Privacy Act — The Right to Know! Annual Report, 2021-2022

Parks Canada

Privacy Act —
The right to know!

Annual Report 2021-2022

Title: Privacy Act — The Right to Know! Annual Report, 2021-2022

Introduction
Organizational structure
Delegation order
Highlights of the statistical report
Training and awareness
Policies, guidelines, procedures and initiatives
Summary of key issues and actions taken on complaints
Monitoring compliance
Material privacy breaches
Privacy impact assessments
Public interest disclosures
2021-2022 Statistical report on the Privacy Act

Introduction

The Privacy Act protects the privacy of individuals with respect to personal information about themselves held by a government institution and provides individuals with a right of access to that information.

This report has been prepared and will be tabled in Parliament in accordance with Section 72 of the Privacy Act. The information contained in this report pertains to the administration of the Privacy Act within the Parks Canada Agency.

Parks Canada’s mandate is to protect and present nationally significant examples of Canada’s natural and cultural heritage and to foster public understanding, appreciation and enjoyment in ways that ensure their ecological and commemorative integrity for present and future generations. The Agency is responsible for operations under multiple pieces of federal legislation and protects approximately 450 000 km² of Canada’s terrestrial, marine and freshwater ecosystems. It is the steward of 47 national parks, one national urban park, four national marine conservation areas and 171 national historic sites, including nine heritage canals. The Agency is highly decentralized with team members located across the country and often in remote areas.

Organizational structure

Parks Canada’s Access to Information and Privacy Office is comprised of seven (7) full-time employees. Internal policies and procedures have been developed in order to meet its obligations in compliance with the Privacy Act, regulations and Treasury Board policies, and those continue to be improved on a regular basis.

Parks Canada did not enter in any service agreements under section 73.1 of the Privacy Act during the reporting period.

Delegation order

Arrêté sur la délégation en vertu de la Loi sur l'accès à l'information et de la Loi sur la protection des renseignements personnels	Access to Information Act and Privacy Act Delegation Order
En vertu de l'article 95 de la Loi sur l'accès à l'information et de l'article 73 de la Loi sur la protection des renseignements personnels, le directeur général et président de l'Agence Parcs Canada délègue aux titulaires de postes mentionnés à l'annexe ci-après, ainsi qu'aux personnes occupant à titre intérimaire lesdits postes, les attributions dont il est, en qualité de responsable de l'Agence Parcs Canada, désigné par le Décret sur la désignation des responsables d'institutions fédérales (Loi sur l'accès à l'information) et le Décret sur la désignation des responsables d'institutions fédérales (Loi sur la protection des renseignements personnels), investi par les articles de ces lois mentionnés en regard de chaque poste. Le présent arrêté sur la délégation remplace et annule tout arrêté sur la délégation pris précédemment.	The Chief Executive Officer and President of the Parks Canada Agency, pursuant to section 95 of the Access to Information Act and the section 73 of the Privacy Act and his capacity as the head of the Parks Canada Agency designated by the Access to Information Act Heads of the Government Institutions Designation Order and the Privacy Act Heads of Government Institutions Delegation Order, hereby designates the persons holding the positions set out in the schedule hereto, or the persons occupying on an acting basis those positions, to exercise the powers and functions pursuant to the provisions of the aforementioned Acts set out in the schedule below opposite each position. This Delegation Order replaces any delegation order made previously.
Daté, à la Ville de Gatineau, ce 26e jour de mars 2020	Dated, at the City of Gatineau, this 26th day of March, 2020
L'original a été signé par Ron Hallman Président et Directeur général, Agence Parcs Canada	Original signed by Ron Hallman President & Chief Executive Officer, Parks Canada Agency

Annexe / Schedule
Poste / Position	Loi sur l'accès à l'information et règlements / Access to information Act and Regulations	Loi sur la protection des renseignements personnels et règlements / Privacy Act and Regulations
Vice-Président, Direction générale des relations externes et de l'expérience du visiteur / Vice-President, External Relations and Visitor Experience Directorate	Autorité absolue / Full authority	Autorité absolue / Full authority
Gestionnaire, Bureau de l'Accès à l'information et à la protection des renseignements personnels (AIPRP) / Manager, Access to Information and Privacy (ATIP) Office	Autorité absolue / Full authority	Autorité absolue / Full authority
Analyste principal (PM-05) / Senior analyst (PM-05)	Articles 7 et 9 de la Loi sur l'accès à l'information / Sections 7 and 9 of the Access to Information Act	Articles 14 et 15 de la Loi sur la protection des renseignements personnels / Sections 14 and 15 of the Privacy Act

Highlights of the statistical report

The following report presents an overview of activities carried out within the Agency during the reporting period of April 1, 2021 to March 31, 2022. The Statistical Report (Appendix A) contains detailed statistics on the information requests processed under the Privacy Act.

