Three different groups were consulted about the renewal of MGI (Management of Government Information) policy during this meeting of the information management (IM) community. For each group, Hélène Valin and Greg Renaud of Treasury Board Secretariat (TBS) presented introductory information before discussions began.

MGI Policy Renewal

Hélène Valin explained that the policy suite renewal process is a Treasury Board-wide initiative to review its policies. Thus, it provides an opportunity to review and redefine the MGI policy.

Treasury Board's Chief Information Officer Branch (CIOB) currently has 10 policies and 90 standards. In the new approach, there will be six policies covering IM, information technology, Government security, service delivery, access to information, and privacy protection of personal information.

Valin reviewed the key objectives of the policy suite renewal. She then presented a high-level view of the policy instruments, which fall into five categories: framework, policies, directives, standards, and a guideline/tool. Policies, directives, and standards will all be mandatory, while a framework will be architectural, and a guideline/tool will be voluntary.

Changes to IM policy will increase accountabilities at the Deputy Head level, provide a basis for increased monitoring and reporting, introduce consequences for not meeting policy requirements, and clarify and simplify the policy.

After reviewing some of the issues and challenges associated with the renewal process, Valin outlined the consultation strategy and the work plan for drafting the new policy. The final version of the policy must be completed by December 21, 2006. Its effective date is still undetermined – there is some flexibility as to when the policy comes into force. One possibility is to extend the effective date of the policy to December 2007, which would allow a year to prepare supporting instruments and tools.

During the discussions following this presentation, participants highlighted a number of issues, including Deputy Head accountabilities, the policy's relevance to libraries, requirements for effective implementation, and other groups that should be consulted.

Draft Policy on the Management of Government Information

Greg Renaud reviewed the current draft of the MGI policy section by section.

He noted that Treasury Board plans to create a glossary of policy definitions for the entire policy suite so that there is consistent use of terminology throughout. He invited participants to share their ideas regarding preferred definitions of terms.

Discussing the difference between a policy and a directive, Renaud noted that a policy is the "what," while a directive is the "how." It will be important, he said, to ensure that the right content is included in each instrument.

Regarding Section 6.2, he explained that the content of this section focuses on areas where this policy gives authority to a department or a Deputy Head to fulfill requirements. If something needs to be highlighted to reflect other instruments that provide certain authorities, it can be mentioned in Section 8.

Renaud noted that Section 7 (Consequences) can include both positive and negative consequences (i.e., it can include the possibility of rewards for complying with this policy).

Small Group Discussions: June 27

Part One: Specific Comments on the Draft Policy

Following the introductory presentations, participants discussed the draft policy in small groups and then presented initial comments to the plenary.

A participant criticized the fact that metadata is not discussed in the new policy. Citing the 2002 version of the policy (Section 2.3.b.) where metadata is addressed, she noted that this reference had been excluded from the new version.

Greg Renaud commented that if an important matter is not addressed in the draft policy – but if this matter is not necessarily "policy content" – then it could be included in a directive or a standard and still be a mandatory requirement. Perhaps, he suggested, metadata is one of those subjects.

Two other elements included in the 2003 version of this policy have also disappeared, said a participant: the privacy protective manner and the reference to both official languages. Renaud explained that these two elements are related to process issues (the "how") and not to policy content (the "what"), so they should be included in another policy instrument. He added that these areas are already covered by other policies.

Regarding Section 5.2.4, a participant asked if the reference to "common methodologies" was a reference to the Business Transformation Enablement Program (BTEP). Renaud replied that it was just a general reference to methodologies.

A participant asked if the reference in Section 6.2.1.c. to a framework for the management of information was a reference to the current Framework for the Management of Information (FMI) and said that if this was the case, it should be made more explicit. She also suggested that the policy link to other Treasury Board tools through hyperlinks.

Regarding Section 6.3.2, a participant asked if Treasury Board had specific tools in mind. The speaker suggested that if the Information Management Capacity Check (IMCC) was to be a tool for the audit, this should be made specific. Renaud replied that the tools are not yet determined.

Participants commented that Section 8 was not clear and needed clarification. Renaud noted that additional content on the responsibilities of organizations was missing from this section.

Regarding definitions, a participant said that IM and the management of information (MI) are not really different concepts and recommended consolidating them.

Participants commented that "the verbs are very weak" in Section 6.1 and said the only reference to concrete actions on the part of the Deputy Heads was in Section 6.1.6.

Like the previous document, this policy should refer to the responsibilities of individual employees.

Noting that Section 7.3 refers to evaluation based on compliance with IM, participants commented that this type of evaluation would then lead to monitoring and reporting. This process has to be clarified: "Who is responsible for what, and who has accountability?"

For Section 6.3.1, participants requested that Treasury Board Secretariat develop a template for internal auditing that could be adapted by departments.

