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Office of the Privacy Commissioner of Canada

Please provide details and/or examples, including what your organization is using to set its goals (e.g., operational priorities, labour market availability [LMA], population data, workforce availability [WFA]), and how these goals are communicated to employees, if applicable. What has been the most helpful in advancing towards the goals you have set? What challenges, if any, have you encountered?

The Office of the Office of the Privacy Commissioner of Canada (OPC ) has set representation goals in order to reach the workforce availability (WFA) rates based on the 2016 Census and the 2017 Canadian Survey on Disability. Since there is no more data that is more recent, the OPC uses the WFA data as a reference point to evaluate whether all four employment equity designated groups (which includes aboriginal peoples, as well as black and racialized people) are sufficiently represented within the workforce.

The OPC’s multi-year Employment Equity, Diversity and Inclusion Strategic Plan (EDI Plan) presents the representation rate of designated group members in each occupational category and explains how the OPC plans to reach its goal of creating an inclusive workplace for all. The EDI Plan has been shared with all employees through messages from senior management and is also available on the intranet (extended until 2025). A dashboard featuring a detailed analysis of the workforce was submitted to senior management with the intention of using it for a more comprehensive OPC business intelligence strategy that will be posted on the intranet in the coming months and updated regularly.

Since the OPC is a small organization, individuals leaving or joining the workforce can have a considerable impact on the representation of employment equity designated groups.

The OPC is continuing efforts to recruit members of designated groups. The size of our organization may increase significantly due to an upcoming legislative reform which would greatly expand our mandate. This could lead to opportunities to diversify our workforce. Moreover, the Human Resources (HR) team created a Staffing Strategy for the OPC and presented it to the Executive Management Board Plus in March 2024. It included many staffing options available for hiring managers specifically aimed at recruiting members of employment equity designated groups.

Question 2

Has your organization set goals to foster greater inclusion (for fiscal year 2023-2024 or future fiscal years)?

Please provide details and/or examples, including which metrics or data your organization is using, if applicable (e.g., your Public Service Employee Survey results, pulse surveys, exit interviews, human resources administrative data).

To promote an inclusive and welcoming workplace for all, the OPC has three main pillars in its EDI Plan (2021–2024), which sets out the expected outcomes and a list of activities with an annual implementation process in order to obtain those results.

Pillar 1: Communication and Engagement

Expected outcomes:    

Pillar 2: Leadership and Accountability

Expected outcomes:

Pillar 3: Recruitment, Development and Retention

Expected outcomes:

The OPC uses measurable performance indicators based on data from its organizational information and data from the Public Service Employee Survey (PSES) in order to measure the desired results and identify areas for improvement within the OPC .

In addition, since December 2023, the Office of the Ombuds of Mental Health and Well‑Being for Small Departments and Agencies, our service provider, has been offering OPC employee retention interviews and exit interviews. They are asked specific questions pertaining to equity, diversity and inclusion.

Measuring progress

Question 3

Has your organization developed an approach for measuring progress towards your established goals? 

How is the approach being implemented within your organization (e.g., how is it communicated to employees? What are the roles of executive team members including the Chief Data Officer and Head of Audit and Evaluation and regional management if applicable? How are you reporting on results and outcomes both internally and externally?)?

The OPC has monitored the progress and results of the activities set out in its EDI Plan in accordance with the performance indicators specific to each objective. For the moment, the OPC uses measurable performance indicators based on data from its organizational information and from the PSES. These same performance indicators, as well as the ones to be established by the Treasury Board of Canada Secretariat (TBS) (recommended from Report 5 – Inclusion in the Workplace for Racialized Employees) will be used to draw up the new Integrated Human Resources (HR) Plan (expected in fall 2024), which will include a section on equity, diversity and inclusion.

Every year, the HR team, which is responsible for monitoring the EDI Plan, posts a progress report on its intranet page, under the Equity, Diversity and Inclusion tab. A copy of this report is also sent to union representatives.