Parks Canada responded to all requests for personal information within legislated timelines.

Thirty-one (31) personal information requests were received under the Privacy Act. Two (2) requests were carried over to next reporting period.

The number of completed requests, broken down by completion times are: Twenty-four (24) completed within 1-30 days, seven (7) completed within 31 to 60 days.

No active complaints were outstanding from previous reporting periods.

Five (5) requests was fully disclosed and twenty-three (23) requests resulted in the partial disclosure of the records.

The following is a percentage breakdown by disclosure types for privacy requests processed in 2021-2022:

Disclosure	Percentage
All disclosed	16%
Disclosed in part	71%
No records located	12%
Requests abandoned	1%

Section 15 of the Privacy Act permits the statutory time limits to be extended if consultations are necessary, if translation is required or if the request is for a large volume of records and processing it within the original time limit would unreasonably interfere with the operations of the institution.

Parks Canada invoked a total of seven (7) extensions during the 2021-22 reporting period that were deemed necessary to process a large volume of records.

In the last three (3) years since fiscal year 2018-2019, there has been a 71% increase in the number of privacy requests received.

The Agency did not receive any consultation requests under the Privacy Act. No consultations were carried forward from the previous reporting period and no consultations were carried forward to the next reporting period.

There was no impact on the processing of requests due to COVID-19 during the reporting period. Parks Canada responded to all requests within legislated timelines. Due to mitigation measures put in place during the previous fiscal year, all documents were received electronically and then imported into the ATIP processing software. The ATIP Office continued delivering responses electronically via epost connect.

The Agency provides the public with information on an informal basis. Information is provided only when the Agency is satisfied that the information requested concerns the individual making the request or where at least one of the conditions outlined in subsection 8(2) of the Act is met.

In addition to the above, Parks Canada’s ATIP Office also reviews human resources investigation reports and provides strategic advice on human resource issues.

Training and awareness

Facilitating efficient and transparent access to information and to personal information for Canadians is a priority for Parks Canada.

To ensure that all employees of the Agency are aware of the legislation and their obligations, general awareness sessions are also given periodically to provide basic information on the provisions of the Privacy Act. Furthermore, there is a comprehensive section on Access to Information and Privacy on the Parks Canada’s Intranet site that is available to all employees.

The Agency put a focus on training its employees on their responsibilities pertaining to access to information and privacy. Thirty (30) training sessions were given to Agency employees in 2021-2022. In total, 460 employees attended these sessions. More than double the amount of employees were trained in 2021-2022 fiscal year and triple the number of training sessions were offered compared to the previous fiscal year. This increased training was made possible by strengthened access to digital connectivity for live video presentations and the technical resources across the Parks Canada network.

Policies, guidelines, procedures and initiatives

During the reporting period, the ATIP Office was continuously ensuring that its policies and procedures for processing requests made pursuant to the Privacy Act were up to date and that adjustments were made to areas where the need for improvement was identified.

The ATIP Office has added a full-time resource to its team to analyze privacy management and provide recommendations to programs responsible for the national parks and national marine and conservation areas systems that provide many of Parks Canada's visitor services and activities. This has allowed for even greater consistency and efficiency in the administration of privacy requests and privacy matters within the Agency.

During the reporting period, Parks Canada updated the internal privacy breach protocol and over 103 requests for privacy compliance advice were completed.

The Agency did not receive authority for any new collection(s) or new consistent use(s) of Social Insurance Numbers during the reporting period.

Summary of key issues and actions taken on complaints

One (1) complaint was filed with the Office of the Privacy Commissioner of Canada during the reporting period under review. There have been no audits or investigations.

Monitoring compliance

The Agency monitors the time required to process personal information requests. When the need for improvements are identified, internal processes are adjusted. No requests for correction of personal information were received during the reporting period.

Material privacy breaches

There were no material privacy breaches reported to the Office of the Privacy Commissioner and to the Information and Privacy Policy Division, Treasury Board of Canada Secretariat during this period.

Privacy impact assessments

Between April 1, 2021 and March 31, 2022, four (4) privacy impact assessments were still underway and are scheduled to be completed in the future.

Public interest disclosures

There were no disclosures of personal information made pursuant to 8(2)(m) of the Privacy Act during the reporting period.