Referring to page 1, participants said there should be more contextual information. Specifically, why is IM being discussed only as a service within government and not as a service offered directly to the public? The document should record the distinctions between the two types of IM.

Participants praised the clarity of language in Section 3.4 but added that it could be even stronger in outlining a broader level of accountability.

It was noted that the language used in Section 5.1 was relatively traditional. This section should mention things like transparency, accountability, and support to business processes rather than turning to traditional IM language so quickly. It was suggested that the section be divided into two parts – one broader and one more specific.

Referring to Section 6.2.1.b., a participant asked how TBS would help federal government institutions integrate IM requirements into corporate business and information technology strategies and plans.

Regarding the context-setting aspect of the document, a participant called for more reference to individual responsibility. Although this policy is focused on the accountabilities of Deputy Heads, the context setting should include this additional perspective – particularly because this area is addressed in several places in the document (including sections 5.2.2 and 6.2.1.b.).

Also, the Deputy Heads should be made more clearly responsible for some areas. Referring to TBS's responsibilities outlined in Section 6.2.1, a participant asked why these are not areas of responsibility for the Deputy Heads.

Part Two: Discussion Topics

Each of the three groups discussed one topic and reported their conclusions back to the plenary. Following each report, members of other tables added their comments and discussed particular issues of interest.

Table 2: Policy Implementation – Feasibility

This group discussed the capacity required to implement the policy, the greatest gap and how to close it, and the opportunities within an implementation strategy.

Gaps

IM communities of practice do exist within government, the group observed, but the government is losing IM expertise as people retire. IM training is evolving slowly, and the community is developing, but not fast enough for the community to meet the needs in government. This issue needs to be addressed as the MGI policy is rearticulated.

How can policy implementation be sustained? Some departments are readier than others to implement the policy. In most departments, there may be a lack of consistent and enforceable guidelines and tools regarding IM.

There is a big gap between the expectations articulated in the new MGI policy and the ability and willingness of senior management to comply with the policy. IM would be more successful with senior management buy-in. The current version of the policy is meant to better articulate the accountabilities of Deputy Heads, but "it remains to be seen whether we'll obtain those accountabilities."

Other gaps include the lack of time and resources to ingrain good IM practices within each business area.

Suggestions for policy implementation

The key requirement of an implementation strategy is a clear policy objective that is communicated to the right levels and departments. Communication should also outline the benefits of compliance. Policy should articulate what is required of government employees and of the business areas.

A TBS IM sustainability plan could be created in collaboration with TBS and departments and used as a framework for sustained policy implementation over the next five years.

There should be a communications strategy to communicate to senior management how this new policy will benefit the business of their department. Also, the implementation of MGI policy will have to be promoted in the larger context of the renewal of all TBS policies: "How do we work within that framework and ensure that our voice is heard?" To get the support of senior management, there needs to be a clear message.

One option to consider is a graduated compliance mechanism, whereby higher priority aspects of the policy are implemented first.

Discussion

Asked for recommendations regarding the timing of implementation, a participant advised enforcing as quickly as possible. She explained that when there is a "push" behind policy implementation, it has a bigger impact at the management table. "The shorter the timeframe, the better," she added.

Another participant expressed support for stipulating a clear timeframe (such as 12 months), but added that departments, if given a timeframe, will also want to be given the tools to implement the policy. "That is a consideration for Treasury Board," he said.

Robert Coffin remarked that TBS plans to provide tools in support of the implementation strategy. Another idea, he said, was to create short-term IM working groups in policy implementation teams or departments.

Another participant agreed with this idea, saying that working groups should involve IM and IT people and representatives from the business community – "just a core of business people involved in thinking about implementation and the ramifications."

Table 3: Directives, Standards, Guidelines

This group commented that it is not clear who is responsible for developing tools and helping with policy implementation. What are the respective roles of Treasury Board and Library and Archives Canada? There needed to be more clear direction on this matter.

Groundwork must be done from the departmental level to educate employees about their responsibilities. For example, Natural Resources Canada provided a package of information to employees. This is a fundamental step before introducing any kind of policy in which an employee has to take on IM responsibilities.

TBS should include something on its portal to state clearly that FMI is the authority for the Government of Canada when it comes to guidelines and best practices.

Recommending that TBS communicate with the rest of the community regarding these policy changes, the group suggested that the IM in Business Report be available on the TBS website.

Templates (or a checklist) should be created for the departments' use in developing internal guidance documents, the group said, adding that TBS should share information and collaborate. Every directive, standard, and set of guidelines should have a review date to expedite updates within a reasonable timeframe. Enforcing this requirement within departments would ensure that departmental standards are reviewed regularly.

During the discussion in plenary, participants expressed strong support for the idea of providing templates to departments.

