Annual Report to Parliament on the Administration of the Access to Information Act - 2024-2025

Table of Contents

• Introduction
  • Purpose of the Access to Information Act
  • Mandate of the Institution
  • Operating Context
• Organizational Structure
  • Organizational Structure - Proactive Publication under Part 2 of the ATIA
• Delegation Order
• Performance under the Part 1 of the Access to Information Act, 2024-2025
  • Number of Requests
  • Active Requests Carried Over to the Next Reporting Period
  • Extensions
  • Compliance Rate
  • Completion Time
  • Disposition of Completed Requests
  • Decline to Act – Subsection 6.1(1) of the Access to Information Act
  • Informal Requests
  • Consultations from Other Government Institutions and Other Organizations
  • Staffing
• Training and Awareness
• Policies, Guidelines and Procedures
  • Effective Communication
  • Refine Procedures - Proactive Disclosure
• Initiatives and Projects to Improve Access to Information
  • Working With the Information Commissioner
  • Integration of ATIP in Executive Performance Management Program (PMP)
  • ATIP Engagement at GAC’s Executive Committee and Corporate Management Meeting
  • Open Government Departmental Outreach Initiatives
  • New Software Solution for Processing Requests
  • Human Resources and Talent Development
• Summary of Key Issues and Actions Taken on Complaints
  • Complaints Received and Completed
  • Active Complaints Carried Over to the Next Reporting Period
• Proactive Publication
• Monitoring Compliance
  • Ongoing Reporting
  • Limiting Inter-Institutional Consultations
  • Frequently Requested Types of Information
  • Right of Access in Contracts, Information Sharing Agreements and Information Sharing Arrangements
• Annex A: Designation Order

Introduction

We are pleased to table the Annual Report to Parliament on the administration of the Access to Information Act (the Act) for fiscal year 2024-2025, as required under section 94 of the Act. Global Affairs Canada is not reporting on behalf of wholly-owned subsidiaries or non-operational institutions.

Note: The Department is referred to in this report as Global Affairs Canada (GAC). Its legal name, however, remains the Department of Foreign Affairs, Trade and Development, as set out in the Department of Foreign Affairs, Trade and Development Act.

Purpose of the Access to Information Act

The purpose of the Access to Information Act is to enhance the accountability and transparency of federal institutions in order to promote an open and democratic society and to enable public debate on the conduct of those institutions.

Part 1 of the Access to Information Act extends the present laws of Canada to provide a right of access to information in records under the control of a government institution in accordance with the principles that government information should be available to the public, that necessary exceptions to the right of access should be limited and specific and that decisions on the disclosure of government information should be reviewed independently of government; and decision on the disclosure of government information should be reviewed independently of government.

Part 2 of the Access to Information Act sets out requirements for the proactive publication of information.

Mandate of the Institution

Global Affairs Canada, under the leadership of the Minister of Foreign Affairs, the Minister of International Trade, the Minister responsible for Canada-US trade, Intergovernmental Affairs and One Canadian Economy, and the Secretary of State (International Development), is responsible for advancing Canada’s international relations, including:

• developing and implementing foreign policy;
• fostering the development of international law, international trade and commerce;
• providing international humanitarian, development, and peace and security assistance;
• providing consular services for Canadians; and
• overseeing the Government of Canada’s global network of missions abroad.

Global Affairs Canada’s mandate is derived from the Department of Foreign Affairs, Trade and Development Act.

Operating Context

From the movement of people and goods around the world to regional conflicts and changes caused by climate change, the world is more connected and interconnected than ever. Events within and beyond our borders influence Canadians’ peace, security and prosperity.

The world is seeing challenges and threats to peace and security, rules-based trade and equitable access to resources and assistance. Aggressive actions by both state and non-state actors mean that Canada must continue to work with allies and partners to address these challenges and threats. Canada is not immune to the economic threats posed by uneven supply chains, shifting alliances and deteriorating trade relations among nations.

As a result, Canada’s international activities must foster security and prosperity for Canadians through a full suite of policies and programs that promote peace and security, strengthen rules-based trade and contribute to humanitarian and development assistance.

Global Affairs Canada is the department responsible for managing Canada’s diplomatic and consular relations, international trade and development efforts around the world. In a continuously changing and unpredictable international setting, protecting Canadians remains Global Affairs Canada’s top priority.

Organizational Structure

The Access to Information and Privacy Protection Division (the ATIP Division) is responsible for the administration of the Access to Information Act (ATIA) and the Privacy Act (PA), including the processing of requests and consultations. The director of the ATIP Division reports to the Director General, who also serves as the Corporate Secretary, and who, in turn, reports to the Associate Assistant Deputy Minister, Strategy, Policy and Public Affairs.

In 2024-2025, the ATIP Division had 64 Full-Time Equivalent positions to fulfill the Department’s obligations under both the Access to Information Act and the Privacy Act. During the fiscal year, the ATIP Division filled, on average, 62 of those 64 positions and relied on up to seven ATIP consultants.

The ATIP Division is led by a director, who manages the teams that administer the Access to Information and Privacy Acts:

• The Operational Unit is managed by four deputy directors who head one or two processing teams. There are seven team leaders who supervise processing teams. Two senior advisors, 22 analysts and five consultants are distributed throughout these teams. The Operational Unit is responsible for the processing and review of access, privacy and consultation It also includes a team with dedicated resources to address complaints; the team, processes legacy complaints and works closely to resolve them with the Office of the Information Commissioner (OIC) and the Office of the Privacy Commissioner (OPC).
• The Privacy Policy Team is managed by a deputy director and includes a team leader, five analysts and a consultant, who deal directly with privacy breaches, departmental complaints, privacy impact assessments and requests for privacy
• The Policy and Governance Team is managed by a deputy director and includes a senior ATIP policy and governance advisor, who coordinates process modernization, procedural updates and departmental
• The Business Practices and Systems Unit is managed by a deputy director and includes a manager of business practices and systems, an ATIP systems analyst, three system administrator and four ATIP clerks who process incoming and outgoing ATIP correspondence, imaging services, technical support and other administrative tasks.
• The Corporate Affairs Unit is managed by a deputy director and includes an administrative assistant and a consultant. This group is responsible for the oversight of the division’s human resources, budget management and general administration.