2021-2022 Statistical report on the Privacy Act

Name of institution: Parks Canada Agency

Reporting period: 2021-04-01 to 2022-03-31

Section 1: Requests under the Privacy Act

1.1 Number of requests received

		Number of requests
Received during reporting period		31
Outstanding from previous reporting periods		0
• Outstanding from previous reporting period	0
• Outstanding from more than one reporting period	0
Total		31
Closed during reporting period		29
Carried over to next reporting period		2
• Carried over within legislated timeline	2
• Carried over beyond legislated timeline	0

1.2 Channels of requests

Source	Number of requests
Online	29
E-mail	2
Mail	0
In person	0
Phone	0
Fax	0
Total	31

Section 2: Informal requests

2.1 Number of informal requests

		Number of requests
Received during reporting period		0
Outstanding from previous reporting periods		0
• Outstanding from previous reporting period	0
• Outstanding from more than one reporting period	0
Total		0
Closed during reporting period		0
Carried over to next reporting period		0

2.2 Channels of informal requests

Source	Number of requests
Online	0
E-mail	0
Mail	0
In person	0
Phone	0
Fax	0
Total	0

2.3 Completion time of informal requests

Completion time
1 to 15 days	16 to 30 days	31 to 60 days	61 to 120 days	121 to 180 days	181 to 365 days	More than 365 days	Total
0	0	0	0	0	0	0	0

2.4 Pages released informally

Less than 100 pages released		100-500 pages released		501-1000 pages released		1001-5000 pages released		More than 5000 pages released
Number of requests	Pages released	Number of requests	Pages released	Number of requests	Pages released	Number of requests	Pages released	Number of requests	Pages released
0	0	0	0	0	0	0	0	0	0

Section 3: Requests closed during the reporting period

3.1 Disposition and completion time

Disposition of requests	Completion time
Disposition of requests	1 to 15 days	16 to 30 days	31 to 60 days	61 to 120 days	121 to 180 days	181 to 365 days	More than 365 days	Total
All disclosed	5	0	0	0	0	0	0	5
Disclosed in part	2	14	7	0	0	0	0	23
All exempted	0	0	0	0	0	0	0	0
All excluded	0	0	0	0	0	0	0	0
No records exist	1	0	0	0	0	0	0	1
Request abandoned	0	0	0	0	0	0	0	0
Neither confirmed nor denied	0	0	0	0	0	0	0	0
Total	8	14	7	0	0	0	0	29

3.2 Exemptions

Section	Number of requests	Section	Number of requests	Section	Number of requests
18(2)	0	22(1)(a)(i)	0	23(a)	0
19(1)(a)	0	22(1)(a)(ii)	0	23(b)	0
19(1)(b)	0	22(1)(a)(iii)	0	24(a)	0
19(1)(c)	0	22(1)(b)	2	24(b)	0
19(1)(d)	0	22(1)(c)	0	25	0
19(1)(e)	0	22(2)	0	26	22
19(1)(f)	0	22.1	0	27	2
20	0	22.2	0	27.1	0
21	0	22.3	0	28	0
		22.4	0

3.3 Exclusions

Section	Number of requests	Section	Section
69(1)(a)	0	70(1)	70(1)(d)
69(1)(b)	0	70(1)(a)	70(1)(e)
69.1	0	70(1)(b)	70(1)(f)
		70(1)(c)	70.1

3.4 Format of information released

Paper	Electronic				Other
Paper	E-record	Data set	Video	Audio	Other
1	27	0	0	2	0

3.5 Complexity

3.5.1 Relevant pages processed and disclosed for paper and e-record formats

Number of pages processed	Number of pages disclosed	Number of requests
12149	11517	28

3.5.2 Relevant pages processed by request disposition for paper and e-record formats by size of requests

Disposition	Less than 100 pages processed		100-500 pages processed		501-1000 pages processed		1001-5000 pages processed		More than 5000 pages processed
Disposition	Number of requests	Pages processed	Number of requests	Pages processed	Number of requests	Pages processed	Number of requests	Pages processed	Number of requests	Pages processed
All disclosed	5	67	0	0	0	0	0	0	0	0
Disclosed in part	3	171	10	2389	7	4875	3	4647	0	0
All exempted	0	0	0	0	0	0	0	0	0	0
All excluded	0	0	0	0	0	0	0	0	0	0
Request abandoned	0	0	0	0	0	0	0	0	0	0
Neither confirmed nor denied	0	0	0	0	0	0	0	0	0	0
Total	8	238	10	2389	7	4875	3	4647	0	0

3.5.3 Relevant minutes processed and disclosed for audio formats

Number of minutes processed	Number of minutes disclosed	Number of requests
33	33	3

