Office of the Privacy Commissioner of Canada

Part I. Values and ethics training plans

Question 1

Has your organization developed department-specific values and ethics training plans down to the divisional level?

• Yes

If not, to what level have department-specific values and ethics training plans been developed and what is your target time frame for completing this work?

The Office of the Privacy Commissioner (OPC) has a department-specific values and ethics training plan in place. The OPC is presently developing training plans down to the divisional level. The target deadline for the complete implementation of the divisional level training plan is Winter 2024.

Department level

The OPC is a small organization of less than 225 full time equivalents. We have training plans for all employees, managers (including executives) and functional communities. Our training framework includes monitoring compliance with the OPC Learning Roadmap and conducting follow-ups with employees and management to ensure courses are completed. 

The OPC Learning Roadmap for all employees includes the Values and Ethics Foundations for Employees (FON301) as a required training. This is to be taken within the first 3 months of employment with the OPC, with additional mandatory renewals every 5 years. The OPC has also included Navigating Social Media as a Public Servant (TRN125) as a recommended course. In addition to the training included on the OPC Learning Roadmap for all employees, the OPC has the Values and Ethics Foundations for Managers (FON302).

The OPC has a mandatory orientation session for all new employees to be taken within 3 months of beginning their employment with the OPC. The orientation session contains information on values and ethics, the codes of conduct and additional resources for employees, including the link to a guide on social media use that was created by the OPC. The orientation session is maintained on a regular basis and updated as required. In addition to the orientation session, the Champion of Values and Ethics now meets with all new employees to discuss values and ethics and conflicts of interest.

Additionally, the following trainings offered by the Canada School of Public Service include values and ethics components:

• Managing People Effectively (COR152 - for Executives and Managers requiring delegation)
• Basics of Staffing in the Public Service (COR111 - For Human Ressources – Staffing)
• Contract Management Practices (COR408 - for Materials Management and Procurement Employees)

The OPC also plans to host regular learning activities on specific topics related to values and ethics; the topics will be determined through an assessment of commonly asked questions.

Divisional level

The Champion of Values and Ethics is now meeting with each new OPC employee individually. As these conversations happen at an individual level, this will ensure the conversation is relevant to the employee’s specific work.

The OPC is creating a working group with representatives from the different sectors of the organisation to create a training tool that will give concrete scenarios of ways to put values into action, and scenarios of real or potential conflicts of interest situations specific to each sector. This will allow employees to see values and ethics and conflicts of interests in a more tangible way that is relevant to their everyday work. These scenarios will be the basis of Division Specific Training. The OPC will add a yearly training requirement within each Sector to remind employees of their obligations regarding values and ethics and to discuss considerations specific to their work. 

Question 2

Has your organization fully implemented department-specific training plans?

• Yes

If not, what is your target time frame for completing this work?

N/A

Part II. Codes of conduct

Question 3

Has your organization reviewed its code of conduct?

• Yes, my organization has reviewed its code of conduct.

Question 4

If your organization is in the process of reviewing its code of conduct, what is your target time frame for completing the review?

N/A

Question 5

If your organization has completed the review of its code of conduct, did this review lead to updates?

• My organization is in the process of updating its code of conduct.

Please briefly describe the nature of any updates made (e.g., to clarify expected behaviours, to align with the emerging context, to include emerging risks) or explain why no updates were deemed necessary.

Following the OPC All-Staff meeting in January 2024 focused on values and ethics, it was determined that the OPC Code of Conduct would require an update. It was determined that small changes to the OPC Code of Conduct were required to clarify and update some of the expected behaviours to be more aligned with the current context of privacy in Canada, evolutions in the mandate of the organization and changes to the way we work in a hybrid work environment. The OPC has developed a draft of the revised and updated OPC Code of Conduct based on the feedback from the All-Staff meeting. The target time frame for the review and update of the OPC Code of Conduct is September 2024.

These are the next steps and target timeframe for the review and update of the OPC Code of Conduct:

• Initial Review and Update - Spring 2024 (In progress)
• Consulting Executive Management Board - Summer 2024
• Consulting Champions, Committees and Networks and Employees for Feedback - August-September 2024
• Making changes and seeking Approval - October – November 2024
• Communicating to All Employees -  December 2024

Part III. Discussions on personal accountability in upholding public service values and ethics

Question 6

What activities or actions has your organization undertaken to foster a conversation at all levels on personal accountability to uphold our public service values and ethics?

• Dedicated discussions at executive and management committee meetings
• All-staff engagements (e.g., town halls)
• Focused engagement sessions for specific functional areas (e.g., operations, finance, communications, policy, human resources)
• Focused engagement sessions on specific topics (e.g., conflicts of interest, social media, emerging technologies)
• Engagement sessions with equity groups, employee groups, networks and communities
• Inclusion in employees’ performance and talent management cycle discussions
• Specific values and ethics communications campaigns

Please provide additional details on activities that you have undertaken, including those not listed above.

