MGI Policy Renewal Consultations, September 14-15, 2006

Table of Contents

September 14

MGI Policy Renewal Consultations: MGI Senior Officials and IM Community

Introduction and Welcome

Results of Consultations on the New IM Policy

Highlights of the New IM Policy

Plenary on Key Issues Identified in Group Discussions

September 15

MGI  Policy Renewal Consultations: MGI Senior Officials and  IM Community

Introduction and welcome

Results of Consultations on the New IM Policy

Highlights of the New IM Policy

Plenary on Key Issues Identified in Group Discussions

September 14

MGI Policy Renewal Consultations: MGI Senior Officials and IM Community

Facilitator: Daniel Normandeau

Introduction and Welcome

Following the introductory and welcoming remarks by Gina Smith and Ken Cochrane, participants expressed their views and their expectations for this Information Management (IM) Policy consultation meeting with Information Management Committee (IMC) and Management of Government Information (MGI) leads, hosted by the Treasury Board Secretariat (TBS) of Canada.

A delegate asked for greater clarification on the linkages between the IM Policy and the Federal Accountability Act (FAA). Cochrane explained that the linkages are indirect rather than direct, represented by the duty to document and the themes of transparency and accountability that drive the policy.

Gregory Renaud, a speaker who would later present highlights of the new IM Policy, added that the draft policy contains two key elements: the requirement to document the decision-making process, and an acknowledgement that there are specialists of IM but that IM is also the responsibility of every employee. Cochrane noted that each organization must have people who understand the policy, rules, and practice, and know how to approach the problem.

A participant asked for clear definitions of roles, in particular of IM and information technology (IT), as both roles manage information. The work of government depends on information, with or without technology, he said. The interesting discussion is around "who is responsible for managing what information within each organization."

Another delegate pointed to a need to bring IM to a real level for the average employees so that they will view it as something very important to government. He suggested providing greater resources and clearer rules.

Hélène Valin, the speaker who would next present the results of the consultations on the new IM Policy, noted that communication is key.

A participant commented that the term IM often refers to records management, either in the context of library or other information resources. Cochrane replied that all groups that have been consulted in fact wanted clarification as to the definition of IM. Both Valin and Cochrane emphasized that the IM Policy is still in draft form and open to input.

Results of Consultations on the New IM Policy

In a plenary discussion following Hélène Valin's presentation of the results of the consultations on the new IM Policy, a delegate said he is in favour of the new policy but expressed concern that it lacks a horizontal assessment of its implication across all departments. Without allocating additional budgets, the policy will require each department to commit a certain percentage of its existing budget to IM. Thus each department is being asked to invest more but at the same level of resources.

Valin replied that the purpose of the consultation process is to build on these pieces and continue to develop the draft policy. The most recent draft is dated September 11. Currently only the sheet of policy instrument definitions is finalized. All concerns and issues are to be categorized under the definitions identified there: framework, policy, directives, standards, guidelines, and tools. These instruments will all be mandatory, she noted. After the consultations are completed next week, TBS will be examining whether the draft policy has the required links to support the development of these instruments.

Valin added that some departments have developed action plans according to the 2003 Policy on the Management of Government Information (2003 MGI Policy), while others have said the policy renewal provides a good opportunity to move forward on implementation.

A participant said the "showstoppers" – implementation strategy, effective date, need for real consequences, lack of capacity, lack of senior management buy-in – that Valin spoke about in her presentation are fairly broad in scope. Without a framework and action plan in place, she expressed uncertainty as to how accountability translates to activities and implementation issues.

Valin replied that the day's discussion was to build on the showstoppers by focusing on three key issues: "what does success look like," consequences, and implementation strategy. TBS is still accepting recommendations for the policy and looking for opportunities and strategies to move forward on successful implementation.

A delegate said he was interested in what is meant by "IM" in terms of records management, legal obligations, and ownership of information.

Cochrane noted that information itself is both a process and a tool. The policy aims to address government's current immaturity in managing information by making the guidelines, directives, and other instruments more prescriptive. This initiative requires the participants' input, he said, as departments must be able to accept the policy and work with it, and all parties must understand the impact of the policy. The renewal is an opportunity to provide higher professional capability to manage information and to work together cohesively among all elements of IM.