3.5.4 Relevant minutes processed per request disposition for audio formats by size of requests

Disposition	Less than 60 minutes processed		60-120 minutes processed		More than 120 minutes processed
Disposition	Number of requests	Minutes processed	Number of requests	Minutes processed	Number of requests	Minutes processed
All disclosed	3	33	0	0	0	0
Disclosed in part	0	0	0	0	0	0
All exempted	0	0	0	0	0	0
All excluded	0	0	0	0	0	0
Request abandoned	0	0	0	0	0	0
Neither confirmed nor denied	0	0	0	0	0	0
Total	3	33	0	0	0	0

3.5.5 Relevant minutes processed and disclosed for video formats

Number of minutes processed	Number of minutes disclosed	Number of requests
0	0	0

3.5.6 Relevant minutes processed per request disposition for video formats by size of requests

Disposition	Less than 60 minutes processed		60-120 minutes processed		More than 120 minutes processed
Disposition	Number of requests	Minutes processed	Number of requests	Minutes processed	Number of requests	Minutes processed
All disclosed	0	0	0	0	0	0
Disclosed in part	0	0	0	0	0	0
All exempted	0	0	0	0	0	0
All excluded	0	0	0	0	0	0
Request abandoned	0	0	0	0	0	0
Neither confirmed nor denied	0	0	0	0	0	0
Total	0	0	0	0	0	0

3.5.7 Other complexities

Disposition	Consultation required	Legal advice sought	Interwoven information	Other	Total
All disclosed	0	0	0	0	0
Disclosed in part	0	0	0	0	0
All exempted	0	0	0	0	0
All excluded	0	0	0	0	0
Request abandoned	0	0	0	0	0
Neither confirmed nor denied	0	0	0	0	0
Total	0	0	0	0	0

3.6 Closed requests

3.6.1 Number of requests closed within legislated timelines

Number of requests closed within legislated timelines	29
Percentage of requests closed within legislated timelines (%)	100

3.7 Deemed refusals

3.7.1 Reasons for not meeting legislated timelines

Number of requests closed past the legislated timelines	Principal reason
Number of requests closed past the legislated timelines	Interference with operations / Workload	External consultation	Internal consultation	Other
0	0	0	0	0

3.7.2 Request closed beyond legislated timelines (including any extension taken)

Number of days past legislated timelines	Number of requests past legislated timeline where no extension was taken	Number of requests past legislated timeline where an extension was taken	Total
1 to 15 days	0	0	0
16 to 30 days	0	0	0
31 to 60 days	0	0	0
61 to 120 days	0	0	0
121 to 180 days	0	0	0
181 to 365 days	0	0	0
More than 365 days	0	0	0
Total	0	0	0

3.8 Requests for translation

Translation requests	Accepted	Refused	Total
English to French	0	0	0
French to English	0	0	0
Total	0	0	0

Section 4: Disclosures under subsections 8(2) and 8(5)

Paragraph 8(2)(e)	Paragraph 8(2)(m)	Subsection 8(5)	Total
0	0	0	0

Section 5: Requests for correction of personal information and notations

Disposition for correction requests received	Number
Notations attached	0
Requests for correction accepted	0
Total	0

Section 6: Extensions

6.1 Reasons for extensions

Number of requests where an extension was taken	15(a)(i) Interference with operations				15 (a)(ii) Consultation			15(b) Translation purposes or conversion
Number of requests where an extension was taken	Further review required to determine exemptions	Large volume of pages	Large volume of requests	Documents are difficult to obtain	Cabinet Confidence Section (Section 70)	External	Internal	15(b) Translation purposes or conversion
7	0	7	0	0	0	0	0	0

6.2 Length of extensions

Length of extensions	15(a)(i) Interference with operations				15 (a)(ii) Consultation			15(b) Translation purposes or conversion
Length of extensions	Further review required to determine exemptions	Large volume of pages	Large volume of requests	Documents are difficult to obtain	Cabinet Confidence Section (Section 70)	External	Internal	15(b) Translation purposes or conversion
1 to 15 days	0	0	0	0	0	0	0	0
16 to 30 days	0	7	0	0	0	0	0	0
31 days or greater								0
Total	0	7	0	0	0	0	0	0

Section 7: Consultations received from other institutions and organizations

7.1 Consultations received from other Government of Canada institutions and other organizations

Consultations	Other Government of Canada institutions	Number of pages to review	Other organizations	Number of pages to review
Received during the reporting period	0	0	0	0
Outstanding from the previous reporting period	0	0	0	0
Total	0	0	0	0
Closed during the reporting period	0	0	0	0
Carried over within negotiated timelines	0	0	0	0
Carried over beyond negotiated timelines	0	0	0	0