Table 4: Management of E-records and Consequences for Non-compliance

Management of e-records

Information management is broader than just records management, this group observed. It is necessary to manage both electronic and paper information and records, and the policy should include an umbrella statement to cover both areas. Observing that this issue is covered in sections 2.1 and 5.2.7, the group said this seems sufficient (given that the policy is focused on "what," not on "how"). However, it added that the challenges associated with records (such as the need for long-term accessibility and preservation) are related to questions of "how" to implement the policy. If the MGI policy is not the place to consider these questions, then the issue should be addressed in other policy instruments. Library and Archives Canada should be included in this discussion. The group suggested creating a link in the policy to the material on records, but said that, ultimately, more policy instruments will be needed for records.

Discussion of e-records

A participant stressed the need to ensure that when e-records are managed, they are managed in coordination with paper records or microfiche. There should be consistency between the two. Often, while one paper record is being managed formally, there are several electronic records, all on the same subject.

Consequences for non-compliance

There are no incentives for managing information, the group observed. This policy should include such incentives, as well as consequences for failing to manage information. People who retire or who are transferred often do not leave time to organize their information. Incentives for doing so (and consequences for not doing so) should be established. For example, signature delegation could be suspended. There should be strong wording on this matter and severe consequences, such as delays in promotions or bonuses.

The group stressed that it is not just the responsibility of managers to see that information is managed; it is also the responsibility of employees to manage their information. One responsibility for managers is to ensure that employees have the means to manage information. It suggested that consequences must be linked to monitoring.

Discussion of consequences for non-compliance

This needs to be part of an employee's performance assessment, said a participant, adding that if there are monetary consequences, then IM will be taken seriously. TBS should focus on the exit process, and the performance review must include a section on IM.

The group observed that one difficult issue is when, at the end of a secondment, an employee returns to a provincial home department. In this case, there are no consequences for the employee, and the federal government has no means of imposing financial penalties.

Closing Remarks

Hélène Valin reviewed some of the main points raised during the session:

Metadata is not included in the current draft of the policy.
The definitions of MI and IM are similar, and a decision needs to be made about whether to refer only to IM.
TBS templates should be provided.
The language is traditional and should be made more accessible.
Tools should be updated.
One way of approaching reporting is to ask departments to show an accountability matrix.
There needs to be a communications strategy.
There should be graduated compliance mechanisms.
There should be an IM portal that is an authoritative source for information.
There should be clear direction regarding the different roles (who is supposed to do what).
Best practices at the departmental level should be shared so that departments have extra information on implementation.
Consequences should be outlined with regard to implementation or the lack thereof.
Existing expertise should be gathered through exit interviews and questionnaires.

Valin concluded by requesting that participants identify a program manager or a service manager whom TBS could contact to participate in this consultation process.

Small Group Discussions: June 28

Part One: Specific Comments on the Draft Policy

Following the introductory presentations, participants discussed the draft policy in small groups and then presented initial comments to the plenary.

Participants commented that the statements in the draft policy were quite broad and that it was difficult to evaluate the policy without the supporting standards and directives. Hélène Valin promised there would be supporting instruments for this policy and said consultations would be held on those other instruments.

A participant said there should be some direction for the working-level employee regarding "what to put to file and what not to put to file."

The statement about IM being a shared responsibility does not take responsibility and accountability down to the level of the end user, said participants. If end users see themselves in the policy, this creates buy-in and makes the policy easier to enforce. Accountability is a higher level concept, and people need to know what the policy means to them as end users.

Speaking of records, a participant commented that public servants have lost the ability to document and track their decisions. There must be some linkage between the Library and Archives of Canada Act and this policy. "As head of IM, I can't always be telling people to flip through the Act," she said.

Another speaker said there needs to be more clarity regarding the naming of related policies, including a list of policies and an explanation of the linkages between them. This has implications in terms of people understanding their roles and knowing which policy they are applying.

One of the greatest problems in IM is the inadequate definition of a record, said a participant. "We in IM need a working definition," she said, adding that a record is not just an email or a piece of paper. The definition of "record" should be the same for all policies and should meet the requirements of the courts. Records must include metadata. She added that currently there are no instruments (from either Treasury Board or Library and Archives Canada) to help information managers do their work.

Table 1: Sections 3, 4, and 5.1

Referring to the second sentence in Section 3.1 (on IM in the Governments Strategic Reference Models), participants said this reference did not contribute to the policy.

When asked what behaviour they want the policy to change, participants considered issues such as accountability, information in support of the business process, and information as evidence. They recognized that the existing MGI policy sets the context very well and establishes certain principles. These include the responsibility of all employees, the link to business, and a message of accountability and governance. It is important to accommodate such elements in order to set the direction for the policy.

Another issue was the definition of "record." Participants suggested that the definition being used was lacking and noted that international definitions focus on records as legal evidence. They recommended that Canada adopt an international standard.

Table 2: Sections 5.1, 5.2, and 6.1

Participants suggested that one area was missing – accountability. There are certain accountabilities related to managing information, they said, and records management should be enshrined in accountability accords.

