Privacy Act - Annual Report 2016-2017

(April 1, 2016 to March 31, 2017)
Canadian Heritage

This publication is available upon request in alternative formats.

© Her Majesty the Queen in Right of Canada, represented by the Minister of Canadian Heritage, 2017

Catalogue No. : CH1-1/2E-PDF

ISSN: 1926-7819

Table of contents

 

1. Introduction

The Department of Canadian Heritage is pleased to present to Parliament its annual report on the administration of the Privacy Act for fiscal year April 1, 2016 to March 31, 2017. Section 72 of the Act requires that the head of every federal government institution submit an annual report to Parliament on the administration of the Act during the fiscal year.

1.1. The Privacy Act

The purpose of the Privacy Act is to protect the privacy of individuals with respect to personal information about themselves held by a government institution and to provide individuals with a right of access to their information. It also protects the privacy of individuals by exercising strict control over the collection, disclosure and use of such information.

The Department of Canadian Heritage is fully committed to both the spirit and the intent of the Privacy Act, which are based on the principles of open government and the assurance of privacy of individuals with respect to their personal information held by the Department.

1.2. Mandate of Canadian Heritage

The Department of Canadian Heritage and Canada's major national cultural institutions play a vital role in the cultural, civic and economic life of Canadians. We work together to support culture, the arts, heritage, official languages, multiculturalism, citizenship and participation, in addition to Aboriginal, youth, and sport initiatives.

The Department of Canadian Heritage is responsible for programs and policies that help all Canadians participate in their shared cultural and civic life. The Department’s legislative mandate is set out in the Department of Canadian Heritage Act and other statutes for which the Minister of Canadian Heritage is responsible and presents a wide-ranging list of responsibilities for the Minister under the heading of “Canadian identity and values, cultural development, and heritage.”

The Department oversees numerous statutes, namely the Broadcasting Act, the Copyright Act and the Investment Canada Act (the latter two acts shared with Innovation, Science and Economic Development Canada), the Official Languages Act (Part VII), the Museums Act the Canada Travelling Exhibitions Indemnification Act, the Cultural Property Export and Import Act, the Status of the Artist Act, the Canadian Multiculturalism Act and the Physical Activity and Sport Act (shared with Health Canada).

The Department of Canadian Heritage is specifically responsible for formulating and implementing cultural policies related to copyright, foreign investment and broadcasting, as well as policies related to arts, culture, heritage, official languages, sport, state ceremonial and protocol, and Canadian symbols. The Department’s programs, delivered through Headquarters, and multiple points of service including five regional offices across the country, fund community and third-party organizations to promote the benefits of culture, identity, and sport for Canadians.

In 2016-2017, the Minister of Canadian Heritage, assisted by the Minister for Sport and Persons with Disabilities, was accountable to Parliament for the Department, five departmental agencies and twelve Crown corporations.

2. Structure of the Access to Information and Privacy Secretariat

The Access to Information and Privacy (ATIP) Secretariat is responsible for administering the Privacy Act within the Department of Canadian Heritage. Its mandate is to act on behalf of the Minister of Canadian Heritage in ensuring compliance with legislation, regulations and government policy and to create departmental directives, including standards, in all matters relating to the Act.

During the reporting period, the ATIP Secretariat consisted of an Operations Unit with 10 positions and a Policy and Governance Unit of two analysts.

The Operations Unit is responsible for processing requests under the Privacy Act.  This includes receiving requests from the public, performing line-by-line review of the records requested, conducting external consultations as required and representing the Department in dealings with the Office of the Privacy Commissioner regarding the application of the Act.

The Policy and Governance Unit provides policy advice and guidance to the department on the protection of personal information.  This unit develops policy instruments, processing products and tools.  It is responsible for assisting program officials when they complete Privacy Risk Checklists and/or conduct a privacy impact assessment (PIA) to ensure privacy legislation and policy requirements are respected.  The unit liaises with employees and prepares and delivers training and awareness sessions throughout the department.  In addition, the unit prepares the department’s annual reporting requirements and publishes the department’s Information about programs and information holdings.

In the departmental organizational structure, the ATIP Secretariat reports to the Corporate Secretariat for Canadian Heritage.