All-staff engagements

On January 31, 2024, the OPC held a virtual All-Staff meeting centered on values and ethics. The meeting began with a presentation exploring the topic of values and ethics and its application within our organization.

Employees and managers participated in a 90-minute workshop, where they were divided into groups at the directorate level and discussions were facilitated by executives. These workshops focused on the following themes:

• The existing code and the continued relevance to the Public Service
• The changes in the culture of the Public Service and impact on values and ethics
• The culture of values and ethics specific to the OPC

There was also a short presentation of the Deputy Ministers’ Task Team on values and ethics Report to the Clerk of the Privy Council.

The OPC plans to continue having all-staff learning and engagement sessions on various topics related to values and ethics.

Focused engagement sessions on specific topics

On April 23, 2024, the Public Service Commission (PSC) held bilingual information sessions for employees of the OPC. These sessions focused on the rights and responsibilities of employees regarding their involvement in political activities, including how to identify risks to political impartiality and how to make informed decisions before participating in a political activity.

Engagement sessions with equity groups, employee groups, networks and communities

The OPC engaged the champions of our various networks and committees in discussions on Values and Ethics. Additionally, the OPC held a panel on Black Employee Networks where the intersection of Organisational Culture, Employment Equity, Diversity and Inclusion and Values and Ethics were discussed with the goal to support the creation of a Black Employee Network at the OPC. The OPC will also be consulting the various champions, networks and committees in the updates to the Code of Conduct.

Inclusion in employees’ performance and talent management cycle discussions

On March 28, 2024, a message was sent to employees and managers, reminding them of the performance evaluation exercise for 2023-2024. Within this email, the following message regarding values and ethics was added:

During the year-end discussion and prior to signing the performance evaluation, managers and employees should have a conversation regarding their obligations under the Values and Ethics Code for the Public Sector, as well as discussing any potential conflicts of interests. To help facilitate this conversation we encourage you to consult the Discussion Guide to the Values and Ethics Code for the Public Sector.

In addition, the OPC included the following corporate commitment for 2024-2025 that is to be used as a mandatory objective in the performance agreement for all employees: “Healthy, Diverse, Inclusive and Values Based Workplace Culture. Promote and foster a safe and healthy work environment, diversity, equity, accessibility, inclusion and substantive equality of official languages within the OPC. Demonstrate awareness and understanding of individual accountability to apply and uphold the Values and Ethics Code for the Public Sector.”

Specific values and ethics communications campaigns

On April 8, 2024, the Director and Departmental Head of Human Resources sent an email to the OPC Management Forum, to remind managers of the importance of maintaining open dialogues with employees regarding their obligations related to values and ethics and the importance of declaring all conflicts of interest including any potential contractual relationships.

In this email, the Departmental Head of Human Resources encouraged all managers to have a conversation with each employee reporting to them regarding their obligations under the Values and Ethics Code for the Public Sector, as well as discussing any potential conflicts of interests. The email also encouraged managers to consult the Discussion Guide to the Values and Ethics Code for the Public Sector and reminded managers that this conversation should be continually maintained throughout the year.

Question 7

Has your organization taken any actions to ensure that conversations on personal accountability to uphold our public service values and ethics occur on a continuing basis?

• Included as part of the onboarding process for new employees
• Incorporated in employees’ professional development and mandatory learning plans

Please provide details on activities that you have undertaken, including those not listed above.

In the OPC Orientation session, a part of the session is dedicated to values and ethics. The following is in the Values and Ethics section of the Orientation session:

• Reminding employees to read the the Values and Ethics Code for the Public Sector and for the OPC as compliance with these Codes are a Condition of Employment.
• Reminding employees to familiarize themselves with the Conflict of Interest Directive.
  • The OPC requires employees to complete and submit a Confidential Conflict of Interest and Post-Employment Report within 60 days of all staffing actions (sent to the employee along with the letter of offer or agreement) whether there is a conflict or not and to update their declaration following all changes to personal situations that may give raise to a real, apparent or potential conflict.
• Encouraging employees to discuss with the Human Resources Team if they would like to become politically involved, as a candidate or as an active campaigner for or against a party.
  • Reminding employees that if they have any questions regarding political activities, they can consult the PSC’s political activities Web site or contact their manager.

The OPC has an onboarding checklist to support managers in the onboarding of new employees. This checklist includes ensuring a conversation on values and ethics, the codes of conduct as well as conflicts of Interests takes place within the first week at the OPC. The OPC plans to add talking points for managers to help facilitate discussions with their new employees regarding values and ethics at the OPC and within their positions and to provide additional resources for managers regarding understanding and discussing post-employment measures, if applicable to the position of the new employee.

