, information published in one of two places: on the institution’s website or on the Open Government portal.

The data review shows the number of proactive publications on the portal has grown between 2019–20 and 2020–21, which suggests that implementation of proactive publication on the portal has been gradual. At the time of the administrative data review, roughly 93 institutions had published on the portal. As the desired long-term outcome of proactive publication is to strengthen the openness and transparency of government, enhanced use of the portal rather than individual Government of Canada websites may promote user accessibility and assist TBS in achieving this outcome. Further study into why institutions opt to publish certain items on their own websites could help TBS add value to the portal and increase predictability in the implementation of proactive publication.

Impacts on users and on access to information requests

There is no tracking of users of proactive publications, given that institutions are not monitoring sites or users in any fashion. Interview respondents estimated that users were likely to be the media, academics, parliamentarians, government staff and the general public. Given website traffic, it is clear that public servants are the ones seeking information on reclassifications and comparative information on grants and contributions programs. Otherwise, little is known about the types of proactive publication materials used or what is most valued by whom.

Documentation indicates that there is an opportunity for greater promotion of proactively published information. In their interviews, the OG Division shared that they would like to know more about user needs and would benefit from engaging more with users, particularly as a means of correcting commonly misinterpreted financial information about multi-year projects that are reported annually.

The evidence indicates that the impact of proactive publication on access to information requests varied among institutions. While government-wide data shows that access to information requests have not increased significantlyFootnote 4 between 2018–19 and 2019–20, about half of the interview respondents said that proactive publication contributed to an increase in access to information requests at their institution.

Other respondents said that proactive publication did not increase the overall number of requests at their institution.

Some said that the users of Access to Information and Privacy (ATIP) are now more diversified because of proactive publication. More academics, for example, are aware of what is available on the portal and use ATIP requests to gather more documentation (briefing notes and transition binders).

Users of proactive publications by Global Affairs Canada

Briefing note titles posted by Global Affairs Canada are used by the media and the public to make clearer and more specific access to information requests, according to interview respondents. In the past, requests would be much more general and more broadly scoped. There were frequent users who would request all briefing notes for a specific period. As a result of publishing the list of briefing note titles, the ATIP Division now receives clear requests with the title and tracking number of the briefing notes of interest. This has made processing these requests easier, as the information is specific and easier to find.

Some respondents mentioned that proactive publication impacted the timing of the ATIP requests and that they observed a surge in demand after proactive publication occurred.

Recommendations

  1. It is recommended that the Information and Privacy Policy Division (IPPD) foster institutional monitoring by:
    1. considering how the access to information policy instruments can cover proactive publication and consulting institutions on ways to improve, and
    2. promoting the use of the Open Government portal
  2. It is recommended that IPPD and the Open Government Division better support institutional operations by:
    • developing service standards
    • learning what prevents institutions from using the portal rather than their own website and addressing these issues where possible
    • sharing best practices
    • providing ongoing training that offers some institutional context and examples
    • better adapting policy guidance
  3. It is recommended that IPPD strengthen communication with institutions by engaging with proactive publication stakeholders beyond the access to information community meetings.
  4. It is recommended that IPPD engage users in order to gain insight into the relevance of proactive publications to users, as well as gain insight into user needs today, and in the future.

Appendix: logic model – proactive publication under the Access to Information Act

Appendix: Logic Model
Text version below
Logic Model - Text version

The logic model for proactive publication under the Access to Information Act is composed of six levels:

  1. Activities (what we do):
    • Support the President in the administration of the Access to Information Act
    • Communicate and provide outreach
    • Develop and provide guidance, advice, training and support to institutions
    • Develop and maintain the Open Government portal
  2. Outputs (goods we produce, services we provide):
    • Legislation, directives, policies and guidance
    • Governance committees
    • Tools and processes
    • Proactive publication platform
  3. Reach (program beneficiaries):
    • Canadians
    • academics
    • bargaining agents
    • Multi-Stakeholder Forum on Open Government
    • government institutions
    • national Indigenous organizations
    • other Indigenous representatives, groups and institutions
    • the access to information community
  4. Immediate outcomes (changes in capacities, opportunities, motivations):
    • Institutions are more able to implement proactive publication provisions efficiently
    • Institutions monitor their performance of proactive publication
    • Proactive publication processes across institutions are improved
    • Intermediate outcomes (changes in behaviour):
    • Proactive publication requirements are being met consistently
    • The public has timely access to key federal government documentation
    • The public is better informed about the federal government’s decisions and priorities
  5. Long-term outcomes (benefits):
    • The accountability of government to its citizens is strengthened and democratic participation is enhanced
    • The openness and transparency of government is strengthened