A dashboard template with data on various HR activities, such as Employment Equity (EE) quantitative results, was recently created and sent to senior management for feedback with the intention of using it for a more comprehensive OPC business intelligence strategy that will be posted on the intranet in the coming months and updated regularly.

During the OPC all-staff meeting in fall 2023, the HR team presented a summary of the PSES results. Afterwards, employees were invited to participate in workshops on various topics based on the PSES results, such as increasing diversity in management roles. These consultations led to the creation of the PSES Action Committee (the Committee). Headed by the Executive Director, Chief Services and Digital Officer, the Committee has as an objective to implement different suggestions brought forward by employees. One of the suggestions under consideration is to establish a mentoring or development program with the purpose of increasing diversity within the management team. The Committee presents its ideas to the Executive Management Board for approval and regularly updates employees by email.

The OPC is aware that more diligent work must be made in terms of communicating information on the results of equity and inclusion measures. To ensure that the organization updates all employees more frequently and more thoroughly on the measurable progress made towards the desired results on equity and inclusion, the OPC plans to create a communications plan or a senior management accountability schedule in order to achieve that objective in its next integrated plan.

Consequential accountability

Question 4

How is your organization using performance management and/or talent management processes to establish accountability for results?

Please provide details about how performance management and/or talent management processes are being used to establish accountability for results.

In 2022–2023, the OPC developed and released a competency profile guide for all non-EX positions that describes the competencies required for all positions at the OPC as well as the core competencies for all public service employees. This guide is intended to help managers assess employee performance more accurately, in terms of the required competencies and the OPC’s objectives. For example, under the heading “Demonstrating integrity and respect,” it states that employees in entry-level positions must “Demonstrate respect for diversity and bilingualism,” while all other levels should “Foster diversity and bilingualism.”

In addition, three years ago, the OPC set common work objectives for all of its employees, which include the obligation to create a healthy, diverse and inclusive workplace. This allows managers and employees to have ongoing dialogue about their respective responsibilities with regard to the desired EDI outcomes. It is also an excellent opportunity to raise awareness of the importance of these issues, and to commit to creating a more equitable, diverse and inclusive workplace.

One of the three pillars of the OPC’s EDI plan (2021–2024) called on leaders to take an active role in ending all forms of discrimination, and to embed equity, diversity and inclusion into all aspects of the OPC’s business. To meet this commitment, an EDI objective has been set in the performance agreements for all supervisory positions. This is intended to spark conversations between senior managers and hold them accountable for fostering a diverse, safe and inclusive environment.

For OPC ’s senior executives, government-wide corporate priorities are included in their performance agreements, as required by the Clerk of the Privy Council and Secretary to the Cabinet, in the Call to Action on Anti-Racism, Equity and Inclusion in the Federal Public Service launched in 2021. Each executive then developed individual commitments and performance measures specific to their role and responsibilities to meet the EDI priorities of the organization and the Government of Canada.

Specific, tangible actions outlined in the forward direction of the Call to Action

Question 5

Have you, as head of your organization, and/or your executive teams sponsored at least two Indigenous employees and Black and other racialized employees to prepare them for leadership roles?

Please provide details about the nature of sponsorship that you and/or your executive team have provided, along with other programs, such as mentorship or leadership development, if applicable.  

As formulated in our response to the Clerk of the Privy Council’s call to action to combat systemic racism and make the public service more inclusive, our Office has used the informal talent management program to promote and advance the interests of highly qualified and high-performing employees. The OPC has sponsored some very promising racialized employees and given them access to development opportunities to prepare them for future leadership roles. These employees, who are members of Black and other racialized groups, have been offered acting assignment opportunities to help them develop the skills and competencies required for future management roles. These employees now all hold leadership positions in the public service.

In 2022, the OPC formalized its EX minus 1 and EX minus 2 Non-Executive Talent Management Program (Program), which aims to promote highly qualified employees who are members of equity-seeking groups to foster the inclusion of a wide range of voices and opinions in the organization’s governance and decision-making. Participants are asked to voluntarily self-declare, indicating that preference may be given to members of employment equity groups.