A participant cautioned against arbitrarily imposing an effective date for implementation. It would create stress and tension in the system, she said, and may pressure departments into a reporting mode rather than focusing on implementation. She recommended having the Deputy Ministers (DMs) propose their own implementation date.

Another delegate said the draft policy is already quite good but expressed concern about the culture shift required. It will affect every level of government and every activity. He also observed that the work of government is still defined by programs and departments, each with its own resources and budget. He emphasized that the policy must be implemented as a government-wide initiative with a common infrastructure across all programs and departments.

Normandeau summarized the key points of the discussion:

• a need to understand the policy implementation implications for departments
• effective date
• culture shift
• lack of capacity across the Government of Canada (GoC).

Cochrane assured the group that the consultation aims to understand the impacts of policy implementation.

Highlights of the New IM Policy

In a plenary discussion following Gregory Renaud's presentation of the highlights of the new IM policy, a participant noted that with the new policy there is a need to identify new links. Normandeau commented that it is a governance issue how to focus the implementation in a coherent way across government.

Another participant made three suggestions. The first was to add "accuracy and integrity of information" as a key contextual message, as these qualities are key elements of good information management. Second, he suggested rewording the key message, "Integrate IM with government business and IT" as "Define the relationship between IM and IT." Third, he said he did not see the value of spending a great deal of time on defining consequences and their specifics in the IM policy. If DMs are not doing their job, they would be either dismissed or charged. Therefore, consequences should be left to the discretion of parliamentarians and the Clerk of the Privy Council.

Valin responded that consequences have been frequently mentioned throughout the consultations. Many participants believe they are one way for the policy to have some "teeth" and for obtaining DM buy-in.

The delegate said it was more useful to try to understand why DMs, among all their accountabilities, do not see IM as being important, or why they view other issues as being more important. It is a matter of getting to the cause rather than focusing on correcting the symptoms.

Normandeau commented that culture shift is about leadership and behaviour, which impact on the policy's success. To have the right behaviours, consequences must be broadened to encompass positive elements such as incentives, rewards, and recognition. Moreover, there must be the right leadership and support to lead to the right behaviours. DMs must first believe it is in the best interest of the GoC to manage information well in order to support GoC business, and they must also have a sound capacity and the ability to support IM.

A participant said the root of the problem is that DMs do not even know what IM is and what they should be implementing. It is unreasonable, therefore, to hold them accountable to something that is not clearly defined. Referring to Section 6.1 of the draft policy, on Policy Requirements for Deputy Heads, she expressed concern that it is too broad and does not really say what DMs are expected to do or what they must put in place.

Another delegate remarked that the core challenge is that DMs are not paying attention to IM practices. Although they know IM is important and is a problem, they have no tools or definitions to work with and always have the issue put to them in a huge size. The policy must focus on tools, he emphasized.

Another participant agreed that the policy must be more specific and be implemented government-wide.

Normandeau summarized that the participants have expressed a need for a practical and grounded approach. DMs need to know a shortlist of specific things to do, to manage information in their departments. IM also needs to be profiled so that DMs see it as high priority.

A participant suggested linking Section 6.1 with Section 5.2, which describes the Expected Results of the Policy Statement. The expected results are not very specific, but still more defined than the contents of Section 6.1.

While another delegate noted that the directives will be more specific once developed, Renaud said the expected results are intended for the whole of the GoC.

The earlier participant said that in any other accountability framework, such as human resources, specific accountabilities are always tied to policy requirements and expected results. These elements cannot be separate. 

Plenary on Key Issues Identified in Group Discussions

The delegates divided into three groups, each assigned to discuss one of the following three topics:

• Building Blocks: What does success look like?
• Consequences
• Implementation Strategy

Table 1 – Building Blocks: What does success look like?

The participants noted that the 2003 MGI Policy was not implemented, mainly because the policy was issued without guidelines, standards, and tools behind it. One building block of success would be a cohesive governance framework. Another would be clear definitions of accountability. Still another would be performance measurement methods to determine whether the expected results are being achieved. The policy must specify at the outset how a DM will know whether the conditions for success have been met. Moreover, departments need the necessary competencies to implement the policy.

