Information & Ethics Committee on Nov. 24th, 2009

[Peter Bruce]

Certainly.

Area of management number 12 is effectiveness of information management. There are 19 areas of management. Each area of management has what we call lines of evidence—we try to do evidence-based decision-making and evaluation, in this context. Until this round of the management accountability framework, there were only four. The fifth one, which we just added, is around recordkeeping practice. So there is a direct correlation between what we've done in our management accountability framework—assessment of area of management 12—and this directive.

Of the other four, the first one deals with whether there is proper governance in place. You can see how that one would have linked with the information management policy. Then we ask whether there is a strategy and plan in place, which should help to address where we are going to find the resources and how we are going to get these policies implemented in our organization.

Now we have the question, is there proper governance; is there a strategy and plan; and now we're adding practices.

The other two lines of evidence that come under effectiveness of information management are access to information and privacy compliance. That is the department's compliance with the act: whether they are tabling the report they're supposed to table in Parliament, and the like. So we have within that area of management the link between how information management can affect access to information and privacy compliance.

[The Chair, Liberal, Paul Szabo]

Thank you.

Madam Freeman.

[Carole Freeman, Bloc, Châteauguay—Saint-Constant, QC]

I would like a little clarification. Perhaps you provided it a little earlier, but I didn't hear it.

This concerns the directive in section 6.1.2 of the Directive on Recordkeeping. It states: “[...] documenting the risk profile of information resources, taking into consideration legal and regulatory risks [...].”

What do you mean by that? What are your criteria for determining the risk profile? What is the risk profile?

[Peter Bruce]

Are you talking about the legal context—

[Carole Freeman, Bloc, Châteauguay—Saint-Constant, QC]

I'm talking about the directive.

[Peter Bruce]

—or the regulatory context—

[Carole Freeman, Bloc, Châteauguay—Saint-Constant, QC]

Could you explain to me what the first paragraph of section 6.1.2 means?

[Peter Bruce]

Yes, I'll give you a specific example.

[Carole Freeman, Bloc, Châteauguay—Saint-Constant, QC]

Finally, we get to hear a practical example!

[Peter Bruce]

Let's consider the need for good documentation so that Health Canada can make a decision on the tobacco issue. There is a risk because there is already litigation over this issue. These risk elements have to be understood because these decisions will affect the health of Canadians.

What is the likelihood that the documentation related to this kind of issue will be important in future? This is the kind of risk that will be assessed in this context.

[Carole Freeman, Bloc, Châteauguay—Saint-Constant, QC]

Do you have an example for the Department of National Defence?

[Peter Bruce]

No.

[Carole Freeman, Bloc, Châteauguay—Saint-Constant, QC]

I'd like to ask you another question. Section 8 of the directive concerns the roles and responsibilities of government organizations, where it says: “[...] other departments and agencies that have a role in the effective implementation [...].”

There are your 171 institutions. It states that those organizations have a role to play in the implementation of this directive. The sentence ends as follows: “[...] this section does not confer authority.” They have a role, but they're given no authority. Can you explain that to me?

[Peter Bruce]

A good example is in section 8.2. It states that the Department of Public Works and Government Services will provide all departments, based on needs defined by them, with the information tools necessary to manage information and respond to needs in that context.

[Carole Freeman, Bloc, Châteauguay—Saint-Constant, QC]

What authority are we talking about here? They're given no authority.

[Peter Bruce]

Precisely. Every department must decide whether or not it wants to take advantage of the services offered by Public Works and Government Services Canada. They are not currently required to avail themselves of those services.

[Carole Freeman, Bloc, Châteauguay—Saint-Constant, QC]

All right. Thank you, Mr. Bruce.

[The Chair, Liberal, Paul Szabo]

Thank you.

I have a couple of brief questions.

Mr. Bruce, the directive on recordkeeping, under paragraph 3.1, refers to managing a function in which information resources of “business value”...and I focus in on those words “business value”. It's not a defined term. In fact, it seems to imply a discretionary situation that someone has to decide upon. Who does that?

[Peter Bruce]

The information management senior official in the department would have a process in place that would allow for those decisions to be made. We would expect that this decision would either be made there, or depending on the governance structure described for our management accountability framework 12.1, they would have a governance structure that would say, this is where we make those decisions.

[The Chair, Liberal, Paul Szabo]

Do you know why the words “business value” were ever used?

[Peter Bruce]

I'll start, and maybe Doug wants to come in.

[The Chair, Liberal, Paul Szabo]

Could it be because you want to eliminate frivolous...?

[Peter Bruce]

No, for many years I think we often used other terms, particularly “archival value”. I think what we've done is, in collaboration with Library and Archives Canada and their need to have documents for long-term retention, and that archival retention for future generations, we realized that up the chain, those documents are really records of business value that the Archives want the subset of. I believe, by using the term “business value” they have broadened, to some extent, the definition of what is required. Then “business value” means whether it actually supported a transaction in the context of government operations--was that grant given and what was the rationale for it?--as well as documenting the policy decisions that governments make.

[The Chair, Liberal, Paul Szabo]

That's helpful, because the way you explain it, it is more comprehensive than a reasonable man would interpret.

[Peter Bruce]

Did you want to add something? Doug was there at the inception of “business value”.