Framework for Analyzing ISC/CIRNAC’s Response to ATIP requests


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Access to information under the control of Indigenous Services Canada (ISC) and Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) and its predecessors – Indian and Northern Affairs Canada (INAC) and Aboriginal Affairs and Northern Development Canada (AANDC) – has long been considered problematic and was recently identified as a concern by the Independent Special Interlocutor for Missing Children and Unmarked Graves and Burial Sites associated with Indian Residential Schools in her Progress Update Report (November 2022) and Interim Report (June 2023).

In response to a 2014 internal audit, AANDC planned to adopt several recommendations to streamline its processing of Access to Information and Privacy (ATIP) requests. On April 24, 2024, we asked CIRNAC for an update on the implementation and impact of this plan. On May 6, 2024, CIRNAC asked for an extension of 90 days for processing my request due to the large volume of records involved and/or interference to government operations.

Meanwhile, in a series of posts, we aim to support the efforts of the Special Interlocutor and others who are working to overcome barriers to access to information pertaining to the history and legacy of relations between First Nations and Canada.

We began by contextualizing ISC/CIRNAC’s processing of ATIP requests, identifying relevant legislation and regulation, applicable policies and procedures, internal and external oversight mechanisms, various reporting obligations, and primary sources of pertinent data.

We now want to formulate an approach to evaluating a prototypical complaint about ISC/CIRNAC’s performance: “I shouldn’t have had to wait so long to receive so little information!”

1. Adopting an Analytical Framework

For our analysis, we will be adopting a framework based on the 2014 internal audit, focusing on four variables:1See “With the ATIP Directorate’s recent focus on ensuring compliance with legislation and policy requirements, there has been limited focus identifying and addressing opportunities to drive efficiencies within management of ATIP requests across the entire Department. … As part of the analysis on the efficiency and continuous improvement, the audit first attempted to gain an understanding of the true cost of processing ATIP requests to the Department. While volumetric data related to ATIP requests was readily available (e.g. number of requests and number of pages) as were operating costs directly associated with the ATIP Directorate, the current data tracking and collection practices in the Department for ATIP requests was found to be insufficient to support the calculation of an accurate level of effort, or cost estimate, as not all inputs to the request process are currently tracked. As such, the audit team undertook an independent exercise to approximate this cost for the most recently completed fiscal year, 2013-2014. In addition to identifying costs associated with the ATIP Directorate, the audit team identified the implications on Regions/Sectors based on the two major ATIP-related activities, information gathering and information review.” AANDC, Internal Audit of Access to Information and Privacy (ATIP) Management, pp. 17-18. My emphasis. Accessed at on June 6, 2024.

  1. Cost
  2. Effort2The “Allocated Costs” section of Annual Reports to Parliament report “These amounts reflect the level of effort in support of CIRNAC’s responsibilities pursuant to the Act”.
  3. Compliance
  4. Efficiency


2. Accessing Statistical Data

We have already identified three primary sources of statistical data related to ATIP requests:

  1. Annual Reports: Access to Information Act submitted to Parliament
  2. Annual department-level statistics published by the Treasury Board Secretariat (TBS)
  3. Summaries of Completed ATIP requests available on Canada’s Open Government Portal

Institutions compile and submit these data to the TBS using the Form for the Statistical Report on the Access to Information Act.3Accessed at on May 26, 2024. The Form is revised periodically – its webpage contains metadata indicating that the Form was last modified on August 1, 2021. Government institutions must include completed copies of the Form in their Annual Reports to Parliament. The TBS establishes definitions and issues specific directions annually to institutions on how to compile their annual and statistical reports.

We have downloaded the annual department-level statistics for 2015-16 to 2022-23 and are making them available in XLSX format in a ZIP file.4The 2014-15 dataset contains Canada-wide statistics only.


3. Focusing the Analyses

Our analyses will focus on 20 data tables from the current Form:5As we are interested in formal ATIP requests only, we will be disregarding the tables in Section 2: Informal requests. We will also be disregarding tables that contain zero counts in all data cells or that provide very inconsistent coverage over time.5Specifically we will be disregarding four tables related to minutes of audio or video recordings as well as Table 4.8 Requests for translation; Table 8.2 Requests with Privy Council Office; and every table in Section 3: Applications to the Information Commissioner on declining to act on requests; Section 6: Fees; and Section 10: Court action).

  • Section 1: Requests under the Access to Information Act
    • Table 1.1 Number of requests
  • Section 4: Requests closed during the reporting period
    • Table 4.1 Disposition and completion time
    • Table 4.2 Exemptions
    • Table 4.3 Exclusions
    • Subsection: 4.5 Complexity
      • Table 4.5.1 Relevant pages processed and disclosed for paper and e-record formats
      • Table 4.5.2 Relevant pages processed per request disposition for paper and e-record formats by size of requests
      • Table 4.5.7 Other complexities
    • Subsection: Closed requests
      • Table 4.6.1 Number of requests closed within legislated timelines
    • Subsection: Deemed refusals
      • Table 4.7.1 Reasons for not meeting legislated timelines
      • Table 4.7.2 Requests closed beyond legislated timelines (including any extension taken)
  • Section 5: Extensions
    • Table 5.1 Reasons for extensions and disposition of requests
    • Table 5.2 Length of extensions
  • Section 7: Consultations received from other institutions and organizations
    • Table 7.1 Consultations received from other Government of Canada institutions and other organizations
    • Table 7.2 Recommendations and completion time for consultations received from other Government of Canada institutions
    • Table 7.3 Recommendations and completion time for consultations received from other organizations outside the Government of Canada
  • Section 8: Completion time of consultations on Cabinet confidences
    • Table 8.1 Requests with Legal Services
  • Section 9: Investigations and reports of finding
    • Table 9.1 Investigations
    • Table 9.2 Investigations and reports of finding
  • Section 11: Resources related to the Access to Information Act
    • Table 11.1 Allocated costs
    • Table 11.2 Human resources



To evaluate ISC/CIRNAC’s response to ATIP requests, we have adopted an analytical framework based on a 2014 internal audit of the AANDC’s performance in this area. Primary data for 2017-18 to 2023-24 will be sourced from annual reports submitted to Parliament by ISC/CIRNAC and from annual department-level statistics published online by the Treasury Board Secretariat.

We are aiming to share our findings in early fall 2024 – soon after the government’s release of reports on its administration of the Access to Information Act in 2023-24 and, we hope, after CIRNAC’s release of information on its plan to improve performance in this area based on recommendations from a 2014 internal audit.



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