The larger group then provided additional viewpoints. One delegate suggested the management of electronic information, including email and e-documents, as one key area in which to show progress and success. Instead of trying to tackle every problem, a real building block and a big step would be to move forward in this one area across the whole of government, by providing leadership, resources, tools, etc.

Another participant emphasized that, to have successful implementation, these building blocks must be in place before implementation. The implementation plan must be presented along with the policy, with all the instruments already in place.

A delegate remarked that the 2003 MGI Policy was prescriptive only with respect to the records management function. Yet records management has been removed from the new policy.

Another participant observed that the recent draft policy has directives embedded in it, making it more prescriptive. In addition, he suggested incorporating copyright, access to information, and other issues. Moreover, he asked whether departments are being expected to ratify the policy, as opposed to implement it.

Another delegate noted the need for a baseline to describe what IM should look like and where the gaps are currently.

Table 2 – Consequences

In the discussion of consequences, the first question was: What real/practical consequences should be added? Participants said that the objective is to change behaviour. They identified two critical successful factors. The first is to know in sufficient detail what the desired behaviour is. Section 5.2, on the Expected Results of the Policy Statement, must be defined and communicated in detail. The second is to have the skills, tools, and support to carry out the behaviour. This group observed that these two factors are already in place.

Given these two factors, if people still do not see the intrinsic benefit, then the policy will need to have incentives or negative consequences. Since there is no single required behaviour for everyone, in order to define incentives and consequences the policy must break down the desired behaviour into roles and responsibilities.

At the highest level are roles for the central agencies, including TBS, Library and Archives Canada (LAC), and Public Works and Government Services Canada (PWGSC). At the next level, DMs and Program Management Executives (PMEs), including Corporate Services, need a Performance Management Accord (PMA) report card. The next group is the IM specialists (functional specialists) and other employees.

The DMs and PMEs have important leadership roles and responsibilities. Consequences need to be at this management level. For the IM specialists and other employees, it is very difficult to define consequences. Nevertheless, their performance must be tracked beyond the performance appraisal.

At this point the next step must be to refer back to the two critical success factors. Not much can be done beyond that. However, if these two factors are in place, there really is no need for many negative consequences, since "most people want to do a good job."

In response to the second question, focusing on incentives, the participants suggested giving financial benefits to DMs and executives, such as targeted bonuses. At the IM specialist and employee level, they recommended giving recognition and offering a reward program. There must be ways to measure success – corporate targets need to be set, and successes should be rewarded at all levels.

However, in response to the third question, whether the expected results listed in Section 5.2 are measurable, the participants said no. Some of the results are very difficult or even impossible to measure. The policy needs a baseline definition of "where we are and what 5.2 means [in terms of] where we want to be."

In the larger group, a delegate said he applauded the conclusion that negative consequences are not supportive. Another participant also agreed with putting a greater emphasis on the positive incentives side. However, he noted that there must be a clear understanding that at a certain point the line cannot be crossed. In particular, there are certain types of information, specific to each program, that are very serious.

Table 3 – Implementation Strategy

In the discussion of implementation strategy, participants noted that IM is about improving overall program performance, something very needed. IM is not a goal in itself but is dependent on other departmental priorities, tied to the overall purpose across the GoC. Currently, however, there is no method to measure success – only failure – and no clear definitions of outcomes and rules. The group suggested accessibility of information as a quick measurable goal.

The delegates also expressed a sense that implementation is a journey, not an end, and should involve seeking a continuous set of improvements as well as identifying endpoints. There was also a sense that implementation cannot be done without new resources.

In terms of aligning with other government priorities, some aspects are government-wide and universal across departments, such as human resources and financial data and also email management. One implementation-specific discussion should be around building a business case for a government-wide electronic document management program, one that encompasses email management. It should adopt a prescriptive approach, in particular in terms of using the same software tools across the whole of government.

However, the large part the IM Policy deals with problems specific to each agency or department, and implementation must be carried out accordingly. For court files, legal obligations are a key issue, for example, and for biodiversity information the question of property rights comes into play. Part of the discussion is how much program information is really enterprise information and how these two aspects should be linked.

In summary, moving from policy to implementation requires identifying directives and other instruments, which in turn requires very well defined outcomes.

