In the work we did—we are not the contract auditors for the Government of Canada—we didn't look for technical compliance with contracts. What we looked for was the consequence of this kind of contracting and what the impact was for the Public Service Employment Act.
The use of “improper” and “circumventing” regarding the Public Service Employment Act was because we found employees who were there for a long time—many more than a year. Now that's been shortened. There are some new regulations, so it's 48 weeks plus 24 weeks. That's still a long time that you have people coming in this way.
The other thing we found was an ongoing relationship. You had people working as temporary help, and then being casual, and then coming back. Now, the way the system's working, that's not supposed to be happening.
We didn't look at the contracting part of it, but we looked at the consequence of it. The consequence of it is that you have an ongoing relationship through a contracting mechanism, and it should be an employment mechanism. So that's why we used the language.
The other part of these phenomena is that I think individual managers were not doing this to work around the system; they were looking to meet their short-term ends and needs. The consequence is that we have a compromise to the system.