December 2024 - ATIP action plan progress report

Introduction

Library and Archives Canada (LAC) has seen great results from its continued efforts to implement its Access to Information and Privacy (ATIP) Action Plan. New temporary funding has helped LAC consolidate improvements made to its ATIP function over the past two years.

Part 1: Getting back on track

Reducing the backlog of requests

As mentioned in the June 2024 report, LAC now considers every request that is late according to legislated timeframes as part of its backlog and will report on the progress made to eliminate them. As of April 1, 2024, LAC had responded to all late requests related to records of former federal public servants.

While this represents less than 23% of LAC’s total ATI requests, consultations with other government departments remain a significant obstacle to meeting legislative deadlines on requests related to other government department records.

In addition to the work completed on backlog reduction, LAC continued answering new incoming requests and responded to 87% of them within legislated timeframes.

Reducing the backlog of complaints

LAC has now resolved all delay complaints from its backlog from before the 2023–2024 fiscal year, except one request from 2021, estimated at one million pages of records. LAC is now observing a change in the nature of complaints received from delay complaints to exemptions complaints.

Part 2: Internal review and improvements

Renew our policies and processes

LAC is now engaged in a continuous renewal of policies and processes to better serve its clients. The Minister of Canadian Heritage recently approved and signed LAC’s new ATIP delegation instrument, and LAC is now planning for further revised procedures, training and broader implementation.

Additionally, LAC’s Privacy Management Team continues to develop procedures, tools, templates and training modules to ensure privacy and the protection of personnel information is better integrated into various LAC processes. The team completed LAC’s first update of Info Source since 2020, and several awareness activities and training sessions were delivered. The renewal of LAC’s privacy policy suite is ongoing as instruments are being revised.

Informed by the new TBS Policy Guidance on the Disclosure of Historical Records, LAC is also reviewing its approach regarding the disclosure of historical records, and the information within, that have reached a certain age. This review has the potential to have a substantial impact on the delivery time of release packages to requesters. For example, the Complaints Management Team has used this guidance to complete requests subject to orders from the Information Commissioner and also as a tool to proactively review requests under exemption complaints and release additional information before the end of an investigation.

Invest in IT

Launched in June 2024, LAC’s new database of previously released ATI requests for LAC archival records has shown great relevance and popularity. A total of 2,200 completed requests, resulting in over 7,700 files, are presently available for direct download from LAC’s website. This represents 40% of the completed requests from the last 10 years that LAC plans to make available to the public by April 2025. Clients have now downloaded more than 7,000 files from the database. This direct client self-serve approach frees up ATIP team members to focus on new incoming requests and clearing backlogs rather than spending time issuing re-release packages.

As noted in our June 2024 report, LAC has recently acquired a new software solution to process its ATIP requests and is actively planning its configuration and implementation.

Ensure business stability and continuity

Now that the specialized ATIP teams are in place and are effectively addressing the backlog while improving their ability to respond to incoming requests within legislative timeframes, the LAC management team is focusing on planning the future ongoing business needs for ATIP operations.

In addition, as the majority of recruitment needs are now met, LAC ATIP’s dedicated human resources team is now focusing its efforts on developing and delivering to our analysts various specialized training courses on ATIP work on archival documents.

Part 3: Engage with external partners on broader issues affecting ATIP

Engage with Government of Canada partners

LAC continues to engage with TBS and other GC institutions to bring improvements to the ATIP system, both as the co-lead of an interdepartmental working group for managing the complaints process and in support of discussions around new approaches to declassification of records and records of interest to Indigenous communities.

LAC has also received specific funding to strengthen its proactive approaches to making records available, including declassification. LAC will continue its efforts to coordinate with other GC institutions, to actively declassify records in its collection and to reduce its need to consult with departments to provide access to archival documents now and in the future.

Engage with international organizations

LAC collaborated with the Australian Society of Archivists to develop specific training for its analysts on trauma-informed approaches to managing archives. Although no other specific actions took place during this reporting period, LAC continues to build relationships with its counterparts elsewhere in the world.

Engage with clients and the public

LAC maintains ongoing relationships with its regular clients by helping them facilitate their requests for records. Currently, LAC ATIP representatives are working with the Métis National Council and the Royal Canadian Legion National Office to proactively manage an expected high volume of ATI requests for commemoration purposes in connection with the 80th anniversary of V-E Day in May 2025.

In order to alert our clients to the potential for sensitive content in certain documents, as various texts mentioning potential traumatic information could be found within disclosed records, references to online mental health resources have been integrated into LAC communications. For example, a client requesting their deceased grandfather’s military file might expect general service details but instead discover unexpected, distressing information, such as severe trauma or injury records documenting physical and psychological impacts of combat experiences. In that case, the cover letter accompanying the release package would state, “Some information, images or terms in this material may be sensitive or upsetting. Please access the mental health support resources available at canada.ca/mentalhealth if you need them.”

Furthermore, during the summer of 2024, LAC consulted targeted stakeholders during the development of our new Procedure for Public Interest Disclosure of Personal Information pursuant to the Privacy Act 8(2)(m)(i). This procedure could be used, where applicable, to assess personal information for individuals or for a global determination that could apply to groups of individuals, and supports ongoing improvements to ATIP services for our clients.