Audit of the Royal Canadian Mounted Police’s Authority to Appoint Casual Workers for More Than 90 Days

Table of Contents

• Introduction
  • Background
  • Royal Canadian Mounted Police’s authority to appoint casual workers for more than 90 working days
• About the audit
• What the audit found
  • Royal Canadian Mounted Police’s framework
    • Guidelines and approval process
    • Monitoring of casual employment
  • Compliance of appointments of casual workers
    • Overview of the population examined
    • Compliance with requirements set by the Royal Canadian Mounted Police
    • Compliance with the Royal Canadian Mounted Police Casual Employment Regulations
• Conclusion
• Recommendations
• Moving forward: the Royal Canadian Mounted Police’s response
  • Response to recommendation 1
  • Response to recommendation 2
  • Response to recommendation 3
• Moving forward: the Public Service Commission of Canada’s response
• Annex A: About the audit

Introduction

Background

Under the delegated staffing system set out in the Public Service Employment Act, the Public Service Commission of Canada (PSC) is responsible for safeguarding a merit-based, representative and non-partisan public service. To fulfill its accountability to Parliament for overseeing the integrity of staffing, the PSC conducts oversight activities such as audits.

The act empowers the PSC to conduct audits on any matter within its jurisdiction; this includes examining how deputy heads exercise their delegated staffing authorities.

Casual employment is a resourcing option available to managers of the federal public service. Subsection 50(2) of the act establishes that “the period of employment of a casual worker may not exceed 90 working days in one calendar year in any particular department or other organization.” Casual workers are also excluded from the provisions of the act, other than section 50, including the application of merit.

Given its unique operational context, subsection 50.2(1) of the act grants the Royal Canadian Mounted Police (RCMP) an exception to the maximum period of casual employment, allowing it to hire casual workers for more than 90 working days in a calendar year.

Royal Canadian Mounted Police’s authority to appoint casual workers for more than 90 working days

As Canada’s national police service, the RCMP is a critical element of the Government of Canada’s commitment to keeping Canadians safe and secure. With a broad and complex mandate, the RCMP works to prevent crime at the municipal, provincial/territorial and federal levels, and provides a federal presence from coast to coast.

To deliver on its mandate, the RCMP relies on the support of temporary workers to respond to operational needs. In November 2014, amendments to the Public Service Employment Act came into force to provide the authority, under subsection 50.2(1), to appoint casual workers at the RCMP for more than 90 working days in one calendar year, as per the circumstances prescribed by the Royal Canadian Mounted Police Casual Employment Regulations.

These regulations state that for the purpose of subsection 50.2(1) of the act, a person may be appointed as a casual worker to the RCMP for a period of more than 90 working days in one calendar year for a major investigation, a major event or an operation if the services of the person are required as a result of unforeseen circumstances such as an unknown duration or the unexpected need for a particular skill.

The regulations define these circumstances as follows:

• major event means an event of national or international significance held within or outside Canada and in which the RCMP is involved, including an official visit to Canada by [His] Majesty, members of the Royal Family, a head of state or a representative of a foreign government, or a sporting event, conference, summit or exhibition
• major investigation includes an investigation of national or international interest or of a complex case in which the RCMP is involved
• operation means an activity in which the RCMP is involved that is necessary and that relates to the protection of the public

Pursuant to the regulations, the RCMP may appoint casual workers for more than 90 working days for one or more of the above circumstances where the situation is unforeseen. The regulations provide the RCMP with the required flexibility and ability to adjust to operational demands in real time so it may respond to emerging situations in a timely fashion.

About the audit

The exercise by the RCMP of the authority to appoint casual workers for more than 90 working days in one calendar year was identified as an engagement in the PSC’s 2025-2027 audit plan.

This audit was undertaken to understand the extent to which the authority is used by the RCMP, assess whether the regulations are being complied with, and to inform potential updates to the regulations.

