Annual Report to Parliament 2018-2019
Privacy Act

PDF Version

Table of Contents

Introduction

The Privacy Act (PA) was proclaimed into force on July 1, 1983.

The PA extends to individuals the right of access to information about themselves held by the Government, subject to specific and limited exceptions. The PA also protects individuals’ privacy by preventing others from having access to their personal information and gives individuals substantial control over the collection, use, and disclosure by the federal government of such information.

Section 72 of the PA requires that the head of every government institution prepare for submission to Parliament an annual report on the administration of the PA within the institution during each financial year.

This thirty-sixth Annual Report on the Administration of the PA is prepared in accordance with section 72 of the Act. It is intended to describe how the Department of Justice administered its responsibilities during fiscal year 2018-19.

Part I – General Information

Department Of Justice

To better understand the context within which the PA is administered, this section provides background information about the Department of Justice.

The Department of Justice has a dual mandate. This mandate stems from the dual role of the Minister of Justice, who is also the Attorney General of Canada.

In support of the Minister of Justice, the Department is responsible for providing policy and program advice and direction through the development of the legal content of bills, regulations and guidelines. In support to the Attorney General of Canada, the Department is responsible for litigating civil cases by or on behalf of the Federal Crown and for providing legal advice to federal law enforcement agencies and other government departments.

Privacy Activities

The Access to Information and Privacy (ATIP) Coordinator is accountable for the development, coordination and implementation of effective policies, guidelines, systems and procedures in order to enable efficient processing of requests under the PA. The Coordinator is also responsible for related policies, systems and procedures stemming from the PA.

The responsibility for the coordination of new data collection at the Department of Justice also lies with the ATIP Coordinator. This ensures compliance with the PA and, as necessary, the creation of new Personal Information Banks or Program Records.

Activities of the Access to Information and Privacy (ATIP) Office include:

Monitoring Compliance

The workload is assessed, through the ATIP Case Management System, on a daily basis in order to ensure that workload is evenly distributed and effectively managed to meet statutory deadlines. Various reports are produced on a weekly, bi-weekly, monthly and quarterly basis to ensure that all levels of officials are advised.

Organization For The Implementation Of Access To Information Activities

The ATIP Coordinator, who is also referred to as the ATIP Director, has full authority delegated by the Minister for the administration of the Act. For the purpose of increased executive oversight, full authority is also conferred to the Assistant Deputy Minister and Chief Financial Officer, Management Sector and the Chief Information Officer. The Delegation Order can be found at Appendix A of this report.

Within the ATIP Office, four employees were dedicated on a full-time basis to the administration of the PA and related functions. The organizational chart of the ATIP Office is as follows:

Organizational Chart of the ATIP Office described below

Organizational Chart of the ATIP Office - Text Version

Listing the title of each position, this organizational chart describes the reporting structure of the ATIP Office:

  • The head of the Office is the Director.
  • 1 Administrative Assistant, 1 Manager ATIP Operations, 1 Legal Counsel and 1 Manager, Policy Center, and 1 Manager Proactive Publication and Intake report to the Director.
  • 2 Senior Advisors/Team Leaders and 3 Senior Advisors report to the Manager, ATIP Operations.
    • Each team reports to a Team Leader:
      • Team 1 is composed of 4 ATIP Advisors, 1 ATIP Analyst and 1 Junior Analyst.
      • Team 2 is composed of 4 ATIP Advisors and 1 Junior Analyst and 1 Processing Assistant.
  • 1 Policy, Evaluation and Reporting Advisor, 1 Systems Administrator and 1 Junior Administrator report to the Manager, Policy Center.
  • 1 Senior ATIP Advisor and 1 Team Leader report to Manager Proactive Publication and Intake
    • 1 ATIP Analysts report to Team Leader.

Officials of the Department were directly involved in the application of the PA by making recommendations concerning the disclosure of records and by ensuring compliance with the provisions of the Act.