They compared Section 5.2 with existing policy and observed that references to privacy are missing in the current draft. Also, employees' responsibilities should be discussed.

Sections 5.2.3 and 5.2.6 seem the same, they observed.

Another issue was the definition and use of the word "record" as compared to the term "information." In the Library and Archives of Canada Act, a record means something different – so there is an inconsistency in the use of terminology.

Another area of confusion involved the discussion of published and unpublished information and how to handle different forms of information.

Regarding Section 6.1, participants recommended enshrining IM in the performance reviews of Deputy Heads. Accountabilities for managing information assets should be woven into delegation frameworks in the departments. The goal is to convey the message that "good record-keeping is part of your job."

One participant said the primary issue surrounding published data is the context of the policy as a whole. She commented that the library community does not see itself in the current MGI policy and feels that it is more focused on records. "If the intent was to broaden that scope, it's not seen here," she said, adding that the theme of published information should be woven through the policy.

Another participant stressed that including the library perspective involves more than "adding a few words here or there about libraries or published information." The work done in libraries is very different – not because the data is published but because it is owned by someone else. Libraries release access to information; they don't own it.

Another type of published information is the published material that the government creates and owns (including website material). Noting that this material is addressed in other policies, a participant asked what the relationship is between this policy and the other policies.

Table 3: Section 6.2

Participants commented that the roles of employees and senior management should be addressed in the policy.

Regarding Section 6.2.1.d., participants called for more clarity in the wording regarding functional communities.

For Section 6.2.2.d., the group referred to previous comments regarding published information.

One participant said she was looking for guidance, direction, and standards regarding the management of collections, including collections of objects and of information. She commented on the challenge of dealing with specialists in particular fields who do not want to give up control of collection management, adding that "somehow this policy applies to everyone but them."

Participants agreed that there should be clarity regarding what is included in the definition of information assets.

A participant suggested including a list of other instruments, so that when consultations on them take place, the links can be made to this policy.

Table 4: Section 6.3

Section 6.3.1 refers to a risk-based approach to auditing, evaluation, and monitoring. Participants stated that there needs to be more understanding and guidance on dealing with risk.

Section 6.3.6 states that "Library and Archives Canada monitors the management of published information by federal government institutions." Participants said they had interpreted this as referring to "information published by the Government of Canada." They added that the distinction between "published" and "unpublished" was "fuzzy," especially for information on websites.

A participant stressed the benefits of citing legislation to support policy changes. He added that the reporting process outlined under Section 6.3 seemed ambiguous and suggested focusing on the core elements of accepted formats. For example, Section 6.3.2 refers to an audit every three years but does not indicate when the annual cycle should start. Should it correspond to the fiscal calendar? Further detail is also needed on the depth and breadth of reports and the reporting vehicle.

"It seems you are establishing a very resource-intensive central or top-level management framework," said a participant. She noted that the responsibilities used to be located more at the departmental level. In the past, there was more diversity of practice and less standardization. Hélène Valin replied that the draft policy calls attention to areas of reporting and auditing that need to be further developed in collaboration.

Another participant suggested adding a statement at the beginning of the policy, after the objective, as follows: "This policy, along with companion directives, standards, and guidelines, sets out the policy requirements, accountability framework, roles and responsibilities, and best practices which will govern the management of information in the Government of Canada."

Table 5: Section 7

Regarding Section 7.2, participants asked why the Secretary of Treasury Board would only "temporarily" adjust the frequency of reporting requirements. They suggested deleting the word "temporarily."

Regarding delegation, participants suggested that there is a need for training and evaluation and that the expectations should be clear. There should be more information about what people are expected to do, on how to delegate, and on the models to use.

Participants suggested consulting private industry regarding the government's IM needs. For example, the Government of Canada could ask Microsoft to develop an option to include metadata when choosing "save as." It was also suggested that job descriptions be linked to this policy, so that IM becomes an integral part of job descriptions.

Participants said the consequences mentioned in Section 7.1 should be applicable to all Treasury Board policies, as is done in the Financial Administration Act.

Part Two: Discussion Topics

Table 1: Policy Objectives and Provisions

Participants suggested removing the reference to the "life cycle" of information in Section 5.1 and inserting it into sections 5.2.5 and 5.2.7. They added that the wording should be simplified.

They observed that something was missing both from the context and from the "expected results" section and suggested adding to the "expected results" section the idea that Canadians at large can access information as a public resource. This section should also refer to the reuse of existing documentation.

Participants suggested adjusting the wording in Section 5.1 to read "...collaboration within and across organizations...."

Discussing governance and accountability, participants stressed that managers and employees must understand their roles and responsibilities regarding the management of information. They noted that this is something that could be measured.

Table 2: Policy Implementation – Feasibility

Participants discussed the need for government-wide technology that makes IM easier.