3. Delegation order

The powers, duties and functions of the administration of the Privacy Act has been fully delegated by the Minister to the Director of the ATIP Secretariat.  A copy of the Canadian Heritage’s delegation order is appended to this report as Appendix A.

4. Administration of requests

The statistical report submitted to the Treasury Board Secretariat on the administration of the Privacy Act has been completed and is appended to this report as Appendix B.

4.1. Privacy requests

Between April 1, 2016 and March 31, 2017, twenty-seven formal requests for information were received under the Privacy Act. In comparison with the last reporting period, this represents a 42% increase in requests.

Chart 1 : Number of requests received, 2010-2011 to 2016-2017
Chart 1 : Number of requests received, 2010-2011 to 2016-2017 – text version

This bar graph shows the number of requests received from 2010-2011 to 2016-2017.  Data is as follows:

  • 2010-2011: 11
  • 2011-2012: 10
  • 2012-2013: 5
  • 2013-2014: 12
  • 2014-2015: 3
  • 2015-2016: 19
  • 2016-2017: 27

Two requests were carried over from the previous reporting period.

No formal requests for correction of personal information were received for this fiscal year.

4.2. Disposition of completed requests

Twenty-eight requests were completed during the reporting period.  One request was completely disclosed to the applicant, eight requests resulted in the partial disclosure of information and nine requests were abandoned. It was not possible to process ten requests as no records existed.

4.3. Extensions

Requests can be extended for up to 30 additional days beyond the 30-day statutory time frame in two circumstances: when meeting the original time limit would unreasonably interfere with the operations of the government institution or when consultations are necessary. In three cases the Department was required to take an extension beyond the statutory time frame; in all cases for interference in order to process a large volume of records.

4.4. Exemptions

The Privacy Act sets out specific exceptions to the right of access. These exceptions are known as exemptions. Each exemption is intended to protect information relating to a particular public or private interest and form the only basis for refusing access to personal information under the Privacy Act. In processing the requests, two types of exemptions were invoked. Section 26 (personal information about another individual) was applied in eight requests and section 27 (solicitor-client privilege) was applied in two requests.

4.5. Exclusions

The Privacy Act does not apply to information that is already publicly available, such as government publications and material in libraries and museums.  It also excludes material deemed to be Cabinet confidences.  There were no exclusions cited in the requests completed during the reporting period.

4.6. Costs

For the fiscal year 2016-17 the cost for the ATIP Secretariat to administer the Privacy Act was $173,925, of which $145,197 was for salaries and $28,728 was for goods and services, including professional service contracts.

5. Education and training activities

Data Privacy Day

On January 28, 2017, Canada and many countries around the world celebrated Data Privacy Day.  Data Privacy Day highlights the impact technology is having on our privacy rights and underlines the importance of valuing and protecting personal information.

To promote Data Privacy Day, the Director of ATIP Secretariat published a communique on the Department’s intranet news service informing employees of the privacy policy instruments and how these instruments support and enhance the Department’s commitment to protecting personal information.

Privacy awareness webinars

During the reporting period, the ATIP Secretariat piloted two privacy awareness webinars, one in French and one in English.  All Department employees were invited to participate in the webinars.  ATIP Secretariat promoted the webinars via the internal news service on the department’s intranet site and also by posting four advertisements on the electronic billboards located in various locations across the Department.

Security Awareness Week

In the reporting period, the ATIP Secretariat participated in the promotion of Security Awareness Week, coordinated by the Chief Information Officer Branch (CIOB) of the Department of Canadian Heritage.  On February 7 and 8, 2017, ATIP Secretariat participated in a “Talk to an Expert” event organized by CIOB at Headquarters in Gatineau, Quebec to promote security awareness.  The ATIP Secretariat used this event as an opportunity to promote ATIPS’s policy instruments, to answer questions and offer information on privacy matters, as well as to deliver the message that incorporating privacy measures at the initial stage of a project will save a program area time and money and will help them avoid unnecessary privacy risks.

Spotlight

In September 2016, to help raise the profile of the ATIP Secretariat and to promote privacy awareness, the Department’s online intranet news service, Spotlight, featured an article profiling an ATIP Secretariat senior advisor.

