Information Bulletin on Double or Multiple Banking of Positions

Purpose

The purpose of this bulletin is to provide direction associated with double or multiple banking, which is the practice of staffing more than one employee in a position. The use of this practice is inconsistent with the intent of the following policy instruments:

• Policy on People Management:
  • subsection 4.1.9: “Planning, managing and utilizing the organization’s workforce effectively”
• Directive on Classification:
  • subsection 4.2.2: “Seeking advice from persons accredited in organizational design and classification when proposing changes to their organizational structure and when updating job descriptions”
  • subsection 4.2.5: “Maintaining accurate organizational structures and current job descriptions for their area of responsibility”

In accordance with the Financial Administration Act, paragraph 7(1)(e) and section 11.1, the Treasury Board may, in its capacity as Employer, act on matters relating to human resources (HR) management. The Office of the Chief Human Resources Officer (OCHRO) supports the Treasury Board by, among other things, providing direction and leadership to support deputy heads to fulfill their responsibilities.

Application

This bulletin is effective immediately and applies to organizations in the core public administration (CPA). It supports organizational design and classification (OC) advisors, staffing advisors and managers authorized to approve staffing actions and to assign work. It is to be used in conjunction with all relevant and subsequent direction and tools issued by OCHRO on this topic.

This bulletin applies to non-Executive group positions.

Background

Through oversight, OCHRO has noted the ongoing practice of double or multiple banking of indeterminate employees to a single position within CPA organizations. This practice is inconsistent with established workforce management policies and contradicts the foundational intent of the Policy on People Management, which emphasizes the importance of maintaining accurate and transparent organizational structures. This practice must cease immediately.

Risks and impacts

The practice of double or multiple banking indeterminate employees to a single position results in organizational structures that do not reflect operational reality. The risks and impacts associated with this practice will vary across organizations, depending on the current state of their organizational design and the maturity of their governance and oversight mechanisms.

Common risks include but are not limited to:

• data inconsistencies in HR systems and jeopardized data integrity
• breaches of privacy
• compromised employee rights
• challenges in labour relations and workforce planning
• undermining of transparency and accountability
• confusion in organizational structures
• complicated HR decisions related to classification, compensation and staffing through inaccurate organizational charts, unclear reporting relationships, inaccurate official language requirements, inaccurate security clearances and duplicated responsibilities
• hindered transition to a common HR system
• legal and operational issues, including an increased risk of pay inequities and grievances and implications in cases involving essential positions, exclusions, or pay file or employee (block) transfers under the Public Service Employment Act

Direction and implementation

The practice of double or multiple banking indeterminate employees in positions is not permitted and is not an allowable strategy to expedite the job evaluation and hiring processes.

To ensure alignment with Treasury Board policies, organizational principles and practices, all current instances of indeterminate double or multiple banking are to be corrected. This means that each indeterminate employee must have their own position number. These cases will be referred to the appropriate classification advisor to provide advice and determine the correct actions as required.

Exceptions

In exceptional circumstances and HR systems permitting, consideration may be given to allowing a temporary double or multiple banking arrangement for short-term operational need, such as but not limited to:

• succession planning for confirmed retirements
• micro-missions
• acting assignments or leave coverage

Double or multiple banking may be leveraged or applied on an exceptional basis provided that:

• a staffing or HR advisor has conducted a thorough analysis of the staffing need, compensation and labour relations implications
• a risk management strategy has been discussed and documented
• advice from an organizational design and classification advisor has been sought to confirm compliance with existing organization and classification policy instruments and standards

The exception may be implemented by a staffing or HR advisor in accordance with the conditions above and will remain valid only for the duration of the specific context in which it was granted. All exceptions must be documented and reviewed cyclically.

Oversight

Heads of HR are responsible for ensuring appropriate oversight of classification activities within their organizations. To support this responsibility, the following expectations are reiterated:

• heads of HR are expected to actively monitor and track the use of double or multiple banked positions and implement corrective measures where necessary
• heads of HR should ensure that internal processes are in place to identify and address classification issues, including impasses and non-compliance with approved Treasury Board policy instruments and job evaluation standards

OCHRO will conduct oversight to assess organizational compliance with this bulletin. Where issues are identified, organizations may be directed to take corrective action and implement additional measures to ensure alignment with the Policy on People Management and its supporting instruments.

Enquiries

All questions pertaining to this information bulletin should be directed to departmental corporate classification resources, who, if required, will direct questions to the Workforce Organization and Classification Division of OCHRO at ZZORGCLA@tbs-sct.gc.ca.

David Prest
Associate Assistant Deputy Minister
Employee Relations and Total Compensation
Office of the Chief Human Resources Officer
Treasury Board of Canada Secretariat