Subsection 50.2(2) of the act gives the Commission the authority to conduct a review, on an annual basis, of the exercise of the authority to appoint casual workers to the RCMP for more than 90 working days during the preceding calendar year. This is the first audit or review conducted by the PSC on the use of this authority since it came into force in 2014.

The audit has 3 objectives:

1. To determine if the RCMP has a framework in place to support sub-delegated managers when appointing casual workers for more than 90 working days during the same calendar year.
2. To determine if the appointments of casual workers for more than 90 working days during the same calendar year meet the requirements set by the RCMP.
3. To determine if the appointments of casual workers for more than 90 working days during the same calendar year meet the circumstances prescribed in the Royal Canadian Mounted Police Casual Employment Regulations.

This audit examined the RCMP’s policies, guidelines and processes related to the use of this authority between January 1, 2018, and December 31, 2023. It also examined all 70 casual appointments over 90 working days made during that same period.

What the audit found

Royal Canadian Mounted Police’s framework

The RCMP has a framework in place to support sub-delegated managers when appointing casual workers for more than 90 working days during the same calendar year. It has a sub-delegation instrument, guidelines and controls, and it has conducted monitoring activities related to the use of this authority.

During the period covered by the audit, the Commissioner of the RCMP established a sub-delegation instrument that outlines who at the RCMP has the authority to appoint casual workers for a period of more than 90 working days. Until December 2018, this authority could only be exercised by the RCMP Commissioner. Effective December 5, 2018, the authority was sub-delegated to the Chief Human Resources Officer and the Director General, Workforce Programs and Services. Since November 2022, the authority has also been sub-delegated to the Director, Corporate Staffing.

Guidelines and approval process

The RCMP has established guidelines on casual employment for more than 90 working days. They provide guidance to managers in determining the appropriate use of casual workers over 90 days, and direction on the approval process.

The RCMP’s guidelines indicate that the authority to appoint casual workers for more than 90 working days in one calendar year is an exceptional staffing option, which may be used in specific circumstances. We found that these guidelines are aligned with the regulations as they provide the same definitions of these circumstances. The guidelines also provide examples of situations where it might be appropriate to appoint a casual worker for more than 90 working days. Examples include wire tap operations, international events like the G20 and disasters such as wildfires and plane crashes.

RCMP guidelines also state that many staffing options are available to managers to assist them in meeting their staffing needs, such as term or indeterminate appointments. Hiring managers are expected to rely primarily on other staffing options and not use casual hiring over 90 days to bypass other staffing options where a long vacancy is anticipated.

The RCMP’s 2023 guide on Casual Employment for More than 90 Working Days further explains that: “The intent of this authority is to provide flexibility to the RCMP when other staffing options do not meet resourcing needs due to the unforeseen nature of the situation. In and of themselves, extenuating factors such as attrition, delayed staffing processes, lack of HR planning, funding models, or individual scheduling and tenure preferences do not necessarily meet the requirements outlined in the [Royal Canadian Mounted Police Casual Employment Regulations]. Rather, the unforeseen circumstances must be linked to the investigation, event, or operation.”

The guidelines also outline the approval process to be followed by managers when hiring or extending a casual worker for more than 90 working days. As part of the approval process, managers are required to complete a business case justifying how the appointment of the casual worker meets the circumstances of the regulations. The business case must also be approved by an authorized person before the hiring or extension of the casual worker.

Monitoring of casual employment

In accordance with their guidelines, the RCMP conducted monitoring activities on the use of casual workers over 90 days, including the number of appointments, the reasons for choosing this staffing option and their adherence to the regulations.

As per the guide, Corporate Staffing monitors the application of the regulations through the RCMP approval process. As part of this process, Corporate Staffing monitors compliance with the regulations of business cases submitted by the Divisional Human Resources Unit and then submits them for approval by a sub-delegated person.

The PSC’s Appointment Delegation and Accountability Instrument requires that deputy heads assess on a cyclical basis, at least once every 5 years, adherence to the requirements established in the instrument, the Public Service Employment Act, other applicable statutes and regulations, the PSC’s Appointment Policy, as well as organizational staffing policies and the sub-delegation instrument. Departments and agencies must share their cyclical staffing assessment results with the PSC in the year the assessment is completed.

