Annual Report on the Privacy Act 2019-2020

Table of contents

• Introduction
• Organizational structure
• Delegation order
• Highlights of the statistical report
  • Time limitations
  • 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
• Complaints, investigations and audits
• Monitoring compliance
• Privacy breaches
• Privacy impact assessments
• Public interest disclosures
• Appendix A : Statistical report Privacy Act (April 1, 2019 to March 31, 2020)

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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 73 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 de l'Agence Parcs Canada délègue aux titulaires de postes mentionnés à l'annexe ci-après, ainsi qu'aux personnes occupant à titre intérimaire les-dits 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 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 of the Parks Canada Agency, pursuant to section 73 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, 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 26^e jour de mars 2016
Dated, at the City of Gatineau, this 26th day of March, 2016

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)	Sections 7 and 9 of the Access to Information Act	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, 2019 to March 31, 2020. The Statistical Report (Appendix A) contains detailed statistics on the information requests processed under the Privacy Act.

Fourteen (14) personal information requests were received under the Privacy Act. Two (2) requests were carried over during the reporting period under review.

Three (3) requests were fully disclosed, eight (8) requests resulted in the partial disclosure of the records. Two (2) requests had no records in response to them and two (2) requests were abandoned.

Time limitations

All requests were processed within legislated timelines.

Consultations received from other institutions and organizations

The Agency received one (1) consultation request 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

Due to the COVID-19 pandemic, Parks Canada experienced some challenges during the reporting period. Parks Canada employees along with the ATIP office teleworked with limited capacity. Special measures were taken to respond to requests as per Treasury Board Secretariat guidelines and requesters were informed that there could be delays due to the pandemic. No requests were affected by COVID-19 for the reporting period.

Formal/information 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.

In addition to the above, Parks Canada’s 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.

Four (4) sessions were given to Agency employees across Canada in 2019-2020. In total, thirty- seven (37) 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 Access to Information Act were up to date and that adjustments were made to areas where the need for improvement was identified.

Complaints, investigations and audits

One (1) complaint was 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.

Privacy breaches

There was one (1) material privacy breach reported to the Office of the Privacy Commissioner and to the Information and Privacy Policy Division, Treasury Board of Canada Secretariat during this period. The Office of the Privacy Commissioner decided not to pursue the matter and closed the file following their review and assessment of the incident.

Privacy impact assessments

Between April 1, 2019 and March 31, 2020, seven (7) 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.

Appendix A : Statistical report on the Privacy Act (April 1, 2019 to March 31, 2020)

Part 1: Requests under the Privacy Act

1.1 Number of requests

Part 2: Requests closed during the reporting period

2.1 Disposition and completion time

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 Closed requests

2.7 Deemed refusals

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

2.8 Requests for translation

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

Part 4: Requests for Correction of Personal Information and Notations

Part 5: Extensions

5.1 Reasons for extensions and disposition of requests

5.2 Length of extensions

Part 6: Consultations Received From Other Institutions and Organizations

6.1 Consultations received from other Government of Canada institutions and organizations

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

6.3 Recommendations and completion time for consultations received from other organizations

Part 7: Completion time of Consultations on Cabinet Confidences

7.1 Requests with Legal Services

7.2 Requests with Privy Council Office

Part 8: Complaints and Investigations Notices Received

Part 9: Privacy Impact Assessments (PIAs) and Personal Information Banks (PIB)

Section 10: Material Privacy Breaches

Section 11: Resources Related to the Privacy Act