7.2 Recommendations and completion time for consultations received from other Government of Canada institutions

Recommendation	Number of days required to complete consultation requests
Recommendation	1 to 15 days	16 to 30 days	31 to 60 days	61 to 120 days	121 to 180 days	181 to 365 days	More than 365 days	Total
Disclose entirely	0	0	0	0	0	0	0	0
Disclose in part	0	0	0	0	0	0	0	0
Exempt entirely	0	0	0	0	0	0	0	0
Exclude entirely	0	0	0	0	0	0	0	0
Consult other institution	0	0	0	0	0	0	0	0
Other	0	0	0	0	0	0	0	0
Total	0	0	0	0	0	0	0	0

7.3 Recommendations and completion time for consultations received from other organizations outside the Government of Canada

Recommendation	Number of days required to complete consultation requests
Recommendation	1 to 15 days	16 to 30 days	31 to 60 days	61 to 120 days	121 to 180 days	181 to 365 days	More than 365 days	Total
Disclose entirely	0	0	0	0	0	0	0	0
Disclose in part	0	0	0	0	0	0	0	0
Exempt entirely	0	0	0	0	0	0	0	0
Exclude entirely	0	0	0	0	0	0	0	0
Consult other institution	0	0	0	0	0	0	0	0
Other	0	0	0	0	0	0	0	0
Total	0	0	0	0	0	0	0	0

Section 8: Completion time of consultations on cabinet confidences

8.1 Requests with Legal Services

Disposition	Less than 100 pages processed		100-500 pages processed		501-1000 pages processed		1001-5000 pages processed		More than 5000 pages processed
Disposition	Number of pages	Pages disclosed	Number of requests	Pages disclosed	Number of requests	Pages disclosed	Number of requests	Pages disclosed	Number of requests	Pages disclosed
1 to 15	0	0	0	0	0	0	0	0	0	0
16 to 30	0	0	0	0	0	0	0	0	0	0
31 to 60	0	0	0	0	0	0	0	0	0	0
61 to 120	0	0	0	0	0	0	0	0	0	0
121 to 180	0	0	0	0	0	0	0	0	0	0
181 to 365	0	0	0	0	0	0	0	0	0	0
More than 365	0	0	0	0	0	0	0	0	0	0
Total	0	0	0	0	0	0	0	0	0	0

8.2 Requests with Privy Council Office

Disposition	Less than 100 pages processed		100-500 pages processed		501-1000 pages processed		1001-5000 pages processed		More than 5000 pages processed
Disposition	Number of pages	Pages disclosed	Number of requests	Pages disclosed	Number of requests	Pages disclosed	Number of requests	Pages disclosed	Number of requests	Pages disclosed
1 to 15	0	0	0	0	0	0	0	0	0	0
16 to 30	0	0	0	0	0	0	0	0	0	0
31 to 60	0	0	0	0	0	0	0	0	0	0
61 to 120	0	0	0	0	0	0	0	0	0	0
121 to 180	0	0	0	0	0	0	0	0	0	0
181 to 365	0	0	0	0	0	0	0	0	0	0
More than 365	0	0	0	0	0	0	0	0	0	0
Total	0	0	0	0	0	0	0	0	0	0

Section 9: Complaints and investigations notices received

Section 31	Section 33	Section 35	Court action	Total
1	1	0	0	2

Section 10: Privacy Impact Assessments (PIAs) and Personal Information Banks (PIBs)

10.1 Privacy Impact Assessments

Number of PIAs completed	0
Number of PIAs modified	0

10.2 Institution-specific and Central Personal Information Banks

Personal Information Banks	Active	Modified
Institution-specific	10	5
Central	0	0
Total	10	5

Section 11: Privacy breaches

11.1 Material privacy breaches reported

Number of material privacy breaches reported to TBS

Number of material privacy breaches reported to OPC0

11.2 Non-material privacy breaches

Number of non-material privacy breaches

Section 12: Resources related to the Privacy Act

12.1 Allocated costs

Expenditures		Amount
Salaries		$92 737
Overtime		$0
Goods and Services		$0
• Professional services contracts	$0
• Other	$0
Total		$92 737

12.2 Human resources

Resources	Person years dedicated to privacy activities
Full-time employees	1.000
Part-time and casual employees	0.000
Regional staff	0.000
Consultants and agency personnel	0.000
Students	0.000
Total	1.000

Organizational contact information

Parks Canada National Office
30 Victoria Street
Gatineau, Quebec
Canada
J8X 0B3

Email: information@pc.gc.ca

Telephone:888-773-8888 (General inquiries)

Telephone — international:819-420-9486 (General inquiries — international)

Teletypewriter:866-787-6221 (TTY)

Parks Canada Agency

Parks Canada