During the scope of the audit, the RCMP submitted to the PSC the results of its first cyclical assessment covering the period of April 1, 2017, to March 31, 2019. At the time, their results identified that only 2 appointments of casual workers over 90 days were made during that period. In May 2025, the RCMP submitted its second cyclical assessment report to the PSC, covering the period of April 1, 2019, to March 31, 2024. The report indicated that Corporate Staffing noticed an increase in the number of business cases submitted and plans to closely monitor the number of requests and the application of the regulations.

Compliance of appointments of casual workers

As part of the audit, we examined the appointments of casual workers for more than 90 working days in one calendar year to determine if they meet the RCMP’s own organizational requirements and the circumstances prescribed in the regulations.

Overview of the population examined

The audit examined all 70 appointments of casual workers over 90 working days made between January 1, 2018, and December 31, 2023.

The number of casual workers hired for more than 90 working days at the RCMP increased between 2018 and 2023. As shown in the table below, fewer than 5 appointments were made under that authority in 2018 and 2019, but this number increased to 21 in 2023.

Note: a very small number of appointments or extensions were approved within one calendar year to take effect in the following year.

During the reference period, out of the 70 appointments, a total of 48 individuals were hired as casual workers, including some appointed more than once:

• 33 individuals were hired once
• 11 individuals were hired twice
• 1 individual was hired 3 times
• 3 individuals were hired 4 times

Most of these individuals were hired to work on an “as and when required” basis. The majority of the 70 appointments were made in British Columbia (56%), followed by the Alberta (10%), Nunavut (10%) and the National Capital Region (10%). Smaller proportions of appointments were made in the Northwest Territories (6%), Yukon (6%), Manitoba (1%) and Prince Edward Island (1%).

The table below provides an overview of the appointments of casual workers over 90 days by classification. Many of these casual workers were hired as telecommunications operators (PO-TCO) or intercept monitor analysts (PO-IMA). Telecommunications operators are responsible for monitoring police telecommunications systems and dispatching police officers to respond to public requests for assistance. Intercept monitor analysts, also referred to as wiretap operators, are responsible for completing detailed and accurate synopses in regard to content received through electronic surveillance of telecommunications pursuant to judicial authorizations.

Another significant proportion of casual workers were hired under the Administrative Services (AS) classification as risk investigators and personnel security managers.

Compliance with requirements set by the Royal Canadian Mounted Police

As per the RCMP guidelines, managers are required to complete a business case justifying how the appointment of a casual worker for more than 90 working days meets the circumstances of the regulations. The business cases must be approved by the appropriate authority before the hiring or extension of the casual worker over 90 days.

The audit found that a business case was completed by the hiring manager for all 70 appointments examined. From these, 69 business cases were approved by a person with the appropriate level of authority, while there was insufficient information to conclude for 1 appointment. In 94% of the appointments (66 out of 70), the business case was approved before the appointment or the extension of the casual worker. In 2 cases, it was approved after the appointment or the extension of the casual worker, and in another 2 cases, dates were missing from the appointment file to conclude.

Compliance with the Royal Canadian Mounted Police Casual Employment Regulations

As shown in Table 3 below, the audit found that 67% of the appointments examined (47 out of 70) were compliant with the regulations, meaning that they met both the definition of major investigation, major event or operation, and the unforeseen nature of the circumstances for the appointment. The majority (41 of the 47) of these casual workers were appointed as Telecommunications Operators (PO-TCO) or Intercept Monitor Analysts (PO-IMA).

However, in approximately one third of the appointments examined (21 out of 70), the casual worker was not appointed to work on a major investigation, a major event or an operation as a result of unforeseen circumstances. Of these:

• 12 appointments did not meet the definition of major investigation, major event or operation, and were not the result of unforeseen circumstances
• 6 appointments did not meet the definition of major investigation, major event or operation, despite being the result of unforeseen circumstances
• 3 appointments met the definition of major investigation, major event or operation, but were not the result of unforeseen circumstances

These casual workers were hired to do work in occupational categories such as the Administrative Services (AS), the Economics and Social Science Services (EC) and Computer Science (CS). Their duties were related to processing security screening applications, human resources, policy analysis and technical support.

