Audit reports 2014-2015: 12 - Audit of the Office of the Commissioner of Lobbying of Canada

Audit conclusion

The first objective of the audit was to determine whether the appointment authorities the Public Service Commission (PSC) has delegated to the deputy head of the Office of the Commissioner of Lobbying of Canada (OCL) were adequately managed. We concluded that these authorities were adequately managed. The OCL had a sub-delegation instrument in place that was accessible across the organization. We also found that those who have been assigned a role in appointment processes were informed of their roles and responsibilities and had access to tools and the human resources support to carry out this role.

The second objective of the audit was to determine whether the OCL’s appointments complied with the Public Service Employment Act, the Public Service Employment Regulations, the PSC’s Appointment Framework and the OCL’s own organizational policies with regard to merit and priority entitlements. We concluded that the appointments complied with these requirements in all cases. In all seven appointments audited, the OCL was able to demonstrate that the person who was appointed met the essential and asset qualifications established by the deputy head. We found that persons with a priority entitlement were considered before appointments were made.

Table of Contents

Audit of the Office of the Commissioner of Lobbying of Canada

12.1 The Office of the Commissioner of Lobbying (OCL) was established in July 2008 under the Lobbying Act to support the Commissioner of Lobbying. The OCL is located in the National Capital Region and had 25 employees as of March 31, 2014. The OCL did not have its own human resources unit but had a Memorandum of Understanding (MOU) with Shared Human Resources Services (SHRS) of Public Works and Government Services Canada for staffing services. The OCL remained responsible for the appointments made within the organization, even though it used a staffing service provider.

12.2 The audit covers the OCL’s appointment activities for the period between November 1, 2012, and October 31, 2014. As part of the audit, the Public Service Commission (PSC) conducted interviews with SHRS human resources (HR) advisors and sub-delegated managers involved in appointment activities, analyzed relevant documentation and audited four advertised and three non-advertised appointments.

Observations on the management of delegated appointment authorities

PSC expectation: The PSC delegates many of its appointment authorities to deputy heads who, in turn, may sub-delegate the exercise of these authorities. As a result, the PSC expects the organization to have a sub-delegation instrument in place that is well managed and accessible across the organization.

12.3 During the period covered by the audit, the deputy head had established an instrument to sub-delegate appointment authorities to managers and outlined terms and conditions of sub-delegation. The instrument was accessible to all sub-delegated managers, employees and bargaining agents.

12.4 As outlined in the OCL’s sub-delegation instrument, in order to be sub-delegated at a certain level, an individual had to be in a managerial position, complete the required training, receive a sub-delegation letter from the deputy head and sign the letter to confirm their acceptance of the sub-delegated authorities.

12.5 We found that the required training was provided to all seven of the OCL’s sub-delegated managers. However, five managers were granted appointment authorities before having completed the staffing sub-delegation training required by the deputy head.

Recommendation 1: The deputy head of the OCL should ensure that the required training is completed by managers before granting sub-delegated appointment authorities.

PSC expectation: Those who have been assigned a role in appointment processes have been informed of their roles and responsibilities and have access to tools and the HR support to carry out this role.

12.6 We found that roles and responsibilities were defined, documented and communicated through various tools such as the Policy and the Delegation of Human Resources Authorities, the Area of Selection Policy and the Policy for Non-advertised Appointment Processes and the instrument of sub-delegation. These tools were available to employees through the OCL’s intranet site.

12.7 We also found that, through the MOU with their service provider, the OCL’s sub-delegated managers had access to an HR advisor who had passed the PSC’s Appointment Framework Knowledge Test. This test is designed to evaluate knowledge of all parts of the PSC’s Appointment Framework (policy, delegation and accountability) and the legislative framework.

Observations on appointments

PSC expectation: Appointees meet the essential and asset qualifications required for the appointment. The PSC’s and organizational policy requirements on area of selection and criteria for non-advertised appointments are met.

12.8 We found that, for all seven appointments audited, the OCL demonstrated that the person who was appointed met the essential and asset qualifications established by the deputy head.

12.9 We also found that the audited appointments met the PSC’s and the OCL’s policy requirements on area of selection and criteria for non-advertised appointments.

PSC expectation: Persons with a priority entitlement are considered prior to making an appointment and a priority clearance number is obtained before proceeding with an appointment process or appointment.

12.10 We found that, in all of the three appointments that required it, persons with a priority entitlement were considered prior to the appointment being made (i.e., a priority clearance number was obtained from the PSC before all appointments were made). We did not examine whether the OCL had obtained a clearance number before proceeding with the appointment process, as all three appointments were made before this requirement was articulated in the PSC’s Priority Appointment Policy and related directive.

Overall response by the Office of the Commissioner of Lobbying of Canada

The Office of the Commissioner of Lobbying (OCL) is in agreement with the findings and the recommendation of this report, and acknowledges that the facts presented are accurate. The organization takes its delegated authorities seriously. It will continue to ensure that appointments are made in accordance with legislative, regulatory and policy requirements as well as with the Public Service Employment Act core and guiding values.

The OCL is committed to continuously improving its staffing regime and to addressing the issue raised in the audit in a timely and effective manner. To this end, a Management Action Plan has been developed to address the recommendation outlined in this report and its implementation has already been initiated.

Action taken by the Public Service Commission

Organizations that have been audited by the Public Service Commission (PSC) receive guidance and assistance from the PSC to develop an action plan that will address the audit recommendations. The PSC systematically reviews audit information, the organization’s management response and associated action that it has taken or will take in response to the audit recommendations to determine whether any action should be taken by the PSC. As a result of this review, the PSC is satisfied with the Office of the Commissioner of Lobbying of Canada’s management response and the actions it has taken or has committed to take to address the audit recommendation. The PSC expects the deputy head to monitor the implementation of the organizational action plan and the PSC may request an update on the action plan. The PSC can provide assistance for this implementation as required.

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