MGI Policy Renewal Consultations, August 30, 2006

Table of Contents

MGI Policy Renewal Consultations, August 30, 2006 (Program Managers)

Part One: Managing IM in the Context of Program Delivery

Table 1

Table 2

Table 3

Part Two: Additional Discussion Topics

Management of E-records

Discussion

Risk Management

Discussion

Duty to Document

Discussion

Consequences for Non-compliance

Discussion

Next Steps

MGI Policy Renewal Consultations, August 30, 2006 (Program Managers)

Introduction

The Treasury Board Secretariat (TBS) consulted a group of Program Heads about the renewal of Management of Government Information (MGI) policy during this meeting. Hélène Valin of TBS presented introductory information while Paul Castonguay facilitated.

The discussion topics were:

• Managing IM in the Context of Program Delivery
• Management of E-records
• Risk Management
• Duty to Document
• Consequences for Non-compliance

Part One: Managing IM in the Context of Program Delivery

The participants discussed the topic in three small groups. Each group then reported its conclusions back to the plenary.

Table 1

Stephanie Latimer reported back.

Senior management must provide stronger directives and enable consistency among Program Heads to ensure they have time, resources, and clear objectives in the management of IM. Currently IM and Information Technology (IT) are disconnected. IM often enters later. Nevertheless, it is important to build the relationship between the two; they should be allies rather than opponents working against each other.

What can get Program Heads interested in doing IM? In addition to having a policy, programs need three elements to enable Program Heads to do their job: incentives, tools, and direction.

To better achieve objectives, Program Heads must understand the program's business needs and IM's benefits for the business. They need to know how to determine which records to keep and which to discard, when to do clean up, etc., and be able to work from an IM perspective. In particular, they must fully appreciate what needs to be kept to comply with the law. They should also be mindful of issues such as physical storage space, migration considerations, and access to information.

Program fixes that need significant investment are indicative of serious problems with the department if it cannot resolve the gaps even after investing significant time and resources.

Table 2

Sylvain Gagné and Peter Cowan reported back.

Resource requirements and availability are key issues for Program Heads. Meanwhile, several notable problems exist within IM. First, departments create and collect information but lack the ability and an adequate system to manage the information. They also lack clarity on the specific tasks involved and lack guidance to manage the new technology, which has exaggerated the problem. In addition, delivery programs that are stressed to deliver on output are unable to do proper IM.

Another problem is that organizationally departments operate as if IM were separate from the business plan and process. Departments do not spend money and energy to train staff on IM expectations.

The new IM policy needs solutions to these problems. Even before a program is approved, there should be IM funding in place and a documented IM plan. IM issues must be clarified and incorporated in the business process and monitored accordingly. The resulting cultural challenges require massive effort, including behavioural change. An environment that supports policy implementation must include training, guidance, and clear orientation.

Staff need training on how to use information, how to name and classify documents, what to do with a report after producing it, where to store it, when to retrieve it, how to find it quickly and accurately, what the implications are on the business process, etc. Training should include how to incorporate IM in the business process; IM staff must know the business to help manage the information.

A key challenge to evaluating the effectiveness of policy implementation is setting standards and expectations – including IM training and business orientation for staff. TBS should measure not only the "whats" but also the "hows" of the business process, whose model will differ across departments. This type of performance-based evaluation represents a cultural shift. Moreover, the evaluation should allow room for growth, improvement, and continual evolution, monitoring, and auditing.

Table 3

Gerald Robertson and Marie Steward reported back.

Program Heads are concerned about resources and resource requirements in terms of upgrading infrastructure as well as implementing the policy itself. There may be new roles or requirements, and existing roles and requirements may change. There may also be incremental requirements for reporting to the Minister on IM.

However, the picture is not as bad as it is painted. For example, departments already have existing records management systems that are working, with retention schedules in place. Paper files still exist and are being used, such as contracts, human resources records, financial management records, etc., and especially documents required by courts. Briefings, memos, and other reports to Ministers still need paper as well as electronic forms.

On the other hand, the multiple copies of emails and other files on shared drives need to be addressed. Some may be encrypted, moreover. By default, emails get disposed of, as they supposedly have no value, but this may not be so in all cases. Another issue is that there is a scientific culture in some departments where the scientists own the research information and publications. At the same time, government must manage this information.

Regardless, communication and education are essential for all managers and staff, and things must be kept as easy as possible. Further, there must be realistic implementation in terms of culture and retention decisions that consider cost factors and the usefulness of the data. A key part of the evaluation criteria should be whether something adds value to the business process.