Currently, the Program’s application form asks applicants to indicate whether they belong to one or more of the employment equity groups, without specifying which group(s) they belong to. Even though more than half of the participants selected for this program belong to at least one employment equity group, we cannot confirm whether these participants are Indigenous, Black or otherwise racialized employees.

While the program’s maximum number of participants is only six per year, and the program has only been running for two years, we feel that it would be helpful to ask participants for details regarding the specific employment equity group(s) they belong to on the application form.

It would also be extremely helpful for smaller federal organizations such as ours if the Treasury Board Secretariat (TBS) were to launch the new self-declaration questionnaire that reflects equity-seeking groups, and not just the four designated groups, in a timely fashion.

Question 6

Have you, as head of your organization, personally endorsed at least one recruitment campaign for Indigenous employees and Black and other racialized employees?

Please provide details.

I support my management team in its efforts to promote equity, diversity and inclusion within our organization.

All selection processes advertised at the OPC , including those for leadership positions, include a statement of our organizational need, which specifies that preference may be given to qualified candidates who self-declare as belonging to one or more of the following employment equity groups: Indigenous Peoples, women, persons with disabilities and members of visible minorities. Equity group members are encouraged to voluntarily self-declare when submitting their applications.

I encouraged and approved the hiring of employees from equity-seeking groups at various levels of the organization, particularly in strategic positions. This support has helped us to build a more diverse workforce from various backgrounds, so that we can continue to better serve Canada and Canadians.

The OPC’s staffing team promoted various government initiatives to hiring managers, including Indigenous Career Pathways, in an attempt to fill positions at the OPC. The OPC also conducted targeted student hiring from various employment equity groups, including Indigenous and racialized groups.

Given the limited number of management positions in our office (around 20), we do not have the same capacity as large government departments to carry out large-scale, targeted recruitment campaigns. However, in anticipation of upcoming legislative reform, we have begun work to support recruitment among equity-seeking groups. The adoption of a new federal Privacy Act might result in OPC being granted new enforcement powers, and if additional financial resources were obtained, it might lead to the organization expanding. In such a context, we would have more flexibility to undertake targeted recruitment campaigns. As a result, we have developed a hiring strategy that takes into account designated group representation, targeted staffing options and the importance of closing gaps in the representation of employment equity members. This strategy has already been presented to senior management, and will be presented to all OPC managers shortly. Meanwhile, we will continue to actively work with internal and external stakeholders to develop recruitment and retention strategies that support and nurture talented employees from Indigenous, Black, racialized and other equity-seeking communities.

I remain firmly committed to pursuing efforts and finding innovative ways to promote diversity and inclusion, even in a context of limited resources. My support for these initiatives reflects the importance I place on creating an inclusive and representative work environment, in keeping with our organization’s values and objectives.

Question 7

Has your organization prioritized official language training for Indigenous employees and Black and other racialized employees who are ready for advancement?

How is your organization prioritizing official language training?

Under Pillar 3 of OPC’s EDI Plan – “Recruitment, Development and Retention,” one of the activities planned for Year 1 is to “Promote and support language training and participation to leadership program to talented equity-seeking groups to support career development services.

To this end, the OPC formalized and implemented its Non-Executive Talent Management Program (EX minus 1 and EX minus 2) on May 24, 2022. The program aims to promote highly skilled employees who belong to equity-seeking groups in order to encourage the inclusion of a wide range of voices and opinions in our organization’s governance and decision-making. Participants are asked to voluntarily self-declare, indicating that preference may be given to members of employment equity groups.

To support program participants who are members of designated employment equity groups, language training is available so that they can achieve second language assessment results at the CBC/CBC level, while other OPC employees must have second language results at the CBC /CBC level or higher to be eligible for the program.