6. Policy instruments, procedures and initiatives

Policy instruments

During the reporting period, the ATIP Secretariat continued to work toward embedding a culture of privacy excellence by updating and creating new policy instruments.  In addition to updating the department’s Privacy Impact Assessment template, the Secretariat revised and re-named the Privacy Risk Checklist (formerly known as the Privacy Impact Assessment Checklist).

The ATIP Secretariat also created two new policy instruments to support the department’s commitment to protecting personal information:

  • The Standard on the Use of Personal Information for Non-Administrative Purposes provides comprehensive governance and accountability in activities involving the collection, use or disclosure of personal information for non-administrative purpose.
  • The Privacy Protocol and Statement of Compliance is a companion piece to the Standard on the Use of Personal Information for Non-Administrative Purposes and the Privacy Risk Checklist.  As its name implies, the Privacy Protocol and Statement of Compliance is a record in which the program responsible for an activity involving the non-administrative use of personal information agrees to comply with the privacy recommendations put forth by the ATIP Secretariat in the Privacy Risk Checklist.

Info Source update

Info Source: Sources of Federal Government and Employee Information provides information about the functions, programs, activities and related information holdings of government institutions.  It provides individuals, as well as current and former employees of the government, with relevant information to assist them to access personal information about themselves held by government institutions.

The Treasury Board Secretariat (TBS) requires that government institutions publish their own Information about programs and information holdings on their Internet site.  During the reporting period, the Department of Canadian Heritage completed its review of its Information about programs and information holdings and met all legislative and TBS mandatory requirements.  In its review, TBS stated the Department’s Information about programs and information holdings was “excellent”.

7. Complaints and federal court cases

One complaint regarding the processing of a request was filed with the Office of the Privacy Commissioner (OPC) against the Department of Canadian Heritage in fiscal year 2016-17. The complaint dealt with the delay in releasing documents.

There were no Federal Court cases concerning the refusal of access during this reporting period.

8. Monitoring the processing of requests and requests for corrections

The ATIP Secretariat monitors the processing of requests on a daily basis using the ATIP management system (Access Pro Case Management/Redaction) as well as through bi-weekly meetings between the officers and management of the Secretariat. This ensures accurate and timely responses to applicants.

9. Material privacy breaches

A privacy breach is deemed to be a material breach if it involves sensitive personal information, could reasonably be expected to cause serious injury or harm to the individual, or involves a large number of affected individuals. During this reporting period, the ATIP Secretariat was informed of one privacy incident. The incident involved an Access to Information request and the release of a document containing an individual’s personal financial information. The inadvertent disclosure was quickly identified and contained. Following a review of this incident, it was determined that it did not meet the criteria for a material privacy breach. The Office of the Privacy Commissioner was not informed.

10. Privacy impact assessment

Twenty Privacy Risk Checklists were evaluated for new or changed programs or systems, two of which resulted in the recommendation to perform a full privacy impact assessment (PIA).  Additionally, the ATIP Secretariat drafted six privacy notices further to the analysis of Privacy Risk Checklists. Departmental colleagues also requested advice on the use and disclosure of personal information in twenty cases. During the reporting period, no PIAs were completed.

11. Disclosure of personal information pursuant to paragraph 8(2)(m)

Subsection 8(2) of the Privacy Act stipulates under which circumstances personal information under the control of a government institution may be disclosed.  Paragraph 8(2)(m) states that disclosure of personal information is permitted for any purpose where, in the opinion of the head of the institution, the public interest in disclosure clearly outweighs any invasion of privacy that could result from the disclosure, or the disclosure would clearly benefit the individual to whom the information relates. During the reporting period, no disclosures were made pursuant to paragraph 8(2)(m) of the Privacy Act.

 

Appendix A – Delegation order

Access to Information Act and Privacy Act

Pursuant to Section 73 of the Access to Information Act and the Privacy Act, I, as head of the Department of Canadian Heritage, hereby designate the persons holding the positions set out in the schedule hereto, or persons occupying on an acting basis those positions, to exercise my powers and functions under these Acts specified opposite each position.