Management Response and Action Plan

The Access to Information Policy and Performance Division (AIPPD) of the Treasury Board of Canada Secretariat (TBS) has reviewed the evaluation report and agrees with its recommendations. The recommendations will guide and inform AIPPD’s ongoing initiative to improve proactive publication under the Access to Information Act (the ATIA). Proposed actions to address the recommendations of the report are outlined below.

Internal and Audit Evaluation Bureau recommendations

Recommendation 1a

It is recommended that AIPPD foster institutional monitoring by considering how the access to information (ATI) policy instruments can cover proactive publication and consulting institutions on ways to improve.

Management response

TBS AIPPD agrees with the recommendation that institutional monitoring related to proactive publication under Part 2 of the ATIA needs to be fostered and to consider how the ATI policy instruments could cover proactive publication. Any policy instrument will be developed in consultation with institutions subject to the ATIA.

Proposed action Starting time frame Targeted completion time frame Office of primary interest

1a.1 TBS AIPPD will develop a policy instrument with the intention of providing direction and consolidated guidance on the implementation of Part 2 of the ATIA, which will include direction to institutions with respect to institutional monitoring.

TBS AIPPD will consult institutions subject to Part 2 of the ATIA during the development of the instrument.

Quarter 1, 2022–23

Quarter 1, 2023–24

TBS AIPPD: ATI Policy

Recommendation 1b

It is recommended that AIPPD foster institutional monitoring by promoting the use of the Open Government (OG) Portal.

Management response

TBS AIPPD agrees that institutional monitoring related to proactive publication under Part 2 of the ATIA could be fostered by promoting the use of the OG Portal.

Proposed action Starting time frame Targeted completion time frame Office of primary interest

1b.1 TBS AIPPD will engage with institutions to promote optimal use of the OG Portal.

Quarter 1, 2022–23

Quarter 3, 2022–23

(ongoing)

TBS AIPPD: ATI Policy/ TBS OG

Recommendation 2a

It is recommended that AIPPD and the Open Government (OG) Division better support institutional operations by developing service standards.

Management response

TBS AIPPD and OG agree with the recommendation that AIPPD and OG have opportunities to better support institutional operations through the development of service standards for responding to inquiries from institutions related to proactive publication.

Proposed actions Starting time frame Targeted completion time frame Office of primary interest

2a.1 TBS AIPPD and OG will explore the development of service standards to respond to all inquiries received from institutions related to proactive publication and implement as required.

Quarter 3, 2021–22

Quarter 4, 2022–23

TBS AIPPD: Outreach and Reporting / TBS OG

Recommendation 2b

It is recommended that AIPPD and OG better support institutional operations by learning what prevents institutions from using the Portal rather than their own website and addressing these issues where possible.

Management response

TBS AIPPD and OG agree with the recommendation that AIPPD and OG have opportunities to better support institutional operations through learning what prevents institutions from using the Portal rather than their own website and developing an understanding of these issues in order to address them and promote the use of the OG Portal.

Proposed actions Starting time frame Targeted completion time frame Office of primary interest

2b.1 TBS AIPPD and OG will engage with institutions to learn what prevents institutions from using the Portal rather than their own websites and address identified issues, where possible.

Quarter 1, 2022–23

Quarter 4, 2022–23

(ongoing)

TBS AIPPD: ATI Policy / TBS OG

Recommendation 2c

It is recommended that AIPPD and OG better support institutional operations by sharing best practices.

Management response

TBS AIPPD and OG agree with the recommendation that AIPPD and OG have opportunities to better support institutional operations through the sharing of institutional best practices.

Proposed actions Starting time frame Targeted completion time frame Office of primary interest

2c.1 TBS AIPPD and OG will conduct options analysis with the goal of establishing a mechanism through which institutions could share best practices on proactive publication implementation.

Quarter 1, 2022–23

Quarter 4, 2022–23

TBS AIPPD: ATI Policy, Outreach and Reporting / TBS OG

2c.2 In alignment with Recommendation #3, TBS AIPPD will leverage the inter-institutional governance structure to share best practices.