In the larger group, a participant commented that in setting out responsibilities and accountability, perhaps what the policy is really doing is seeking ratification and agreement with certain principles. Ultimately, however, departments cannot really implement a policy without a specific implementation plan.

Another delegate added the notion that, rather than seeking policy implementation as an end, TBS may be looking more for improvements to program areas and ways of managing information. He cited an RCMP program to improve the accuracy and completeness of court records as a successful implementation with continuity of program. An improvement-driven policy is needed, he said.

September 15

MGI Policy Renewal Consultations: MGI Senior Officials and
IM Community

Facilitator: Daniel Normandeau

Introduction and Welcome

In a plenary discussion following Gina Smith's introductory remarks and presentation of the IM policy renewal in context, participants expressed their views on their expectations for this IM Policy consultation meeting with IMC and MGI leads, hosted by TBS.

Noting that the policy statement is a very high-level document, a participant said he wished to ensure that the day's discussion would focus on implementation. Another delegate asked for clarification on the gaps and differences that exist between the new IM Policy and the current 2003 MGI Policy. Some departments are already engaged in the implementation of the 2003 MGI Policy, she added.

A participant commented that implementation timeframe is an important issue to discuss. Another remarked that it is necessary to know the impact of the FAA on the policy.

Smith responded that TBS and LAC would be co-hosting two Executive Roundtables, one on September 19 and the other on October 6, at which the IM Policy would be discussed. Although it would not be the only issue discussed, it would be an important opportunity to meet with four DMs to address how to maintain momentum and move forward with respect to the policy. TBS will report back the results of the roundtable.

A delegate observed that monitoring and keeping track of implementation success would be a challenge for the DMs. This is especially so in light of the Auditor General's new Financial Management Framework that has added new tracking requirements to the many already-existing requirements.

Normandeau commented that this is a good picture of context. It is important to consider that DMs have other issues to which they are accountable, and other enterprise-wide obligations above and beyond the IM Policy. The connection must be made between the policy and how it can be helpful to DMs, support the delivery of departmental business, and link to the FAA and other departments.

A participant said the policy renewal is a great opportunity to engage DMs to recognize the value of IM. Instead of being a burden, IM should be presented as a solution to the burden. Here is a chance to define the process and focus on how IM can help solve problems.

Another delegate agreed that IM is a solution, but noted that the challenge is to develop ideas on how IM can be used to solve problems in the very near future. She suggested presenting ideas in the form of an information architecture that can make things happen.

Results of Consultations on the New IM Policy

In a discussion following her presentation of the new IM policy, Hélène Valin explained that TBS is currently developing an approach to define the instruments needed to support implementation of the IM Policy. Once the instruments, such as guidelines, standards, and directives, are developed and sanctioned, TBS will categorize them and integrate them into the policy.

A participant commented that the policy needs greater detail and substance, to allow evaluation of its soundness. Another participant agreed, adding that the statements in the policy relate to measurement and management accountability, yet such statements are more usually found in lower-level instruments.

A delegate raised caution about the risk of creating a "checkmark stigma" in the panic of meeting deadlines under action plans and schedules. The reality is that implementing the IM Policy is a living, breathing, "way-of-life" cultural shift.

Another participant expressed doubt that IM will ever become a major priority. He added that cultural change is more qualitative than quantitative in nature. Moreover, IM is more a path that will not involve major transformations unless there are major crises. "IM is not about the destination; it's about the path and the journey," Normandeau summarized.

Saying that the IM Policy may be "too big to tackle," a delegate suggested selecting a few specific areas in order to try to make a difference. This approach will also help people develop confidence.

Another delegate said that individual employees must understand where they fit. She also recommended balancing the consequences and negatives with more positive reinforcement. There should also be practical measurements and baselines to facilitate demonstrating the value of IM – for example, comparing the cost and time required to complete a certain task today with the cost and time required once IM practice is in place.

A participant agreed with this value proposition. He also suggested packaging the policy with the instruments, to ensure this initiative goes forward and gets attention among all the other policies. In addition, the policy should address other GoC priorities such as privacy and access to information. Normandeau commented that success relates to how closely IM is connected to furthering business goals. The participant said "practical" and "pragmatic" are words to highlight.