The stages for processing requests are as follows:

Stages for Processing Requests described below

Stages for Processing Requests - Text Version

This flowchart tracks the processing life cycle of a Privacy request. Once a request has been received, it is analyzed and a search for relevant records is conducted. The records that are found are reviewed in light of recommendations that have been received. The records are then prepared for release as a response package. Once the response package has been finalized, it is reviewed and approved by the ATIP Director. Upon approval, the response package is sent out to the requester.

The reading rooms at the Department of Justice headquarters and those located in the regional offices across Canada make available to the public the most recent published version of Info Source, as well as Departmental publications and manuals. Many of these publications can be found on the Department of Justice and the Treasury Board Secretariat’s websites.

Administrative Issues

Salary and Administrative Expenditures

A total of 3.6 full-time equivalents were utilized on a full-time basis in the administration of the PA. The salary expenditures amounted to $289,514.

The administrative expenditures amounted to $46,843 which included professional services contracts.

These costs do not include resources expended by the Department’s other sectors to meet the requirements under the PA.

Accomplishments

The Department of Justice continues to strive to provide leadership and improve its performance in order to maintain the highest standards of service. For fiscal year 2018-19, the ATIP Office accomplished the following:

Education and Training

ATIP officers regularly provide advice and informal training on the application of ATIP legislation to departmental employees who must review relevant records requested under the PA.

Formal awareness information sessions are also provided to other sectors within the Department. Particular emphasis is placed on those aspects of the Act that are directly related to the employees’ areas of responsibility. 10 sessions were provided this fiscal year (a total of 105 participants):

The Centre for Information and Privacy Law (CIPL) also offered training to 470 departmental employees, including through the Department of Justice’s Learning Program and to employees from other government departments:

ATIP training is part of the recommended courses under the values and ethics component of the Department’s Roadmap for new Managers. An e-orientation deck is posted on the Department’s Intranet site for employee consultation.

ATIP employees regularly participate in collective awareness sessions with ATIP Counsel to review recent jurisprudence and case law related to the ATIA. The ATIP Counsel participates in monthly ATIP Practice Group meetings during which information is exchanged and viable solutions are proposed. The Practice Group is open to all departmental counsel, including those from Legal Services Units, and its mandate is to discuss questions such as the right of access to information or privacy issues.

In addition to mentorship and partnership relationships, workshops and presentations are also regularly provided within the ATIP Office on various topics concerning the application of the ATIA and related policy and procedures. This allows ATIP employees to benefit from each other’s respective levels of experience and knowledge.

Finally, ATIP employees participate in training sessions, conferences and seminars organized by the Treasury Board Secretariat or by various associations on matters relating to both access and privacy. These exchanges provide updates for employees in the development of ATIP and upcoming trends in this area.

Part II – Report On The Privacy Act

Requests Under The Privacy Act

Statistical Report

The Annual Statistical Report for fiscal year 2018-19 is included at Part III of this Report.

Interpretation of the Statistical Report

Overview of Requests Pursuant to the Privacy Act
Fiscal Year # of Requests Received # of Requests Completed # of Pages Processed # of Pages Released
2018-19 253 248 14,479 7,397
2017-18 292 286 33,915 17,503
2016-17 261 244 54,095 19,094

Requests Received Pursuant to the Privacy Act

253 requests were received during the period under review. In addition, 46 requests were carried forward from previous years, for a total of 299 requests.

Requests Completed Pursuant to the Privacy Act

248 requests were completed during the period under review. Fifty-one (51) were carried forward to be completed in fiscal year 2019-20.

There was a decrease in the number of requests completed from those of the previous year (38 requests). Responding to formal privacy requests involved the review of 14,479 pages, of which 7,397 pages were partially or entirely disclosed.