In addition, in our draft Learning Directive, priority for training expenses is given to employees participating in an approved career development program (including the Non-Executive Talent Management Program [EX minus 1 and EX minus 2]), including members of designated employment equity groups. As mentioned above, program participants who are members of employment equity designated groups are eligible to receive language training. We are also considering the option of prioritizing language training for equity-seeking groups in our draft Learning Directive.

Does your organization offer access to Indigenous language training or have plans to offer access? Please provide details. 

The Indigenous Languages Act aims to preserve, promote and revitalize Indigenous languages, including Indigenous sign languages. In accordance with paragraph 5(a)(iv), the purpose of the Act is to support Indigenous language and cultural learning activities – including language nest, mentorship and immersion programs – to increase the number of people who speak these languages.

With this in mind, and as part of National Indigenous History Month, in June 2023 employees were invited through an internal communication to participate in a Languages, cultures and arts learning event to highlight specific aspects of Indigenous history, cultures and perspectives.

The OPC does not have any specific measures for access to Indigenous language training in its draft Directive on Learning or in the Learning Roadmap, a tool designed to help OPC employees establish their personal learning and development plan in collaboration with their manager. However, the OPC invests heavily in its employee training.

In our efforts to promote equity, diversity and inclusion, we remain open to offering Indigenous language training to our employees, at their request. Employees are encouraged to express their interest in learning activities throughout the year, and also when setting performance objectives.

The OPC is currently reviewing its policy instruments, including the draft Directive on Learning and the Learning Roadmap, to add resources for Indigenous language learning and teaching.

Question 8

Has your organization provided support and/or invested resources for organizational employee networks and communities?

Please provide additional detail about how your organization engages with and supports employee networks and communities.

In accordance with the OPC’s EDI Plan, under Pillar 1, “Communication and Engagement,” one of the activities identified for Year 1 was to “Establish a Committee on Equity, Diversity and Inclusion to engage and consult with employees on ways to foster accessibility and inclusion, and collect ideas and opinions on how to best nurture and foster an inclusive workplace culture.”

Hence, in 2021, the OPC created an EDI Committee to enable employees to work together on promoting EDI initiatives in the organization. The Committee, under the governance of a Champion who sits on the Executive Management Board (EMB) and the EMB Plus, encourages open discussions on strengthening EDI in the public service. One of its mandates is to foster a spirit of belonging for all OPC employees and to engage staff on what actions are required to contribute to the government-wide diversity and inclusion initiative.

The EDI Committee Champion is often consulted by HR on EDI issues and events in order to obtain their support and collaboration, particularly in the implementation of certain activities of the EDI Plan.

According to the EDI Plan, under Pillar 2, “Leadership and Accountability,” one of the activities is to determine the funding allocation on an annual basis for EDI activities. While there is no set budget allocated to EDI activities, expenses are absorbed in the centralized corporate budget by the HR Directorate, as well as in the operations budget of the EDI Champion. This includes, for example, the costs related to the OPC’s yearly participation in the Capital Pride Parade, and in awareness activities such as the in‑person and virtual sessions given at the Office of the Commissioner for the KAIROS Blanket Exercise, etc.

In addition, a welcome message is forwarded to new OPC employees inviting them to take part in various internal committees, teams and working groups, including the EDI Committee, at their convenience and according to their interests.

Moreover, on November 15, 2023, OPC employees were invited to participate in a Lunch and Learn on Black Employee Networks. A panel of Black leaders shared their experience, leadership and involvement in the creation and maintenance of employee networks. The objective of this activity was to learn more about the creation of employee networks dedicated to a community, the benefits of this type of employee network for participants and the organization, and the resources available.

In April 2024, the OPC welcomed the founding Co-Chair of Infinity, a network of neurodivergent public servants; during this discussion, employees were encouraged to create an internal network with the support of the Infinity Network, as needed.

Question 9

Has anti-racism, equity and inclusion work been embedded in your organization’s integrated business plan and/or mental health plan?

The OPC supports a culture that embraces diversity and inclusion in order to provide the highest quality of service to Canadians and enable the full participation of its employees, clients and stakeholders in the delivery of its activities and its mandate.