The OPC reminded employees and managers to have a conversation regarding their obligations under the Values and Ethics Code for the Public Sector, as well as discussing any potential conflicts of interests during the end of year Performance Management process.

The Champion of Values and Ethics is now meeting with all new employees to discuss values and ethics and conflicts of interest at the start of their employment at the OPC.

The OPC Values and Ethics Team as well as the Values and Ethics Champion hold regular conversations regarding values and ethics with all employees as well in sector meetings. 

Part IV. Additional information

Question 8

What recurring themes (e.g., social media, emerging technology, conflicts of interest) have emerged from conversations with employees (e.g., students, new public servants, front-line service providers, managers, executives, members of functional/horizontal communities/employee networks) across your organization?

From the Values and Ethics All-Staff on January 31, 2024, employees and managers noted the following:

1. Positive culture of values and ethics
   • The OPC maintains high standards of professionalism and respect, fostering a culture where employees and committees embody these values.
   • Participants believe the OPC has a reputation and culture for excellence, driven by dedicated teams committed to the mandate.
   • Many participants state that the OPC is a very positive and respectful workplace.
2. Increased education and awareness
   • Participants noted the need for further training and awareness on: Respect for democracy, conflict of interest, social media, and digital technology:
     • Respect for democracy: How the value interacts with personal opinions and beliefs.
     • Conflict of Interest: Clarity regarding interactions with external parties.
     • Social media: Setting clear guidelines for online conduct when using social media.
     • Digital technology: How to safely and effectively use new technologies.
   • Further training and awareness on equity, diversity, inclusion, accessibility, as well as mental health training and accommodations, for further understanding and to be better allies.
   • Values and ethics training should be reviewed to include practical examples.
   • There is a need to develop technological competencies to maintain the quality of work amidst change.

Question 9

How have you adjusted your learning activities to address recurring themes (e.g., adjusted training plans, developed specific case studies, invited expert speakers to focus on emerging themes)?

During the OPC virtual All-Staff meeting, employees noted that they would benefit from increased awareness regarding political activities. To address this, we invited the PSC to hold information sessions for employees of the OPC on the rights and responsibilities of employees regarding their involvement in political activities. This presentation also included how to identify risks to political impartiality and how to make informed decisions before participating in a political activity.

In addition, OPC employees noted a desire for further awareness on their responsibilities regarding personal social media use and values and ethics. In 2023 the OPC developed an informational guide for the use of social media, which was shared with employees. The OPC also plans on hosting more information sessions with all employees on specific topics.

The OPC is developing a tool that will give real ways to put values into action for each sector, including real or potential conflicts of interest situations in each sector. This will allow employees to see values and ethics and conflicts of interest in a more tangible real way that is relevant to their every day work. 

Question 10

Are there any actions or learning activities that have been particularly successful in fostering conversations within your organization (e.g., new tools, creative approaches that have resonated well with employees and managers, meeting with small groups, equipping managers to lead conversations, equipping values and ethics office/practitioners)?

The OPC held a virtual All-Staff meeting centered on values and ethics in January 2024. The All-Staff included 90-minute workshop divided into groups at the directorate level and facilitated by executives. These workshops focused on the following themes:

• The existing code and the continued relevance to the Public Service
• The changes in the culture of the Public Service and impact on values and ethics
• The Culture of values and ethics specific to the OPC

The feedback on the All-Staff was very positive, with many expressing appreciation for the reminder about values and ethics in the workplace. Employees and managers were candid in sharing their perspectives on values and ethics in our changing work environments, within our organization, and the broader Public Service. This all-staff also allowed us to have a greater understanding of what employees’ needs were in terms of education and awareness, as well as concerns and potential solutions. The All-Staff has also led to a marked increase in employees seeking consultation from the Champion of Values and Ethics, demonstrating an increased awareness of values and ethics.

The OPC has developed a two-page tool on the use of social media as a Public Servant and considerations on when and when not to post on social media. This has been a useful tool in furthering the conversations on expected behaviours and for employees to reflect on their obligations towards values and ethics prior to posting on social media. 

Question 11

What indicators will be used to measure increased employee awareness of the role of values and ethics in their daily work (e.g., Public Service Employee Survey, pulse surveys, engagement with focus groups)?

The OPC will use the Public Service Employee Survey, increased consultations and engagements with the Champion of Values and Ethics and Human Ressources, results of discussions within Sectors and Directorates, as well as across the organization as indicators to measure increased employee awareness of values and ethics. 

Question 12

Will these indicators be disaggregated by identity factors?

• No

Given the small size of the organization, and to avoid potentially identifying certain employees, it may not be possible to disaggregate some indicators. 

Question 13

Is there any additional information that you would like to share regarding your organization’s work on values and ethics (e.g., to advance particular recommendations of the Deputy Ministers’ Task Team on Values and Ethics Report)?

N/A