This Delegation Order supersedes all previous Access to Information Act and Privacy Act Delegation Orders.

The Honourable Mélanie Joly
Minister of Canadian Heritage
Date: May 31, 2016

 

Powers and functions delegated pursuant to Section 73 of the Privacy Act and Privacy Regulations

Legend:

DM
Deputy Minister
CS
Corporate Secretary
ATIP/D
Director, Access to Information and Privacy Secretariat
ATIP/DD
Deputy Director, Access to Information and Privacy Secretariat

Note: The Xs indicate which position has delegated authority for each section of the Act.

Privacy Act

Section

Description

DM

CS

ATIP/D

ATIP/DD

8(2)(j)

Disclosure for research purposes

x

x

x

8(2)(m)

Disclosure in the public interest or in the interest of the individual

x

8(4)

Copies of requests under 8(2)(e) to be retained

x

x

x

8(5)

Notice of disclosure under 8(2)(m)

x

x

x

9(1)

Record of disclosures to be retained

x

x

x

9(4)

Consistent uses

x

x

x

10

Personal information to be included in personal information banks

x

x

x

14

Notice where access requested

x

x

x

15

Extension of time limits

x

x

x

x

17(2)(b)

Language of access

x

x

x

17(3)(b)

Access to personal information in alternative format

x

x

x

18(2)

Exemption (exempt bank) - disclosure may be refused

x

x

x

19(1)

Exemption - personal information obtained in confidence

x

x

x

19(2)

Exemption - where authorized to disclose

x

x

x

20

Exemption - federal-provincial affairs

x

x

x

21

Exemption - international affairs and defence

x

x

x

22

Exemption - law enforcement and investigation

x

x

x

22.3

Exemption - Public Servants Disclosure Protection Act

x

x

x

23

Exemption - security clearances

x

x

x

24

Exemption - individuals sentenced for an offence

x

x

x

25

Exemption - safety of individuals

x

x

x

26

Exemption - information about another individual

x

x

x

27

Exemption - solicitor-client privilege

x

x

x

28

Exemption - medical record

x

x

x

31

Notice of intention to investigate

x

x

x

33(2)

Right to make representation

x

x

x

35(1)

Findings and recommendations of Privacy Commissioner (complaints)

x

x

x

35(4)

Access to be given

x

x

x

36(3)

Report of findings and recommendations (exempt banks)

x

x

x

37(3)

Report of findings and recommendations (compliance review)

x

x

x

51(2)(b)

Special rules for hearings

x

x

x

51(3)

Ex parte representations

x

x

x

72(1)

Report to Parliament

x

x

x

Privacy Act Regulations

Section

Description

DM

CS

ATIP/D

ATIP/DD

9

Reasonable facilities and time provided to examine personal information

x

x

x

11(2)

Notification that correction to personal information has been made

x

x

x

11(4)

Notification that correction to personal information has been refused

x

x

x

13(1)

Disclosure of personal information relating to physical or mental health may be made to a qualified medical practitioner or psychologist for an opinion on whether to release information to the requestor

x

x

x

14

Disclosure of personal information relating to physical or mental health may be made to a requestor in the presence of a qualified medical practitioner or psychologist

x

x

x

Appendix B – Statistical Report on the Privacy Act

Part 1: Requests Under the Privacy Act

Number of Requests

Received during reporting period

27

Outstanding from previous reporting period

2

Total

29

Closed during reporting period

28

Carried over to next reporting period

1

Part 2: Requests Closed During the Reporting Period

2.1 Disposition and completion time

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

0

1

0

0

0

0

0

1

Disclosed in part

0

4

2

1

1

0

0

8

All exempted

0

0

0

0

0

0

0

0

All excluded

0

0

0

0

0

0

0

0

No records exist

3

7

0

0

0

0

0

10

Request abandoned

6

3

0

0

0

0

0

9

Neither confirmed nor denied

0

0

0

0

0

0

0

0

Total

9

15

2

1

1

0

0

28

2.2 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)

0

24(b)

0

19(1)(d)

0

22(1)(c)

0

25

0

19(1)(e)

0

22(2)

0

26

8

19(1)(f)