In its 2022–2023 Departmental Plan, the OPC committed to work towards its organizational objectives by focusing on diverse priorities, including implementation of the second year of the Employment Equity, Diversity and Inclusion Plan. The goal was to take practical actions to achieve systemic change.

In its 2023–2024 Departmental Plan, the OPC committed to the transition to a hybrid workplace, while strengthening the engagement of its employees by continuing to focus on organizational change management, adaptation, mental health and inclusion, and to support a healthy, resilient, diverse and inclusive workforce. The OPC also committed to strengthening its culture of respect, inclusion and accessibility in order to benefit from the full potential of its employees and obtain better results for Canadians.

In its 2024–2025 Departmental Plan, OPC Internal Services was mandated to support activities to tackle anti-Black racism and promote diversity, equity and inclusion.

Accessibility, equity, diversity and inclusion are key objectives for the OPC. We are firmly committed to integrating these values into all our operations and to promoting them actively. To this end, at the beginning of each year, sectors and directorates are encouraged to implement initiatives that support these principles in the drafting of their operational plans. In concrete terms, most sectors and directorates have included such activities in their plans for 2024–2025. To ensure the effective follow-up and implementation of activities, operational plans are updated on a quarterly basis. These regular follow-ups make it possible to monitor progress made and adjust strategies to needs in order to meet established objectives.

Question 10

Does your organization have a calendar to avoid holding major meetings and events during significant religious, spiritual, and cultural periods?

If the calendar already exists, please provide additional details on how this calendar is communicated or promoted within your organization.  

In February 2024, the HR Directorate created a Multicultural Calendar (religions and traditions) downloadable for the Microsoft Outlook Suite (iCalendar). A first message was sent to all OPC staff asking them to download the calendar so that they could enjoy its many benefits, such as:

A message was then sent to managers to draw their attention to the importance of considering religious holidays and traditions when planning assessments in the context of recruitment processes. In that message, managers were strongly encouraged to use the Multicultural Calendar and to take into account important religious days and traditions to ensure inclusion and respect for the beliefs and practices of various candidates, and thereby create a more favourable and accommodating environment for them.

Additional information about your organization’s ongoing initiatives 

Question 11

What are two or three specific barriers that you have faced in advancing work on the Call to Action?

Please provide two or three examples.

As the OPC is a small organization, the limited number of employees may represent an obstacle to the progress of the Call to Action in a number of respects.

First, as resources are limited within the HR Directorate, no employee is completely dedicated to the EDI file. Most advisors are responsible for a portfolio consisting in a variety of HR disciplines and programs. These advisors must process multiple competing priorities in various disciplines. The numerous accountability requirements imposed on various departments and federal agencies, which stem primarily from the Centre (TBS), represent a disproportionate administrative burden for small organizations. In addition, as generalists, HR Advisors usually do not have the same expertise as specialists in large departments.

A second obstacle to which the OPC is exposed due to its small number of employees is the meeting of targets set for representation rates. The movement of just one employee may have a major impact on the results and objectives that the organization has set for itself in terms of representation rates. Furthermore, the OPC cannot go ahead with mass hirings to increase its representation rates, as larger departments can.

The OPC does not collect data that is disaggregated or broken down into subcategories according to gender, ethnocultural characteristics, age, sexual orientation, etc., since these grounds are not part of the current framework of the Employment Equity Act. During data collection, the OPC uses controlled methods (e.g., Privacy Impact Assessments) that must be consistent with privacy laws, human rights legislation and other legislative provisions.

Question 12

Recognizing that employees often have multiple identities, what actions is your organization undertaking to support Indigenous employees and Black and other racialized employees who are also members of other communities, such as persons with disabilities, 2SLGBTQIA+ communities and religious minorities who face compounding barriers of discrimination?

Please provide details.