Much greater direction needs to come from the TBS, with Deputy Ministers (DMs) involved, in particular with respect to what information needs to be maintained to be accountable. Program Heads must address issues from both the legal and policy perspective. For example, to be able to refer back to a decision-making process, would a paper or electronic document be the best way? Program Heads must also handle problems more proactively.

Part Two: Additional Discussion Topics

The participants broke into two groups to each discuss two topics and then report back to the plenary. Following each report, participants at the other table added their comments and the large group discussed particular issues of interest.

Management of E-records

John Ekholm reported back.

In the Policy on the Management of Information Consultation Plan, the opening paragraph introducing this topic notes that automation has often fallen short of expectations. It has often led to the elimination of support staff positions that were handling the IM program requirements, without ensuring that those requirements were built into the automated solution. The result is that program delivery officers are expected to manage information without proper tools or a good understanding of their obligations.

This introduction reflects this group's impression, Ekholm said. In the hardcopy days of the past, programs had robust records management systems. However, in the conversion to e-records, things were done in an ad hoc way. Rather than transforming the hardcopy regime to the electronic world, the conversion simply automated a poor process. There is a great deal of information stored in emails, hardcopy files, shared folders, and personal folders, making it very difficult to find information.

How much can be addressed at the program level? It must do the implementation, but the enterprise level must provide the technical support, and guidance and direction need to come from a higher level. A major challenge faced by every department is having to scan numerous hardcopy documents. One suggestion is to keep records that only include titles and references to indicate where the documents can be found.

Discussion

Participants at the other table agreed that the report was an accurate articulation of the situation. The conversion to technology took place very rapidly. Programs lacked capacity to deal with the change, and things never caught up.

Ekholm added that when secretarial support was eliminated, managers had to learn to type their own letters. At the same time records management systems also departed. Programs now recognize the need to return to fundamentals. After years of research, his organization now has a system that prompts the user to specify whether or not every document that is accessed should be filed corporately. In addition, the system has a powerful search engine that can do comprehensive searches on every file and database in the organization.

Another participant emphasize that any new system should give value added to the business process.

Risk Management

John Ekholm reported back.

Ekholm noted that programs must prioritize IM needs with other requirements. Legal requirements come first, followed by policy requirements, then operational requirements. Program Heads must have a clear understanding of the policy and direction. They also need tools, an accountability framework, and consequences.

Some of the current tools are not used effectively. Until they become more user friendly, and until managers see the value added, it is difficult to convince managers to compromise their program's operation and operational requirements to meet IM policy requirements.

Another aspect relates to staff leaving their positions. Departing staff should be required to remove all personal information and leave behind corporate records. The corporation must have access to these records, which often contain information critical to operational requirements.

IM should be introduced as part of the corporation's business and in a way that fulfills business requirements. They must help managers fulfill operational objectives as well as meet IM objectives. It is really a marketing issue of "selling" IM to people. IM can be defined as overhead and something cumbersome, or it can be something that helps managers do their jobs more effectively.

Discussion

A participant agreed that IM needs to be a visible part of the corporate profile. It must continue to fulfill requirements and there must be ongoing ways to assess performance.

Ekholm said that most Program Heads manage information in a way that fulfills current but often not long-term operational requirements. Managers also lack time to reorganize their files. To facilitate their commitment to change, IM must implement tools to help managers meet operational requirements more effectively, find information more efficiently, as well as meet policy and legal objectives.

Another delegate added that behavioural and cultural change is needed. Employees need training on how to use software and utilize it as a tool in the context of the program's business. Those already trained need orientation on bridging the software and their job. IM staff who know the business are better positioned to find IM solutions. Business and process owners should also know how to solve problems via IM. Both sides must learn the business and how to manage information differently in order to fulfill policy obligations. This is a challenging task to manage.

The next participant said any change must give value added; it cannot simply be an obligation imposed by TBS. "If it's about helping people get the job done, that's the reason you do IM," he noted. Program Heads will naturally think of IM when they do planning and other tasks if they can see the value added. IM must develop a process and a system that better delivers the process for the manager. Moreover, new obligations often require new resources.

A delegate mentioned that IM is both about doing the job better and using information better. Another said IM also serves to better enable information exchange for collaborative work within and among departments.

Finally, a delegate agreed that IM cannot be an "add on," simply with a Management Accountability Framework (MAF) layered on top; IM must be integrated in the business.

Duty to Document

Sylvain Gagné reported back.