Gaps

One gap with regard to implementation is the capacity of government employees to fulfill the policy's requirements.

Another question is how to maintain a legacy of records – how to create a government-wide plan to preserve the heritage of government. It is important to not simply publish policy and leave departments to implement it. TBS needs to build awareness and ensure that there are appropriate tools in place to help departments execute policy. Also, the policy should be implemented in phases ("graduated compliance") and should come into effect in December 2007.

Suggestions for policy implementation

Participants discussed the use of directives to encourage good records management practices in government. With the Federal Accountability Act being passed and "duty to document" guidelines being drafted, this is an opportunity to improve IM and to enable information technology towards this end. Standards now under development in government (such as metadata standards) should become mandatory under this policy.

Participants suggested that a percentage be allocated off the top of each departmental budget for IM. In addition, departments should develop a phrase such as "the duty to document" in order to align IM with business processes. It was suggested that smaller agencies with common goals could form partnerships or share services.

A participant commented that one issue is the low status given to IM, adding that "we are clerks in the basement" – and this has to change.

Another issue, said a participant, is the capacity of partners to enable departments to deliver on their obligations.

A participant agreed about the importance of having tools to support policy implementation and suggested that central agencies could do more in this area so that not every department has to develop tools of its own. The "modern office worker" needs help organizing herself to do business and meet IM obligations, she said. Guidelines for managing email are focused on records management, but office workers need practical tips, tricks, and best practices. "Until we get on top of the email issue, we aren't addressing one huge piece," she stressed.

Table 3: Directives, Standards, Guidelines

Directives, standards, and guidelines should be congruent with external standards, said participants.

Participants also recommended that employee responsibilities be outlined in this policy.

It was noted that implementation costs are incurred in one area, while the results are seen in another. This is something to keep in mind when promoting how to better manage government information.

Regarding tools, participants called for instructions on "what to do when."

They suggested that the whole community, including business people, should be involved in developing standards.

There should be more exchange between departments, one participant recommended. "We all have best practices to share," said another, but there is no mechanism or secretariat to communicate them. "We are always underselling and undermarketing what we do."

Regarding compliance, a participant summed up his recommendation by stating that "what gets inspected gets respected."

Another participant commented on the complex issue of intellectual property and noted, "it is almost impossible to get the expertise you need 'just in time.'" Capacity issues regarding expertise and resources exist, and IM professionals are needed to teach people how to maintain proper records. Treasury Board must work with the organizations being consulted at this meeting.

Table 4: Management of E-records

Participants discussed the information life cycle and commented that the adoption of the e-record as the official record would require the development of business processes to ensure its integrity.

There is a need to ensure that classified information is secured consistently across departments. Participants also recommended being more aggressive in developing appropriate RDAs (Record Disposition Authorities) to reduce the paper burden, and centralizing business processes.

Table 5: Consequences for Non-compliance

Non-compliance results in a lack of documentation to support decision making and legal proceedings, said participants. When organizations are challenged, they must go into litigation without material to support them in court. One important issue is the authenticity of documents. For example, when supporting material is not made part of the official record, the integrity of the information can be challenged.

Another consequence of non-compliance is the existence of "orphan records." These partial records are missed when records are destroyed. They then can be taken out of context, and this presents a great risk.

There are particular risks in relation to IM specialists. One is that there is no clear definition of an IM specialist. This means that anyone can claim to have this expertise. To ensure high-quality expertise, Deputy Heads should look carefully at the backgrounds of those they hire.

Many specialists who do have the expertise are leaving government, and the overall level of IM expertise is diminishing, said participants. In addition, the requirements are broadening, because there is a convergence of professions in records management, including library science and data management. Many people specialize in narrow areas of expertise without a broad knowledge base.

Closing Remarks

Hélène Valin reviewed some of the main points raised during the session:

There should be a focus on the behaviours to be created through this policy.
The policy should include information on employee and manager responsibilities.
Policies should be consistent in their approach.
TBS should consult business managers.
There should be an audit trail.
Employees and managers need to know what their responsibilities are and have the tools to meet those responsibilities.
"What is inspected gets respected."
Managers and employees must understand their challenges and the need to challenge departments.
This era of policy change is a clear opportunity to improve IM, and TBS should take advantage of it.

Small Group Discussions: June 29

Part One: Specific Comments on the Draft Policy

Following the introductory presentations, participants discussed the draft policy in small groups and then presented initial comments to the plenary.

A participant said if there are consequences for the lack of implementation, then resources should be provided for implementation.

Others expressed concern about the material that had been removed in order to make the new policy shorter and more concise, asking where that material will be addressed. They added that some of the remaining material is vague and difficult to implement. Some references point the reader back to parent legal documents, and these references make the policy even less clear. Supporting material is needed, such as the audit table that will be used for individual departments, and the expected results should be clearer.