A delegate noted that if IM is to align to business, there should be an IM functional policy centre with profile within each organization, as well as internal follow-up. Moreover, departments must understand where they are today in terms of gaps, and DMs need clarity in terms of their accountability.

Another delegate said there are many factors that will impact on policy implementation, including resources, funding, capacity, skills, knowledge, and feasibility. For example, if the policy is not feasible for a department due to lack of capacity, the department will not implement it. It is the instruments that will guide a department and have the greatest impact on the outcomes of the policy. She recommended drafting the instruments very carefully.

The next participant suggested formulating a strategy to study the more than 30 small agencies and departments and the extent they are at risk for failure. The emphasis should be on enablement at the beginning, followed by enforcement later on. These small organizations have correspondingly small numbers of employees, and they often have few employees in senior job classification. Moreover, there is only one small agency on a committee with TBS, yet it does not necessarily represent all the other small agencies and departments.

Another delegate agreed that the policy suite renewal should take into consideration small and medium players, as well as large ones, and address the characteristics of both scientific and service delivery functions. The policy must use different lenses to understand different communities across the GoC and position itself appropriately for each of these communities.

Highlights of the New IM Policy

In a plenary discussion following Gregory Renaud's presentation on the highlights of the new IM Policy, a delegate suggested creating an audit review instrument as part of the IM Policy. It should be a specific instrument other than a guideline, he said. Moreover, defining the instruments requires first examining the functions performed by Program Managers. With the instruments defined, TBS can then approach the DMs with the policy and the instruments that will be used to measure against their performance.

Referring to the IM Capacity Check initiative, a participant commented that without proper audit criteria it is a waste of both time and money to do an audit.

In response to a question concerning departments that have already implemented the 2003 MGI Policy, Renaud said there will be very little change for these departments to make, to implement the new IM Policy.

Normandeau summarized the key issues raised thus far:

• Implementation requires a cultural shift.
• There is a need to raise the priority of IM.
• "Pick a few low-hanging fruit." – Select a few areas in which to focus implementation first.
• Define roles and responsibilities so that employees know where they fit.
• Generate practical baselines for IM.
• Build a value proposition; focus on the benefits of IM.
• Package the IM Policy together with its supporting instruments, linking policy impact with policy outcomes.
• Examine the needs of small agencies and the risks they face in policy implementation.

Plenary on Key Issues Identified in Group Discussions

The delegates divided into three groups to discuss the following topics:

• Building Blocks: What does success look like?
• Consequences
• Implementation strategy

Table 1

The participants noted that, to include consequences, the IM Policy must define more comprehensive criteria that are IM-connected within each performance accountability framework that applies to DMs. These frameworks include Performance Management Agreements (PMAs), Departmental Performance Reports (DPRs), Reports on Plans and Priorities (RPPs), etc. In addition, an IM action plan must be formulated breaking down implementation into phases with timeframes and milestones.

There should be positive incentives for meeting objectives, for example a bonus allocation based on a certain percentage. Currently it is "all or nothing" – if a department does well generally across all criteria, then it receives a bonus. If the criteria are divided into different areas, such as 2% for finance, 2% for human resources, 2% for achieving departmental goals, 2% for IM, and so on, then if the department does not do well in the IM area, it will only sacrifice the 2% associated with IM.

A further incentive is to publish the successes and give them exposure to the public and to peers. Having compliance as a deliverable will give IM more credibility as well.

Normandeau summarized that it is sound management to inject an IM component into each department's core business while ensuring that each area of criteria is dealt with discretely. With respect to the IM action plan, he continued, each DM would have a plan for his or her own department, and part of the plan would identify deliverables for the year based on the department's areas of criteria.

A delegate noted that the action plan is one of the instruments of the IM Policy, and it is intended to be consistent across all the agencies and departments of the GoC.

Another participant said success relies on employees exercising responsibility in the IM domain. He suggested having incentives for employees as well, to ensure they fulfill their responsibility.

Table 2

The participants at this table mainly discussed implementation strategy. The first point was that there is no "one size fits all." The DM of each department or agency must propose a reasonable plan and decide the scope and timeframe for implementation. Different organizations will have different implementation strategies. Central agencies, however, need to assess what is "reasonable" and assist as needed.

