Summary of MGI Policy Renewal Consultations, September 14-15, 2006

General Comments on the New IM Policy

Participants noted that the new Information Management (IM) Policy needs greater detail and substance. Moreover, it must reflect an understanding of the different communities across the Government of Canada (GoC), including both scientific and service delivery functions.

Raising the profile and priority of IM is critical, as is providing a value proposition for IM, in particular in terms of how it aligns to and advances business goals. "Practical" and "pragmatic" are keywords. The policy must be more cogent and be able to answer the questions of how it helps Deputy Ministers (DMs) and all employees do their jobs, solves both short- and long-term problems, links to the Federal Accountability Act (FAA) and other departments, and addresses other GoC priorities such as privacy, security, and access to information. Communication is key.

There were several specific recommendations:

• Some of the expected results under Section 5.2 of the September 11 policy draft were considered difficult or even impossible to measure. The policy needs to include a baseline definition, identify current gaps, and have very well defined outcomes.
• Section 6.1 must be more specific about the policy requirements for DMs. One suggestion was to link Section 6.1 with Section 5.2.
• Section 6.1.2 needs greater clarification on the process by which a DM appoints a senior official to represent him or her.

Building Blocks of Success

Participants requested greater clarity in the following definitions:

• the definition of IM, in particular in terms of records management and retention, legal obligations, and ownership and control of information
• the definition of the scope of "information"
• the definition of IM's relationship to information technology
• definitions of roles, responsibilities, and accountability.

Every federal government organization must have the following elements to ensure success: resources, funding, capacity, knowledge, skills and competencies, senior-level support, and feasibility. Inadequate budget and lack of capacity and tools across the GoC were significant concerns.

The policy will affect every activity and level of government and requires a culture shift. Treasury Board Secretariat (TBS) should do a horizontal assessment and have a clear understanding of policy implementation implications across all departments. There also needs to be a cohesive governance framework across all departments.

There must be practical performance measurements and baselines – for example, in terms of time and cost savings – to allow the value of IM to be demonstrated and be able to determine whether expected results are being achieved. Departments must build the assessment instruments and criteria into their implementation plan. There should be an audit review instrument that clearly defines the audit criteria used to measure performance.

Another building block is a structured IM career path to enhance pride and professionalization in the IM community. Organizations also need improved accessibility to IM professionals, who are in short supply.

Central agencies, including TBS, Library and Archives Canada (LAC), and Public Works and Government Services Canada (PWGSC), must sustain obligation and commitment to the policy while developing instruments and technical tools for each organization. They should be able to translate accountabilities into activities and implementation issues.

These building blocks should ideally be in place before implementation. The policy needs to be presented along with a specific implementation plan and with instruments already developed.

Consequences

Consequences ensure that the policy has some "teeth" and help to obtain DM buy-in.

Consequences at the management level – DMs and Program Management Executives (PMEs) – are key. The policy needs to define more comprehensive IM-connected criteria within each performance accountability framework that applies to DMs, being mindful that consequences for DMs are also under the discretion of parliamentarians and the Clerk of the Privy Council.

The performance of IM specialists and other employees should be tracked beyond the performance appraisal.

The development of consequences should create a balance and emphasize incentives and positive reinforcement. However, there should be a clear understanding that the line cannot be crossed at a certain point, and that certain types of information are very serious.

Success should be rewarded at all levels, thus also giving credibility to IM. DMs and PMEs might receive financial benefits, such as percentage-based bonuses. Other employees might be offered incentives such as recognition and a reward program.

Implementation Strategy

Participants said that there is no "one size fits all" implementation strategy. IM is about improving overall program performance. It is tied to other departmental priorities and the overall purpose across government. The policy and instruments must be very improvement-driven and organization-adaptable, and implementation must be government-wide. Implementation is a path and a journey, not an end, and should involve continuous improvements as well as endpoints.

Moreover, implementation must deal with organization-specific requirements and problems. Legal obligations and information property rights are examples. It is also important to identify program information versus enterprise information and link the two.

Arbitrarily imposing an effective date for implementation may pressure departments into a reporting mode. Instead, DMs should propose their own date. In particular, participants recommended formulating a strategy to study the needs and risks of small agencies and departments with respect to implementation.

Implementation should select a few initial key projects in which to demonstrate success, adopting prescriptive approaches. One example is improving accessibility to information. Another is improving the management of electronic information, including email and e-documents, and resolving the issue of consistency of format for data and documents.

Two other key suggestions were raised. One was to establish an IM functional policy centre within each department or agency. To facilitate sharing of services, another idea was to build functional clusters based on department size, special security concerns, or other factors.

Other Issues Raised

TBS representatives explained that the linkages between the IM Policy and the FAA relate to the overall themes of transparency and accountability, the duty to document the decision-making process, and the acknowledgement that IM is the responsibility of every employee.

TBS representatives also noted that departments that have developed action plans or begun implementation according to the 2003 policy will not need to make many changes, to implement the new policy.

A participant recommended adding "accuracy and integrity of information" as a key contextual message.

When entrusted with information from another source, a department's IM function must be mindful of the management of the external source's obligations and restrictions related to that information. To demonstrate to non-federal government partners – including municipalities, international partners, and non-governmental organizations – that their IM criteria are protected, the IM Policy and instruments must have legislative weight and IM rules embedded within.