Other key issues raised included how to implement and monitor consistently across departments. Is it appropriate that different departments achieve the same thing?

Participants recommended prioritized implementation of different policies. They also asked how the relationship between policies is mapped.

One participant suggested turning this policy into legislation to make it a fully enforceable document. Another participant stressed that the policy should indicate clearly that the information being managed belongs to the Government of Canada.

Another participant commented that there were gaps in the policy, which is very focused on gathering and organizing information and not on helping people find information and gain access to it. She added that some information is owned by external parties but is needed by employees for decision making. This type of IM is done by libraries and is not addressed here.

Table 1: Sections 3, 4, and 5.1

Making a distinction between an MGI policy and an IM policy, a participant explained that IM involves working with government information but does not include published information. Currently, this policy does not include much of the work being done by libraries, she observed, adding that this may be acceptable in order to keep the policy simple.

A participant suggested that not everyone will understand the reference in Section 3.1 to Governments Strategic Reference Models.

Participants recommended using the word "accountability" to strengthen Section 5.1. They added that it should make reference to external stakeholders and partners.

Regarding Section 4 (Definitions), a participant asked for clarification on whether this policy deals only with government information or includes information acquired from outside sources.

Greg Renaud clarified that this is meant to be a policy for IM, rather than one simply for government records. Thus, it should be broad enough and comprehensive enough to reflect this bigger picture, while still remaining relatively simple. Other instruments can supplement this policy and address issues that are more specific.

Another participant questioned the distinction between published and unpublished information, saying that this is a false distinction in the digital age. She said that while the current definition of published information is not arcane, it is difficult to work with.

Another speaker commented that the definition of records is no longer correct.

Participants suggested that the word "information" be added to the glossary and that this definition integrate all the different usages of the term.

Table 2: Sections 5.1, 5.2, and 6.1

Referring to Section 5.1, participants suggested ending the statement after the phrase "service delivery" and deleting the rest of the sentence, which only elaborates on the basic objective. They expressed concern that the reference to preserving information of historical value would imply the acceptability of deleting other information once program objectives had been achieved.

When discussing Section 5.2, participants acknowledged that a return on investment is hard to prove financially. However, they called for some tabulation of an organization's performance that numerically quantifies the return on investment.

There should also be some reference to the auditing document, even if it is an external document, so that people can refer to it to gain an understanding of the expectations.

Participants raised the possibility of auditing IM more often than every three years. Three years is a cycle normally applied to systems and organizations that are already achieving their goals. For a new policy, organizations may need to be audited regularly or continuously. Also, some risk analysis should be applied so that organizations with a bad history or whose work is more dependent on information would be audited more often.

Participants also suggested that there should be greater emphasis on technology. The auditing process should evaluate whether technology is being used to support the high-level goal of collaborating across organizations.

One participant commented that sections 5.2.3 and 5.2.6 are the same.

Another speaker observed that this policy reflects "a very records-centred approach" and does not capture the idea of big information systems (and IT systems) doing many things with different pieces of data.

Criticizing Section 6.1.1 as being too vague in its requirements of Deputy Heads, participants recommended replacing it with the following wording: "Recognizes sound information management as crucial to the comprehensive and effective attainment of service delivery goals and is responsible to ensure that program delivery includes IM practices."

Participants noted that the service delivery focus seemed to have faded. The statements on expected results and objectives emphasize that IM should support service delivery, but that fades when the duties of senior officers are outlined. There should be more correlation between the duties of senior officers and the expected results of the IM program.

Regarding sections 6.1.6 and 6.1.2, participants said there should be more emphasis on digital information and on ensuring that decision-making processes are fully documented.

Participants commented that Section 6.1.4 refers to governance only and asked if the intent was to support the implementation and management of information. The current wording provides an opportunity for a Deputy Head to walk away from responsibilities, they said.

A participant commented that "for the purposes of this policy" in Section 6.1.2 is a weak phrase and suggested adding a verb so that the phrase reads "for the purposes of [enforcing or implementing] this policy."

Table 3: Section 6.2

Participants criticized Section 6.2.1, commenting that it does not clarify Treasury Board's role in monitoring IM.

Regarding Section 6.2.1.b., they suggested replacing the word "helping" with the word "ensuring."

Participants expressed concern that the phrase "at the discretion of institutions" (in reference to the destruction of information) in Section 6.2.2 is confusing and leaves the matter too open. They suggested rewording this section for greater clarity.

The policy should also include material on what libraries, statistics services, and other IM areas do with information, they said.

The description of Library and Archives Canada in Section 6.2.2 is more oriented towards records management, said a participant. There is also a huge social science and humanities collection, which must be managed by government employees. Other national collections also exist in other departments. The policy should mention the body that acquires and licenses information, because employees must go through that organization to coordinate the acquisition of information.

Table 4: Section 6.3

A participant commented that Section 6.3 seems to reiterate the responsibilities of various departments and may not be needed.