Second, the policy must reflect a clear understanding of the scope of "information" – for example, whether implementation is being done for records, data, structured or non-structured information. Otherwise it is easy to become sidetracked. Moreover, whether the information resides in a database, a file, or a filing cabinet should not matter in terms of how it is covered in the policy.

Third, if a department is entrusted with information from another source, whether government or private, there will be different obligations and restriction that apply, depending on the source. As such, the department's IM function must be mindful of the management of those obligations and restrictions when managing the information and other information arising from it.

Normandeau commented that in the world of increasing interoperability, the IM Policy must indeed include strategies and supports to ensure information integrity.

Fourth, organizations need to know the assessment instruments and criteria at the outset, since they need to be built into the implementation plan and will impact on implementation strategy.

Fifth, this group gave strong support to the idea of building functional clusters. Such clusters can be based on department size, special security concerns, or other factors, and will facilitate sharing of services within each cluster group.

Sixth, the policy must have "teeth," to demonstrate to non-federal government partners that their IM criteria are protected. Specifically, the instruments must have a certain degree of legislative weight, and IM rules must be embedded throughout the policy suite. Federal departments and agencies will then be able to set out clear rules on the joint management of information when they work with and share information with non-federal government partners, including international partners.

The last point was the need to have clear understandings around ownership, control, and location of information, in particular when transferring and copying information. Who is the owner? What does ownership mean? Who controls that information if it is stored elsewhere? If that information is transferred elsewhere, where may copies reside? The specific responsibility each organization has must be clear.

In the larger group, participants further discussed the issue of ownership. One delegate noted that it will be a true partnership if government and non-governmental agencies can bind together and jointly own and operate a server containing information. However, she asked what the accountabilities are for the DM under this situation. Another delegate further asked which agency would be accountable if errors are made or problems occur.

A participant noted that federal departments are service providers to municipalities. Municipalities often create information and store it on the RCMP's systems, yet it is not clearly defined which department is responsible for managing that information. The policy is silent particularly on how to deal with non-government relationships, he added.

Another participant, however, said that the Department of Justice has rules that make ownership clear; if it is a GoC server, then the GoC is in control. A delegate further commented that sharing intelligence information is a huge issue.

Section 6.1.2 of the September 11 draft IM Policy, concerning policy requirements, states that the DM is to appoint a senior official to represent him or her to TBS, other central agencies, and common service or shared service organizations. A participant suggested that the policy provide greater clarification on this appointment and how this key official is to be determined.

Table 3

The participants at this table said the main priority is to sustain obligation and commitment to the IM Policy from the centre while developing policy instruments as well as technical tools for each organization. Having an IM career path will help sustain this commitment and build pride and enhance professionalism in the IM community around a clear definition of IM.

Very importantly, participants noted that the policy needs to be more cogent. It must be able to answer questions about why IM should be a priority. Selecting key projects is also critical. Moreover, the policy should focus on return on investment, not only in terms of money but also of what makes employees' lives easier. Expectations must be defined early on, and implementation should make early successes visible.

In addition, participants recommended linking IM to the Program Activity Architecture (PAA) that each federal government organization submits to TBS.

In the larger group, delegates pointed out that the issue of whether the scope of IM includes structured data only or unstructured data as well needs to be resolved. Record retention is another key issue, involving questions such as when and how and which records.

Delegates also emphasized the importance of clarifying the complicated ownership and control issue, as well as distinguishing between the owner and custodian of information. There are many parallel processes around this question, one participant said, making it quite complicated.

In terms of IM as a career path, a participant said that IM professionals are already extremely scarce, and they are even more scarce if expertise in IT is added on, and security clearance beyond that. Government will be in need of far more of such professionals in the future and must help organizations improve accessibility to these people. Another participant commented that only DMs at the executive leadership level can structure such a career path.

Another participant raised the issue of consistency of data format. For example, the GoC should make a choice among Word, WordPerfect, or any other format for its documents. Organizations can handle different formats up to a certain point, but beyond that it becomes very difficult, he said.

Valin remarked that this had been an excellent discussion, noting that the meeting was the first time the suggestion was raised to build functional clusters around special security concerns.