0

22.1

0

27

2

20

0

22.2

0

28

0

21

0

22.3

0

2.3 Exclusions

Section

Number of Requests

Section

Number of Requests

Section

Number of Requests

69(1)(a)

0

70(1)

0

70(1)(d)

0

69(1)(b)

0

70(1)(a)

0

70(1)(e)

0

69.1

0

70(1)(b)

0

70(1)(f)

0

70(1)(c)

0

70.1

0

2.4 Format of information released

Disposition

Paper

Electronic

Other formats

All disclosed

1

0

0

Disclosed in part

2

6

0

Total

3

6

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

48

48

1

Disclosed in part

8539

7885

8

All exempted

0

0

0

All excluded

0

0

0

Request abandoned

0

0

9

Neither confirmed nor denied

0

0

0

Total

8587

7933

18

2.5.2 Relevant pages processed and disclosed by size of requests

Disposition

Less Than 100
Pages Processed

101-500
Pages Processed

501-1000
Pages Processed

1001-5000
Pages Processed

More Than 5000
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

1

48

0

0

0

0

0

0

0

0

Disclosed in part

1

55

3

856

2

1461

2

5513

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

9

0

0

0

0

0

0

0

0

0

Neither confirmed nor denied

0

0

0

0

0

0

0

0

0

0

Total

11

103

3

856

2

1461

2

5513

0

0

2.5.3 Other complexities

Disposition

Consultation Required

Legal Advice Sought

Interwoven Information

Other

Total

All disclosed

0

0

0

0

0

Disclosed in part

1

0

1

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

1

0

1

0

2

Deemed refusals

2.6.1 Reasons for not meeting statutory deadline

Number of Requests Closed Past the Statutory Deadline

Principal Reason

Workload

External Consultation

Internal Consultation

Other

2

1

1

0

0

2.6.2 Numbers 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

0

0

0

16 to 30 days

0

0

0

31 to 60 days

0

0

0

61 to 120 days

1

1

2

121  to 180 days

0

0

0

181 to 365 days

0

0

0

More than 365 days

0

0

0

Total

1

1

2

2.7 Request 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)

Paragraph 8(2)(e)

Paragraph 8(2)(m)

Subsection 8(5)

Total

0

0

0

0

Part 4: Request 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

15(b)
Translation or Conversion

Section 70

Other

All disclosed

0

0

0

0

Disclosed in part

3

0

0

0

All exempted

0

0

0

0

All excluded

0

0

0

0

No records exist

0

0

0

0

Request abandoned

0

0

0

0

Total

3

0

0

0

5.2 Length of extensions

Length of Extensions

15(a)(i)
Interference with operations

15(a)(ii)
Consultation

15(b)
Translation purposes

Section 70

Other

1 to 15 days

0

0

0

0

16 to 30 days

3

0

0

0

Total

3

0

0

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

1

13

0

0

Outstanding from the previous reporting period

0

0

0

0

Total

1

13

0

0

Closed during the reporting period

1

13

0

0

Pending at the end of the reporting period

0

0

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 Ddays

More Than 365 Days

Total

All disclosed

0

0

0

0

0

0

0

1

Disclosed in part

0

0

0

0

0

0

0

0

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

0

0

0

0

0

1

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 Ddays

More Than 365 Days

Total

All disclosed

0

0

0

0

0

0

0

0

Disclosed in part

0

0

0

0

0

0

0

0

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

0

0

0

0

0

0

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

501-1000 Pages Processed

1001-5000 Pages Processed

More than 5000 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 Request with Privy Council Office

Number of Days

Fewer Than 100 Pages Processed

101-500 Pages Processed

501-1000 Pages Processed

1001-5000 Pages Processed

More than 5000 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

Section 31

Section 33

Section 35

Court action

Total

1

0

0

0

1

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

$145,197

Overtime

$0

Goods and Services

$28,728

• Professional services contracts

$17,785

• Other

$10,943

Total

$173,925

10.2 Human Resources

Resources

Person Years Dedicated to Privacy Activities

Full-time employees

1.80

Part-time and casual employees

0.00

Regional staff

0.00

Consultants and agency personnel

0.20

Students

0.00

Total

2.00

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