Referring to sections 6.3.5 and 6.3.6, a participant asked how the strategic planning process would work between the Deputy Head, Treasury Board, and Library and Archives Canada.

A participant recommended ending the sentence in Section 6.3.1 with the word "departments" and deleting the material on Treasury Board policy.

Another participant observed that sections 6.3.2 and 6.3.3 will have a big impact and will require considerable resources. He suggested encouraging Consulting and Audit Canada (CAC) to increase its human resources for auditing and monitoring.

Referring to the phrase "a timely fashion" in Section 6.3.3, a participant asked if this could be made more specific.

A participant commented that, currently, information audits are not conducted. To go from "never" to once every one to three years is not only unrealistic, it will not be possible given current resources.

Another speaker criticized the terminology, saying it was "all over the map." There needs to be greater precision in the use of terms like "auditing," "monitoring," and "evaluation." For example, an audit has legal consequences, while monitoring is more about what is going well or poorly.

Treasury Board should ensure that IM plays a key role across any policy, a participant recommended.

Table 5: Section 7

Participants commented that the opening statement in this section is too weak and does not present real consequences for Deputy Heads. They suggested the following wording as an example with greater clarity regarding the authority and responsibility of Deputy Heads: "The people/Government of Canada expect that the Deputy Head of the department takes full responsibility for...throughout the information life cycle...."

With this type of high-level statement, Section 7.3 should stay at a high level – the consequences should be applied at the senior level.

Another participant expressed support for this last statement, commenting that IM was not in his job description. If it is to be included in job performance evaluation, this should be negotiated with the human resources department and the unions. He suggested putting IM into the job description of the Deputy Heads and tying it to their performance pay.

Regarding Section 7.2, a participant spoke against the idea of suspending Disposition Authorities and/or other delegated authorities, commenting that this would prevent people from doing what was required.

Participants suggested that the consequence for not having a good IM program should be the withholding of program funding. This consequence should be applied not in the first year but in subsequent years. The repercussion in the first year should involve "a humiliating process" whereby the Deputy Head must explain to high-level people why the organization has fallen short.

Part Two: Discussion Topics

Table 1: Policy Objectives and Provisions

Participants discussed the management of information through its life cycle and wondered whether this policy should have a strong business focus (in order to help business run better) or whether it should focus on clarifying IM aspects and activities.

If IM and records management is everybody's responsibility, said a participant, then this could be indicated under "expected results" (i.e., everyone is expected to manage information). In certain cases, IM should be part of the job description.

A participant observed a statement in the existing policy indicating that all employees are responsible for the management of information in their custody and that this reference had been deleted from the current draft. She stressed that it must be retained.

Participants commented that there is an organizational component to managing information and discussed the requirements for employee training. For example, all employees should be taught that the information they deal with at work is not "their" information – it belongs to the Government of Canada. One participant suggested that Treasury Board require new employees to pass a test on IM and sign a statement indicating that they know the information they collect belongs to the government. The same requirement should exist for those leaving their jobs.

Table 2: Policy Implementation – Feasibility

Participants concluded that it would not be feasible to "implement the policy" as such, because it does not include anything against which one could monitor compliance. The requirements outlined in all subordinate documents, however, could be implemented.

They presented a diagram showing how departments could proceed through a process of goal setting. Departments would identify tasks and objectives to reflect their current situation and budget as well as their interpretation of the rules. This goal-setting activity would include a Treasury Board representative and would take place in the first year.

In the second year, the same group would meet, but instead of a Treasury Board representative, an auditor would attend. The auditor would present the rules and show how to calculate one's score against one's objectives. As a result of the audit, the organization would pass or fail. Passing could have benefits such as good publicity or bonuses. Failing would result in punishments or embarrassments.

Clusters of departments could also undertake this process. Through this process, the instruments could be improved with each successive year. Departments with an extensive list of tasks could receive additional resources.

Participants commented that if Treasury Board does not provide the monitoring function, each department must provide its own person to conduct an independent audit. This requires the creation of a new role and would have to be funded within the departmental budget.

There should also be communication and awareness programs as this policy is rolled out. Ultimately, all the processes should be embedded in the software suite on desktops so that employees will naturally perform these functions as they create documents.

A participant suggested that Treasury Board consider creating a working group to identify implementation tips, such as integrating IM into every agenda and committee within a department.

Table 3: Directives, Standards, Guidelines

Participants asked what instruments should come from central agencies: policies, directives, standards, guidelines, tools – or all five? Indicating that policies, directives, and standards are mandatory suggests that they should come from a central agency. But none of these can be developed in isolation, and the best way to get buy-in is to have each instrument developed by the communities that will feel the greatest impact.

It was noted that Library and Archives Canada already has standards and does not plan to develop new ones. Instead, it wants the government to endorse the existing ones. If this is not possible, then "let's develop what we need together, rather than having it imposed."