Quarter 2, 2022–23

Quarter 4, 2022–23

TBS AIPPD: ATI Policy

Recommendation 2d

It is recommended that AIPPD and OG better support institutional operations by providing ongoing training that offers some institutional context and examples.

Management response

TBS AIPPD and OG agree with the recommendation that AIPPD and OG have opportunities to better support institutional operations through the provision of ongoing training.

Proposed actions Starting time frame Targeted completion time frame Office of primary interest

2d.1 TBS AIPPD and OG will engage with key stakeholders to better understand the training needs with respect to proactive publication and adjust where required.

Quarter 1, 2022–23

Quarter 4, 2022–23

TBS AIPPD: ATI Policy / TBS OG

2d.2 TBS AIPPD will work with Canada School of Public Service (CSPS) to develop training content related to proactive publication under Part 2 of the ATIA.

Quarter 1, 2022–23

Quarter 4, 2022–23

TBS AIPPD: ATI Policy

2d.3 TBS OG will continue to provide training to institutions and explore opportunities, where possible, to include institutional context and examples.

Quarter 1, 2022–23

Quarter 4, 2022–23

TBS OG

2d.4 TBS OG will conduct a review of and update existing guidance on uploading proactive publications to the Open Government Registry.

Quarter 1, 2022–23

Quarter 4, 2022–23

TBS OG

Recommendation 2e

It is recommended that AIPPD and OG better support institutional operations by better adapting policy guidance.

Management response

TBS AIPPD and OG agree with the recommendation that AIPPD and OG have opportunities to better support institutional operations through better adapting policy guidance, where appropriate to do so.

Proposed actions Starting time frame Targeted completion time frame Office of primary interest

2e.1 To develop a stronger understanding of where policy guidance could be better adapted to institutions’ needs, TBS AIPPD and OG will coordinate consultations with institutions and internal to TBS stakeholders to determine the most appropriate policy instrument to provide direction and consolidated guidance to institutions.

Quarter 1, 2022–23

Quarter 1, 2023–24

TBS AIPPD: ATI Policy / TBS OG

2e.2 In addition to the development of a policy instrument, TBS AIPPD will develop additional tools to support institutions in streamlining their proactive publication processes.

Quarter 3, 2021–22

Quarter 1, 2022–23

TBS AIPPD: ATI Policy

2e.3 Planned updates to the ATI Policy Suite by TBS AIPPD will include the addition of the responsibility of heads of institutions to establish effective procedures and systems, including use of prescribed platforms, to meet the proactive publication requirements under Part 2 of the ATIA and TBS guidance on proactive publication.

Quarter 2, 2021–22

Quarter 2, 2022–23

TBS AIPPD: ATI Policy

Recommendation 3

It is recommended that AIPPD strengthen communication with institutions by engaging proactive publication stakeholders beyond ATI community meetings.

Management response

TBS AIPPD agrees with the recommendation that AIPPD strengthen communication with institutions by engaging proactive publication stakeholders beyond the ATI community meetings.

Proposed actions Starting time frame Targeted completion time frame Office of primary interest

3.1 TBS AIPPD will adapt existing governance and communication structures to include proactive publication stakeholders, with a focus on the sharing of best practices as per 2c.2.

Quarter 1, 2022–23

Quarter 4, 2022–23

TBS AIPPD: ATI Policy, Outreach and Reporting / TBS OG

Recommendation 4

It is recommended that AIPPD engage users in order to gain insight into the relevance of proactive publications to users, as well as gain insight into user needs today, and in the future.

Management response

TBS AIPPD agrees that it is important to engage users in order to gain insight into the relevance of proactive publications to users, as well as gain insight into user needs today, and in the future. Insight in these areas will better inform legislative reviews of the ATIA as well as other government activities in support of long-term outcomes of transparency and accountability.

Proposed actions Starting time frame Targeted completion time frame Office of primary interest

4.1 TBS AIPPD and OG will apply data, produced by TBS OG and institutions, to gain insight into current usage of proactive publications (e.g., are proactive publications being accessed and how often).

Quarter 1, 2022–23

Quarter 4, 2022–23

TBS AIPPD: ATI Policy, Outreach and Reporting / TBS OG

4.2 TBS AIPPD will leverage existing consultative forums to engage with users on an ongoing basis to obtain their feedback and determine their needs.

Quarter 1, 2022–23

Quarter 4, 2022–23

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