Disposition of Completed Requests

Of the 248 requests completed in fiscal year 2018-19:

The remaining 41 requests were released in the following manner:

Disposition

Disposition described below

Disposition - Text Version

This pie graph illustrates the percentage of requests that were completed during the reporting period with the following dispositions: All Disclosed (15%) and Disclosed in Part (85%).

Completion Time and Extensions

Out of 248 requests completed in 2018-19, 211 (85%) were processed within 30 days or less.

Completion Time

Completion Time described below

Completion Time - Text Version

This pie graph illustrates the percentage of requests that were completed during the reporting period within the following timeframes: 1 to 15 days (34%), 16 to 30 days (51%), 31 to 60 days (5%), 61 to 120 days (5%), 121 to 180 days (0%), 181 to 365 days (2%) and more than 365 days (3%).

The ATIP Office routinely monitors the processing time for privacy requests. This routine monitoring is done through various statistical reports (weekly, monthly, quarterly and yearly) and meetings with ATIP staff to ensure that requests are being processed in a most timely manner. All ATIP staff, portfolio contacts and senior management are made aware of the performance metrics.

In some instances, the Department found it necessary to seek extensions to the prescribed time limits due to the need to consult with other government institutions (three times) and interference with operations (20 times).

Exemptions Invoked

The Department invoked exemptions under the PA for 46 requests. Section 26 was invoked most often (31 times), which exempts personal information relating to individuals other than the requester, and section 27 (15 times), which exempts information relating to solicitor-client privilege. For further details regarding all the exemptions invoked, please refer to the Statistical Report at Part III of this Report.

Exclusions Cited

Information was excluded once under Section 69(1)(a) as it the Act did not apply (library or museum material preserved solely for public reference or exhibition purposes).

Method of Access

A total of eight (8) requesters wanted paper copies and 33 requesters chose to receive information on CD-ROM at no extra charge, an option which tends to be more widely accepted.

Consultations by other Federal Institutions or Departments

Overview of Consultations Requests Received from other Government Institutions and Organizations
Fiscal Year # of Requests Received # Pages Received # of Requests Completed # of Pages Reviewed
2018-19 26 1,387 26 1,162
2017-18 31 994 30 1,081
2016-17 73 2,805 74 4,904

During the period under review, the Department received 26 requests from other government institutions and organizations requesting recommendations regarding records originating from, pertaining to, or of interest to the Department of Justice. In addition, five consultations outstanding from previous years were carried over, for a total of 31. In total, the Department were reviewed 1,162 pages for these consultations.

Of the 31 consultations active throughout the reporting period, 26 were completed during the 2018-19 fiscal year and the remaining five were carried forward to be completed in fiscal year 2019-20.

Other types of Requests

Advice

The ATIP Office also acted as a resource on several occasions for departmental officials as well as those from other government institutions, offering advice and guidance on the provisions of the legislation as well as related policies. The Office was consulted on the disclosure and collection of information on a wide range of issues.

Complaints, Investigations and Federal Court Cases

Complaints Filed

Fifteen (15) complaints were filed with the Office of the Privacy Commissioner (OPC) during the reporting period. The reasons for the complaints were as follows:

Completed Investigations

Complaint findings are defined as follows:

Well-founded
The OPC found evidence of the complainant’s rights being denied under the PA.

Not well-founded
The investigation uncovered no evidence leading the OPC to conclude that the government institution violated the complainant’s rights under the PA.

Resolved
After a thorough investigation, the OPC helped negotiate a solution that satisfied all parties. The finding is used for those complaints in which well-founded would be too harsh to fit what essentially is a miscommunication or misunderstanding.

Settled during the course of investigation
The OPC helped negotiate a solution that satisfied all parties during the investigation, but did not issue a finding.

Discontinued
The complaint was withdrawn or abandoned by the complainant before allegations were fully investigated.

Nine (9) investigations were completed during the reporting period, some of which had been carried forward from previous years. Out of the nine (9), two (2) were not well-founded, one (1) was settled during the course of the investigation, and six (6) were well-founded. No key issues were raised as a result of these complaints.

