Audit reports 2014-2015: 9 - Audit of Status of Women
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 Status of Women Canada (SWC) were adequately managed. We concluded that these authorities were adequately managed. SWC 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 SWC's appointments complied with the Public Service Employment Act, the Public Service Employment Regulations, the PSC's Appointment Framework and SWC'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 thirteen appointments audited, SWC was able to demonstrate that the person who was appointed met the essential and asset qualifications established by the deputy head. We also found that persons with a priority entitlement were considered before appointments were made.
Table of Contents
Audit of Status of Women Canada
9.1 Status of Women Canada (SWC) was established in 1976 as an agency to coordinate policy with respect to the status of women and administer related programs. SWC promotes equality for women and their full participation in the economic, social and democratic life of Canada. As of January 2015, SWC had 91 employees, the majority of whom were located in the National Capital Region. The remaining employees work in offices in Montreal, Moncton and Edmonton. SWC relies on its own human resources (HR) unit for staffing services.
9.2 This audit covers SWC’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 HR advisors and sub-delegated managers involved in appointment activities, analyzed relevant documentation and audited 13 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.
9.3 During the period covered by the audit, the deputy head had established an instrument to sub-delegate appointment authorities to managers and the terms and conditions of sub-delegation. The instrument was accessible to all sub-delegated managers, employees and bargaining agents.
9.4 As outlined in SWC’s sub-delegation instrument, in order to be sub-delegated at a certain level, employees 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. We found that all 10 sub-delegated managers had met these conditions.
9.5 The PSC requires that only deputy heads can approve the extension to become bilingual for non-imperative appointments in the Executive Group (i.e., when the appointee is temporarily exempted from meeting the official language proficiency requirements in bilingual positions) and that any extensions cannot exceed two years in total. However, we found that this authority was sub-delegated in SWC’s instrument of sub-delegation and the required time limit for extensions was not specified. Nevertheless, we found that this posed a low risk as, in practice, SWC did not exercise this delegated authority. SWC has committed to adjusting its sub-delegation instrument accordingly.
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.
9.6 We found that roles and responsibilities were defined, documented and communicated through newsletters, e-mails and SWC’s shared drive. We also found that 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.
9.7 We found that, for all 13 appointments audited, SWC demonstrated that the person appointed met the essential and asset qualifications established by the deputy head. Furthermore, we found that the four non-advertised appointments audited met the PSC’s and SWC’s related requirements.
9.8 We also found that in three appointments, the advertised area of selection was limited to SWC employees in the National Capital Region instead of all organizations in the region of the position, as required by SWC’s policy. Nevertheless, given there was a sufficient number of employees within SWC who could have potentially applied to the advertised jobs, we found that this advertised area of selection provided reasonable access and thus complied with the PSC’s policy requirement. We noted that SWC had since revised its area of selection policy to provide greater flexibility to managers, while ensuring that it continues to provide reasonable access.
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.
9.9 We found that, in all the 13 appointments audited, 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 the appointment was made).
9.10 With respect to seeking priority clearance before proceeding with an appointment process, we found that most of the appointments were made before this requirement was articulated in the PSC's Priority Appointment Policy and related directive. Of the remaining appointments, SWC had in most instances obtained a priority clearance number before proceeding with an appointment process. In a few instances, SWC identified a candidate that it proposed to appoint from an existing pool prior to considering persons with a priority entitlement. This audit observation highlights a need for the PSC to clarify its expectations of how this policy requirement should be implemented.
Overall response by Status of Women Canada
The report provided a clear understanding of the observations and of the Public Service Commission (PSC) expectations in relation to the management of delegated appointment authorities as well as appointment activities. The report also presented a context of transparency and collaboration by ensuring perspectives from both the PSC's audit function and SWC's functional responsibilities were considered in the analysis.
The facts, in parallel with the observations as they are now expressed in the report, are accurate, based on SWC's current Sub-Delegation Instrument and the 13 appointments audited. We are committed to adjusting our instrument of sub-delegation in accordance with these observations.
We share your commitment to ensuring that appointments comply with the Public Service Employment Act, the Public Service Employment Regulations as well as the PSC Appointment Framework and, to this end, will continue to work in collaboration with your organization.
Overall response from the Public Service Commission
The Public Service Commission (PSC) systematically reviews audit information and an organization’s management response to determine whether any action should be taken by the PSC. This review confirmed to the PSC that Status of Women Canada has put in place the key elements of a sound staffing management system.
The Commission has also noted that audit observations highlight a need for the PSC to clarify its expectation of how the policy requirement to obtain a priority clearance before proceeding with an appointment process should be implemented and is committed to address this finding.
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