The OPC supports equity-seeking groups through various means, such as promoting national and international celebrations and events by sending messages to all employees on a regular basis. Examples include Pride Season; International Transgender Day of Visibility; International Day Against Homophobia, Transphobia and Biphobia; Public Service Pride Week; Gender-Based Analysis Plus Awareness Week; Black History Month; National Indigenous History Month; National Day for Truth and Reconciliation; Indigenous Public Service Awareness Week; National Indigenous Peoples Day; National Accessibility Week; 16 Days of Activism Against Gender-Based Violence; Sikh Heritage Month; Asian Heritage Month; and Tamil Heritage Month.

Throughout the year, employees are invited to participate in learning activities, virtual events, presentations, virtual discussions, round tables and other activities to familiarize themselves with and learn more about EDI. These activities are organized by various partners (e.g., the Canadian Innovation Centre for Mental Health in the Workplace and the Canada School of Public Service) as well as by the OPC. For instance, the OPC hosted Deputy Minister Quan-Watson to talk about his open letter on systemic racism in Canada. In addition, we hosted representatives of the Interdepartmental Black Employee Network to learn more about the creation of employee networks dedicated to a community and the benefits of this type of network; we also hosted the founder and Co-Chair of Infinity, a network for neurodivergent public servants. The OPC also invited federal speakers to talk to us about their life experience, including Angèle Charlebois, who shared with us her experience with hearing loss and the deaf culture. Les Escobar spoke to us about his experience with racism as a first-generation Canadian, and Thérèse St-Arnaud shared some facts with us about her personal experience with a bipolar disorder.

In a spirit of reconciliation and to raise employees’ awareness of the history of Indigenous Peoples, the EDI also organized KAIROS Blanket activities at the OPC. In addition, we actively participate in Capital Pride activities, including the Pride Parade. At the OPC, we are invested in the recognition of staff members who contribute to the implementation of a positive and inclusive workplace, particularly through formal and informal awards and recognition programs (annual well-being recognition, integration and instant awards).

Question 13

In your first year of implementing the forward direction of the Call to Action, what impact has this work had on the culture of your organization?

Please provide the two or three most important impacts. 

As part of the implementation of the directions to follow concerning the Call to Action, the OPC implemented a three-year Action Plan on Equity, Diversity and Inclusion (EDI). The EDI Plan is built around the following three pillars: 1) Communication and Engagement ; 2) Leadership and Accountability; and 3) Recruitment, Development and Retention.

The first pillar focuses on strengthening equity, diversity and inclusion education to create a workplace where conversations are encouraged and supported. In the first year, the Communications Plan included key elements, such as a calendar of celebrations of various national and international events. Many awareness messages, as well as messages to promote the various EDI learning activities, were sent to employees to create a safe space for all OPC employees and thus foster dialogue.

The second pillar focuses on ensuring that leaders take an active role in ending all forms of discrimination and on including equity, diversity and inclusion in all aspects of OPC business. All supervisory position incumbents have an EDI objective in their Performance Agreement. The purpose of this measure was to spark conversations among senior executives and to make them accountable in order to foster a diverse, safe and inclusive environment.

The third and last pillar focuses on building a workforce that reflects Canada’s diverse population and linguistic duality and on ensuring its retention. To support professional development and talent management, the OPC has sponsored very promising racialized employees and given them access to opportunities for development in order to prepare them for their future management roles.

The second key action taken in this context is the appointment of an EDI Champion and the implementation of a diversified EDI Committee to enable employees to work together to move EDI initiatives forward at the OPC. One of the Committee’s mandates is to foster a spirit of belonging for all employees and engage staff on what actions need to be taken to contribute to diversity and inclusion initiatives.

Lastly, the results of the 2022 Public Service Employee Survey demonstrated that the actions taken by our organization bore fruit. In fact, 88% of OPC employees reported that they would be comfortable informing a person in a position of authority that they had concerns about workplace racism issues, compared with 79% for the public service as a whole. Moreover, 85% of the employees reported that they thought the OPC was making every effort to create a workplace free of discrimination. By encouraging dialogue and emphasizing promotion and awareness, EDI is now an integral part of OPC culture.

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2025-01-23