Participants also discussed the importance and significance of good communication and marketing.

Table 4: Management of E-records

Participants identified many challenges associated with the management of e-records. Many of these challenges have to do with the fact that the whole area is still in evolution. One challenge is that there is no ownership of processes. The processes used to manage e-records are extrapolated from the paper world and do not always work for e-records. Advice and guidance around standards is still being informed, drafted, and developed.

Participants also commented on a lack of clarity with regard to definitions and noted that the definition of a record is unclear.

There needs to be input from business people in order to streamline processes, they said. They suggested consulting private industry to see how these organizations handle the management of e-records and establishing a central mechanism to capture best practices within the federal government as they develop.

In terms of strategies, participants commented on the need to examine processes, document them and link existing tools to policies in development.

In the bigger picture, said a participant, it is time for central agencies to demand solutions from the IT community "that solve more than 30 per cent of our requirements." IM should drive the IT industry, not the other way around.

Participants noted that IM also has a security element. The security of a network is one requirement, but ultimately it is the information that is being protected. In this light, a participant recommended using the term "e-information" rather than "e-records."

Table 5: Consequences for Non-compliance

There needs to be consistency in the measurement process, said participants, so that people know what they are being measured against. In terms of consequences, this policy should be consistent with other policies. Participants recommended that consequences be related to pay.

Regarding Section 7.3, participants commented that performance evaluation at the senior management level would cascade down to address employees' performance as well.

They suggested that the results could be published under access to information provisions, making departments more conscious about their performance. This could have both positive and negative impacts.

Regarding evaluation, a participant recommended a scoring system and a requirement that organizations not achieving top marks must improve their performance.

Another participant asked if there was a role for the Information Commission. He commented that access to information is only a consequence of good record keeping.

Closing Remarks

Hélène Valin reviewed some of the main points raised during the session:

Compliance is a key theme, and it is important to reflect on goals and expectations.
Policy content needs to be "doable."
Definitions (such as the definition of information) should be reviewed.
The linkages among policies should be outlined.
Command of an organization means command of its information.
Positive reinforcement and buy-in are the best ways to achieve results.
The policy cannot be implemented as it currently stands.
Employees should be included in the policy.

Practical ideas on compliance were presented.

Appendix 1: Attendance

TBS Staff

Denise Charbonneau

Jeff Cinnamon

Robert Coffin

Gregory Renaud

Hélène Valin

Consultant (Facilitator)

Paul Castonguay

Participants: June 27

Marie-Claude Côté, CIDA

Jane Dubé, CICS

Peter Forsyth, NRCan

Lise Gour, BC

Lesley Hoermann, NRCan

Barry Honeyman, FAIT

Tom Nash, TC

Vicki Ross, SC

Stephane Thibodeau, CIDA

Participants: June 28

Joanne Hauck DeMorest, OAG

Claude Donovan, CSIS

Alexandra Freeland, CNSC

Julia Goodman, FO

Rhonda Healey, LAC

Susan Hurst, DRDC

Emilia Kolcon-Lach, OSFI

Nicole Laframboise, CSE

Diane Leduc, SC

Danny Moore, LAC

Heather Moore, PSEPC

Andrew H. Morgan, IC

Cathy Niman, CSIS

Fabio Onesi, LAC

David Peterson, INAC

Coreen Saikaley, PC

Suzanne Sauriol, CSIS

Linda Swanston, CSIS

Catherine Zongora, PWGSC

Participants: June 29

Gail Anderson, TBS

Minda Bojin, PWGSC

Emile Daniel, FO

Suzanne Duguay, FO

Charlene Elgee, CIC

Sue Franklin, LAC

Beverly Graham, BC

Donna Hellmann, MPCC

Patricia Jackson, PSEPC

Danielle Jacques, AAFC

Carole Julien, CFL

Léo N. J. Maisonneuve, CIDA

Ann Martin, RCMP

Sandra Porter, RCMP

Scott Proctor, ARMA

Mahmood Rasheed, CPCL

Andre Richer, CFIA

Diane Santerre, CRTC

Leslie Still, HC

Suzanne St. Georges-Trépanier, CSC

James St-Jean, HC

Edward Tompkins, CAC

Scott Warren, PWGSC

Jean Weerasinghe, CAS

Emmett Will, CPCL

Cabot Yu, CIC

Appendix 2: Acronyms and Initialisms

BTEP Business Transformation Enablement Program

CAC Consulting and Audit Canada

CIOB Chief Information Officer Branch (of Treasury Board Secretariat)

FMI Framework for the Management of Information

IM Information Management

IMCC Information Management Capacity Check

MGI Management of Government Information

MI Management of information

RDAs Record Disposition Authorities

TBS Treasury Board Secretariat

Date published:	2007-02-02
Date modified:	2007-01-18
Date reviewed:	2007-01-18

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