With regards to the unforeseen circumstances for the appointment of the casual worker, in many cases, information available in the appointment file indicated that the hiring manager was aware of the ongoing and foreseen need for that particular skill. In other cases, the hiring manager did not explain why the need for that skill was unforeseen or indicated another reason for the casual appointment that did not necessarily meet the definition of “unforeseen,” such as preference for the individual to be appointed as a casual worker.

For the 2 remaining appointments, there was insufficient information available to conclude.

Overall, the audit also revealed that the proportion of non-compliant appointments of casual workers hired for more than 90 working days has increased in recent years. As shown in the table below, while this proportion was at 24% in 2022, it reached 52% in 2023, meaning that half of the casual workers’ appointments during that year did not meet the regulations.

Note: A very small number of appointments or extensions were approved within one calendar year to take effect in the following year. For the purposes of this audit, compliance was examined based on the date the business case was approved and, accordingly, when the authority was exercised.

Conclusion

The audit found that the RCMP has a framework in place to support sub-delegated managers when appointing casual workers for more than 90 working days in one calendar year. This framework includes guidelines that provide guidance to managers in determining the appropriate use of casual workers over 90 days, and direction on the approval process.

As per the RCMP guidelines, managers must complete a business case to explain how the appointment or the extension meets the circumstances of the regulations. The business case must also be approved by an authorized person before the hiring or extension of the casual worker over 90 working days. The audit noted that this framework is aligned with the regulations, as it provides the same definitions of the prescribed circumstances. During the scope of the audit, the RCMP conducted monitoring activities on the use of casual workers over 90 days.

The audit found high compliance with the RCMP’s own organizational requirements to complete a business case and obtain approval before the appointment or the extension of the casual worker over 90 working days.

The audit revealed, however, that compliance with the regulations requires attention. Despite having a framework in place, the audit found that 30% of the appointments examined did not meet the definition of a major investigation, major event or operation, or were not the result of unforeseen circumstances. These casual workers were hired to perform tasks related to processing security screening applications, human resources, policy analysis and technical support in information technology.

The audit also revealed that the proportion of non-compliant appointments of casual workers hired for more than 90 working days has increased between 2018 and 2023. For the 2023 calendar year, 52% (11 out of 21) of the appointments did not meet the circumstances prescribed by the regulations.

This authority was granted to the RCMP to provide it with the required flexibility to adjust to operational demands in real time. However, the authority was intended to be exercised only in those circumstances defined in the regulations. Other staffing options, such as term appointments, are available to managers to assist them in meeting their staffing needs.

Moving forward, it will be important that the RCMP implement their framework as intended and that its monitoring activities better detect and correct non-compliant situations. The PSC should also maintain ongoing oversight of the RCMP’s use of this delegated authority.

Recommendations

Recommendation 1: The Commissioner of the RCMP should conduct a review of the 21 non-compliant cases to determine why the existing framework and monitoring activities were insufficient to detect them and identify corrective measures to strengthen future compliance with the Royal Canadian Mounted Police Casual Employment Regulations. The results of this review, including any actions taken, should be reported to the PSC.

Recommendation 2: The Commissioner of the RCMP should report annually to the PSC on the use of the authority to appoint casual workers for more than 90 working days in one calendar year, including the number, the location, the groups and levels and the circumstances of the appointments. This could be done through the reporting requirements (Annex D) of the Appointment Delegation and Accountability Instrument.

Recommendation 3: As part of the review of the Royal Canadian Mounted Police Casual Employment Regulations by the PSC’s Policy and Communications Sector, the audit results, as they relate to non-compliant appointments, should be discussed with the RCMP to determine whether the regulations meet the RCMP’s needs or whether adjustments are required.