At the end of the fiscal year, 15 complaints were still under investigation by the OPC.

Review by the Federal Court of Canada

No applications were filed before the Federal Court pursuant to sections 41, 42 and 44 of the PA during the reporting period.

Request for Correction of Personal Information

Paragraph 12(2)(a) of the PA provides that every individual given access to personal information about himself or herself that has been used, is being used, or is available for use for an administrative purpose, is entitled to request correction of such information where the individual believes there is an error or omission therein.

The Department of Justice has not received any request for correction of personal information during the reporting period.

Use and Disclosure

It is the Department of Justice’s policy that personal information be used solely for the purpose for which it is collected or for a consistent use as described in the Info Source publication.

Disclosure under Paragraph 8(2)

Sub-paragraph 8(2)(m) of the PA permits the disclosure of personal information in situations where the public interest in disclosure clearly outweighs any invasion of privacy that could result from the disclosure or when the disclosure would clearly benefit the individual to whom the information relates. The Privacy Commissioner must be informed of disclosures to be made under these provisions.

The Department disclosed personal information once pursuant to paragraph 8(2)(m) during the reporting period. The Minister of Justice disclosed the name and title of two (2) individuals contained in a document in response to his undertaking to the members of the Standing Committee on Justice and Human Rights after informing the Privacy Commissioner of Canada pursuant to subsection 8(5) of the PA.

Exempt Banks

The Department of Justice had no exempt banks under the PA.

Audits Conducted by the Privacy Commissioner

Pursuant to subsection 37(1) of the PA, the Privacy Commissioner may carry out investigations in respect of personal information under the control of government institutions to ensure compliance with paragraphs 4 to 8.

No formal investigations by the Commissioner were completed during the reporting period.

Privacy Breaches

Federal institutions are required to notify the Office of the Privacy Commissioner of Canada and the Treasury Board of Canada Secretariat of all material privacy breaches and of the mitigation measures being implemented if the breach involves sensitive personal information and could reasonably be expected to cause serious injury to the individual.

No material breaches were reported during this reporting period.

Privacy Impact Assessments (PIAs)

PIAs are a means to ensure that privacy principles are taken into account during the design, implementation and evolution of programs and services that involve personal information. Programs and services with potential privacy risks are required to undergo a PIA.

No PIAs were completed during this reporting period.

However, a privacy risk assessment was conducted under the Department of Justice’s Protocol for Non-Administrative Purposes for the Mass Notification System (MNS). The MNS is a unified, multi-channel communication platform which enables messaging services to various devices; rapidly and simultaneously informing employees of an emergency situation. This solution serves to enhance workplace safety and security through the communication of real-time notifications and instructions prior to, during and after an event.

This solution and its privacy risk assessment has been shared with several other government departments as a best practice.  

Part III – Annual Statistical Report

Statistical Report on the Privacy Act

Name of institution: Department of Justice

Reporting period: 2018-04-01 to 2019-03-31

Part 1: Requests Under the Privacy Act

Number of Requests
  Number of Requests
Received during reporting period 253
Outstanding from previous reporting period 46
Total 299
Closed during reporting period 248
Carried over to next reporting period 51