This group first asked two questions: What level of the organization would the duty to document impact? And would records managers need to be created throughout the organization? The participants concluded that the core of the business must have a process in place and people to manage that process. There must be clear decisions regarding what the organization should document, when, and where, being mindful that there is an element of risk management involved. The ability to recover a document is critical.

TBS needs to provide basic guidelines on what to document, and organizations need ongoing assessment of the decision to document and the context of that decision. Senior management must identify the level of responsibility based on specific criteria. All levels require clear guidance, communication, and assessment methods.

How to implement is another question. The five-year plan should be an aggressive plan that is done intelligently, without overreacting on the recommendations of the Gomery report. Managers must ask whether automation is necessary and how best to automate each task.

Lastly, the group asked whether the government archival mechanism should be done collectively via joint partnerships.

Discussion

A participant noted that programs need clear guidance on the levels of decisions and instructions that need to be documented, such as whether it is executive-level decisions only or all instructions from management to employees. It is not feasible to consider an email or any draft document as a corporate record to be filed centrally. If the document explains a significant decision, especially involving impact on the public, a record must be kept. To avoid information overflow, the cut-off must be clear.

Another delegate said the duty to document extends to online consultation and BlackBerry messages if that record led to policy direction. However, keeping everything is not managing information. One must determine what to keep and delete information that is no longer useful.

The next delegate added that IM needs to provide the criteria and tools to help people determine legal requirements and incorporate them up front. Guidelines for overall policy direction are insufficient; further breakdown is needed.

The first participant said the bottom line is having clear implementation-level guidelines. He also noted that sometimes it is riskier to keep certain records. For example, a draft sent out for comments may later be shredded or so dramatically changed that there is risk of potential damage to keep it.

Consequences for Non-compliance

Sylvain Gagné reported back.

The group emphasized that consequences should be clear and specific at every level, including details of what constitutes non-compliance and different magnitudes of infraction and their related consequences. The lower level has a particularly large role to play in meeting policy requirements.

It is hard to apply consequences without clear standards and guidance. The group suggested a performance-based approach. However, TBS should be mindful of the risk of overreaction to avoid consequences. TBS must also itself meet standards and guidelines and have consequences. "Apply it to yourself first."

A clear implementation plan is needed, including how to deal with older records, giving consideration to cost and usefulness. Departments must distinguish between the different types of information that may be needed in future. The implementation plan must specify a point in time to begin retaining records in the new system.

The group questioned the meaning of item 7.2 in the Draft Policy on the Management of Government Information. The item states that, based on analysis of monitoring and information received, the TBS Secretary may temporarily adjust the frequency and nature of the deputy head reporting requirements and initiate actions to suspend Disposition Authorities and/or other delegated authorities. The issue of taking action to "suspend Disposition Authorities" needs further discussion.

Discussion

A delegate noted that the policy must plan for departments to meet policy expectations over time. Departments need sufficient implementation time before consequences for non-compliance can be applied.

Another participant commented on item 7.3, which states that "Deputy heads will take into consideration employee conformance with departmental information management requirements for the purpose of performance evaluation." She said that performance evaluations are no longer done except for either very good or very bad performance. For most public servants, they are no longer effective and are simply documents kept on file.

Instead, she suggested bringing in another organization to manage IM in that department. This is what the private sector does if a critical task is not being performed adequately – shuffle responsibilities or give the responsibility to another organization. Taking away the responsibility and authority would be an effective consequence.

The next participant expressed uncertainty as to the practicality of this solution. If IM is part of the department's business, it cannot be run by some other organization or by TBS, he said. Moreover, if the IM responsibility is passed elsewhere, it does not help the department's own staff manage the information better. He suggested having TBS provide the department with a more prescriptive approach. The department must be required to review the way it is defining its regulations and standards, training its staff, and delivering services. Very importantly, it must require its staff to know the business.

The participant who suggested bringing in an outside body said that the department should then bear the entire cost of the outside body. There was much agreement among delegates.

Another participant noted that a consequence does not necessarily have to be a punishment. It should, however, meet the goal of doing the job better. The group discussed incentives and rewards, including documenting best practices, offering more opportunities for training and sharing, and showcasing value added. Human resources management and financial management are areas that can provide further ideas on how to encourage IM.

Next Steps

Valin noted that the day's consultation with Program Heads had resulted in very different feedback compared to that from the consultation with IM Specialists. She invited the delegates to recommend colleagues to participate in the next consultation meeting scheduled for September 13. In particular, she said showcasing is a key part of the IM community and acknowledged it as a very positive component of compliance.