Moving forward: the Royal Canadian Mounted Police’s response

Response to recommendation 1

The Royal Canadian Mounted Police (RCMP) accepts the audit findings. Corporate Staffing has monitored the application of the Royal Canadian Mounted Police Casual Employment Regulations via the approval process since the inception of the regulations. Though this framework is in place, the audit results suggest consideration be given to reviewing internal controls and file review mechanisms that may better flag non-compliance in real time and ensure corrective action is taken on individual files.

The following issues routinely arise in monitoring and have been analyzed on a general systemic level (the RCMP has been awaiting PSC annual review and regulatory review to help determine next steps):

• The ambiguity of what exactly does and does not constitute a major event, major investigation, an operation and unforeseen circumstances. Definitions are imprecise and open to broad interpretation.
• The Human Resources Management Information System does not enable term or indeterminate as-and-when-required staffing options. Many casual as-and-when-required requests, whether 90+ or not, cannot be processed another way in the system. Thus, the choice may be between casual as-and-when-required staffing or leaving the position vacant, which is not viable operationally. It is possible to introduce this functionality to the system, but key stakeholders, such as Compensation, have expressed concerns regarding increased workload that would result.
• There is a potential mismatch between the requesting manager authority, that is, the manager with financial authority and operational accountability, and the sub-delegated staffing authority responsible for approving the casual 90+ (typically an HR representative). HR largely operates in an advisory & client service capacity; requesting managers otherwise operate with full staffing authority.

Response to recommendation 2

The RCMP accepts the audit findings. Under the Public Service Employment Act, the PSC has authority to conduct an annual review of the exercise of Royal Canadian Mounted Police Casual Employment Regulations authority. The RCMP agrees to provide the requested information via the Appointment and Delegation Accountability Instrument’s Annex D annual reporting requirement, and welcomes the opportunity to receive timely feedback on the use of casual 90+ going forward.

Response to recommendation 3

The RCMP accepts the audit findings. The RCMP looks forward to PSC Policy and Communication Sector consultation on the review of the regulations.

Moving forward: the Public Service Commission of Canada’s response

A review of the Royal Canadian Mounted Police Casual Employment Regulations was already planned and included in the Public Service Commission of Canada (PSC)’s forward regulatory plan. The PSC will ensure that the findings of the audit are considered and integrated into the upcoming review and will hold consultations with the RCMP, thereby reinforcing our commitment to continuous improvement and accountability.

Annex A: About the audit

Objectives and criteria

The objectives and criteria of this audit were:

Objective 1: To determine if the RCMP has a framework in place to support sub-delegated managers when appointing casual workers for more than 90 working days during the same calendar year.

• Criterion 1.1: Review of the RCMP’s policies, guidelines, processes and practices implemented to support managers when appointing casual workers for more than 90 days in one calendar year.
• Criterion 1.2: Review of the RCMP’s controls and monitoring requirements to ensure that the use of casual workers for more than 90 days in a calendar year is conducted according to the intent of the Royal Canadian Mounted Police Casual Employment Regulations.

Objective 2: To determine if the appointments of casual workers for more than 90 working days during the same calendar year meet the requirements set by the RCMP.

• Criterion 2: Review of casual workers’ appointments of more than 90 working days in one calendar year to determine if they meet the requirements established by the RCMP (identified as part of audit objective 1).

Objective 3: To determine if the appointments of casual workers for more than 90 working days during the same calendar year meet the circumstances prescribed in the Royal Canadian Mounted Police Casual Employment Regulations.

• Criterion 3: Review of casual workers’ appointments of more than 90 working days in one calendar year to determine if they meet the circumstances prescribed in the Royal Canadian Mounted Police Casual Employment Regulations (Section 2): “A person may be appointed as a casual worker to the Royal Canadian Mounted Police for a period of more than 90 working days in one calendar year for a major investigation, a major event or an operation if the services of the person are required as a result of unforeseen circumstances such as an unknown duration or the unexpected need for a particular skill.”

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