Part 2: Requests Closed During the Reporting Period

2.1 Disposition and completion time - Number of requests
Disposition of 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
All disclosed 2 2 1 1 0 0 0 6
Disclosed in part 1 7 6 12 1 5 3 35
All exempted 0 0 0 0 0 0 0 0
All excluded 0 0 0 0 0 0 0 0
No records exist 46 87 2 0 0 0 0 135
Request abandoned 36 30 2 0 0 0 4 72
Neither confirmed nor denied 0 0 0 0 0 0 0 0
Total 85 126 11 13 1 5 7 248
2.2 Exemptions
Section Number of Requests
18(2) 0
19(1)(a) 0
19(1)(b) 0
19(1)(c) 0
19(1)(d) 0
19(1)(e) 0
19(1)(f) 0
20 1
21 0
22(1)(a)(i) 0
22(1)(a)(ii) 0
22(1)(a)(iii) 0
22(1)(b) 1
22(1)(c) 0
22(2) 0
22.1 0
22.2 0
22.3 0
23(a) 0
23(b) 0
24(a) 0
24(b) 0
25 0
26 31
27 15
28 0
2.3 Exclusions
Section Number of Requests
69(1)(a) 1
69(1)(b) 0
69.1 0
70(1) 0
70(1)(a) 0
70(1)(b) 0
70(1)(c) 0
70(1)(d) 0
70(1)(e) 0
70(1)(f) 0
70.1 0
2.4 Format of information released - Number of requests
Disposition Paper Electronic Other formats
All disclosed 1 5 0
Disclosed in part 7 28 0
Total 8 33 0
2.5 Complexity
2.5.1 Relevant pages processed and disclosed
Disposition of Requests Number of Pages Processed Number of Pages Disclosed Number of Requests
All disclosed 217 212 6
Disclosed in part 14,052 7185 35
All exempted 0 0 0
All excluded 0 0 0
Request abandoned 210 0 72
Neither confirmed nor denied 0 0 0
Total 14,479 7397 113
2.5.2 Relevant pages processed and disclosed by size of requests
Disposition Less Than 100 Pages Processed 101-500 Pages Processed 501-1,000 Pages Processed 1,001-5,000 Pages Processed More Than 5,000 Pages Processed
Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed
All disclosed 5 42 1 170 0 0 0 0 0 0
Disclosed in part 9 335 19 3,421 5 1,203 2 2,226 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 71 0 1 0 0 0 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0 0 0 0 0 0
Total 85 377 21 3,591 5 1,203 2 2,226 0 0
2.5.3 Other complexities - Number of requests
Disposition Consultation Required Legal Advice Sought Interwoven Information Other Total
All disclosed 0 0 0 0 0
Disclosed in part 2 0 0 0 2
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 2 0 0 0 2
2.6 Deemed refusals
2.6.1 Reasons for not meeting statutory deadline
Number of Requests Closed Past the Statutory Deadline Principal Reason - Number of requests
Workload External Consultation Internal Consultation Other
31 24 1 3 3
2.6.2 Number of days past deadline
Number of Days Past Deadline Number of Requests Past Deadline Where No Extension Was Taken Number of Requests Past Deadline Where An Extension Was Taken Total
1 to 15 days 4 5 9
16 to 30 days 0 1 1
31 to 60 days 1 3 4
61 to 120 days 5 0 5
121  to 180 days 0 1 1
181 to 365 days 4 1 5
More than 365 days 0 6 6
Total 14 17 31
2.7 Requests for translation
Translation Requests Accepted Refused Total
English to French 0 0 0
French to English 0 0 0
Total 0 0 0

Part 3: Disclosures Under Subsections 8(2) and 8(5)

Disclosures Under Subsections 8(2) and 8(5)
Paragraph 8(2)(e) Paragraph 8(2)(m) Subsection 8(5) Total
0 1 0 1

Part 4: Requests for Correction of Personal Information and Notations

Requests for Correction of Personal Information and Notations
Disposition for Correction Requests Received Number
Notations attached 0
Requests for correction accepted 0
Total 0

Part 5: Extensions

5.1 Reasons for extensions and disposition of requests
Disposition of Requests Where an Extension Was Taken 15(a)(i) Interference With Operations 15(a)(ii) Consultation - Section 70 15(a)(ii) Consultation - Other 15(b) Translation or Conversion
All disclosed 0 0 0 0
Disclosed in part 15 0 3 0
All exempted 0 0 0 0
All excluded 0 0 0 0
No records exist 0 0 0 0
Request abandoned 5 0 0 0
Total 20 0 3 0
5.2 Length of extensions
Length of Extensions 15(a)(i) Interference with operations 15(a)(ii) Consultation - Section 70 15(a)(ii) Consultation - Other 15(b) Translation purposes
1 to 15 days 2 0 0 0
16 to 30 days 18 0 3 0
Total 20 0 3 0

Part 6: Consultations Received From Other Institutions and Organizations

6.1 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 25 1,346 1 41
Outstanding from the previous reporting period 5 110 0 0
Total 30 1,456 1 41
Closed during the reporting period 25 1,121 1 41
Pending at the end of the reporting period 5 335 0 0
6.2 Recommendations and completion time for consultations received from other Government of Canada institutions
Recommendation Number of Days Required to Complete Consultation 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 1 1 1 0 0 0 0 3
Disclosed in part 2 1 4 4 0 3 0 14
All exempted 1 1 1 0 0 1 0 4
All excluded 0 0 0 0 0 0 0 0
Consult other institution 0 0 0 0 0 0 0 0
Other 3 0 0 0 1 0 0 4
Total 7 3 6 4 1 4 0 25
6.3 Recommendations and completion time for consultations received from other organizations
Recommendation Number of days required to complete consultation 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 0 0 0 0 0 0 0 0
Disclosed in part 0 0 1 0 0 0 0 1
All exempted 0 0 0 0 0 0 0 0
All excluded 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 1 0 0 0 0 1

Part 7: Completion Time of Consultations on Cabinet Confidences

7.1 Requests with Legal Services
Number of Days Fewer Than 100 Pages Processed 101-500 Pages Processed 501-1,000 Pages Processed 1,001-5,000 Pages Processed More than 5,000 Pages Processed
Number of Requests 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
7.2 Requests with Privy Council Office
Number of Days Fewer Than 100 Pages Processed 101-500 Pages Processed 501-1,000 Pages Processed 1,001-5,000 Pages Processed More than 5,000 Pages Processed
Number of Requests 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

Part 8: Complaints and Investigations Notices Received

Complaints and Investigations Notices Received
Section 31 Section 33 Section 35 Court action Total
15 0 0 0 15

Part 9: Privacy Impact Assessments (PIAs)

Number of PIA(s) completed: 0

Part 10: Resources Related to the Privacy Act

10.1 Costs
Expenditures Amount
Salaries $287,886
Overtime $1,628
Total - Goods and Services $46,843
Professional services contacts - Goods and Services $39,103
Other - Goods and Services $7,740
Total $336,357
10.2 Human Resources
Resources Person Years Dedicated to Privacy Activities
Full-time employees 3.40
Part-time and casual employees 0.10
Regional staff 0.00
Consultants and agency personnel 0.00
Students 0.10
Total 3.60

Annex A: Delegation Order

Access to Information Act and Privacy Act Delegation Order described below

Access to Information and Privacy Act Delegation Order - Text version

The Minister of Justice of Canada, pursuant to section 73 of the Access to Information Act and the Privacy Act, 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 of the Minister as the head of a government institution, under the section of the Act set out in the schedule opposite each position. This designation replaces the attached designation.

Schedule
Position Privacy Act and Regulations Access to Information Act and Regulations
The Deputy Minister 33(2) and 35(1) 35(2) and 37(1)
The Director, Access to Information and Privacy Office Full authority Full authority
The Assistant Deputy Minister Management Sector and Chief Financial Officer Full authority Full authority
The Chief Information Officer Full authority Full authority
The Chief of Operations, Chief of Policy and the Legal Counsel, Access to Information and Privacy Office 15, and the mandatory provisions of 26 for all records 8(1), 9, 11(2) to (6) inclusive, and the mandatory provisions of 19(1) for all records
The Senior Access to Information and Privacy Advisors 15 for all records 8(1) and 9 for all records

Dated, at the City of Ottawa,
May 2016

The Honourable Jody Wilson-Raybould
Minister of Justice