All employees are working within a hybrid model, with telework from home and in-office presence at headquarters (125 Sussex Drive). Global Affairs Canada did not have any regional ATIP staff during the fiscal year 2024-2025. 

During the fiscal year 2024-2025, Global Affairs Canada did not have any service agreements pursuant to section 96 of the Access to Information Act.

Organizational Structure - Proactive Publication under Part 2 of the ATIA

During the reporting period, responsibility for proactive disclosure under Part 2 of the Access to Information Act was managed by several different departmental leads (see table below). No specific position or group monitored departmental compliance overall.

Delegation Order

As part of GAC’s transformation implementation plan, the Access to Information and Privacy Division revised its delegation instrument under the Access to Information Act. The previous delegation order, signed in July 2017, no longer aligned with GAC’s new structure and operational needs. The updated delegation order is designed to enhance efficiency in processing Access to Information Act requests by enabling a broader range of decision-makers such as Team Leaders and Senior Advisors.

The revised delegation instrument now authorizes Senior Advisors and Team Leaders within the ATIP Division to make a wider range of decisions and approve additional tasks. By empowering experienced supervisors and managers to exercise delegated authority, the Division aims to reduce bottlenecks and improve response times on ATIA requests.

In January 2025, pursuant to section 95 of the Access to Information Act, the Minister delegated full authority to the Deputy Ministers, Associate Deputy Minister of Foreign Affairs, Assistant Deputy Minister and Associate Assistant Deputy Minister of Strategy, Policy and Public Affairs, the Director General of the Corporate Secretariat, the Director of the Access to Information and Privacy Division, the Deputy Directors of the Access to Information and Privacy Division and Team Leaders within the ATIP program. In addition, Senior Advisors were granted authority to issue time extension under the Act.

A copy of Global Affairs Canada’s signed Designation Order is provided in Annex A.

Performance under the Part 1 of the Access to Information Act, 2024-2025

Number of Requests

In 2024-2025, the Department received 1043 new requests for information under the Access to Information Act, a decrease of 45% compared to the 2023-2024 fiscal year and a decrease of 20% compared to the average of the previous three reporting periods. At the beginning of the 2024-2025 fiscal year, a total of 1954 requests were outstanding from the previous reporting periods; 1147 requests were outstanding from the 2023-2024 fiscal year, and 807 requests were outstanding from more than one reporting period. During the same reporting period, 1845 requests were closed; a significant increase of 52% compared to the 2023-2024 fiscal year.

Active Requests Carried Over to the Next Reporting Period

At the end of the reporting period, 20% of Global Affairs Canada’s requests that were carried over the next reporting period (2025-2026) were on time. The carry-over of active files at the end of fiscal year 2024-2025 was 1152.

Extensions

Of the 1845 requests closed during the reporting period, GAC invoked 1157 extensions pursuant to section 9:

• 382 times pursuant to 9(1)(a) for interference with government operations
• 751 times pursuant to 9(1)(b) to undertake consultations
  • This includes 18 times where consultations were required with the Department of Justice Canada to confirm exclusion pursuant to subsection 69(1) of the ATIA.
• 24 times pursuant to 9(1)(c) to undertake third party consultations

Compliance Rate

The compliance rate is defined as the percentage of access to information requests that the Department responded to within the deadline required under the Act. In 2024-2025, the departmental compliance rate for Global Affairs Canada was 41%. This means that 58% of Access to Information requests received a response beyond the deadline. The compliance rate for the reporting period decreased by 8% compared to the previous reporting period.

Completion Time

During the reporting period, the Department closed a total of 108 requests in 15 days or less (6%), 190 requests closed within 16-30 days (10%), 132 requests closed within 31-60 days (7%), 304 requests closed within 61-120 days (17%), 146 requests closed within 121-180 days (8%), 318 requests closed within 181-365 days (17%), and 647 requests took over 365 days to complete (35%).

Disposition of Completed Requests

Of the 1845 Access to Information requests closed in the 2024-2025 fiscal year, 100 were all disclosed (6%), 657 were disclosed in part (36%), 25 were all exempted (1%), 40 were all excluded (2%), 170 had no records in existence (9%), 38 were transferred (2%), 246 were abandoned (13%), 13 were neither confirmed nor denied that we had records (1%) and 556 were declined to act with the approval of the Information Commissioner (30%).

Decline to Act – Subsection 6.1(1) of the Access to Information Act

In 2024-2025, Global Affairs Canada declined to act on 556 requests under subsection 6.1(1) of the Access to Information Act. During the fiscal year, GAC received 597 access to information requests from a single individual. Following multiple discussions with the requester, it became evident that the volume and nature of requests were intended to overwhelm the Department’s resources, prompting the need for additional capacity with the ATIP Division.

GAC considered the requests to be vexatious and referred the matter to the Office of the Information Commissioner (OIC) for review. While the OIC did not agree that the requests met the threshold for being vexatious under the Act, it acknowledged that the requester’s approach constituted an abuse of the right of access, justifying the application of subsection 6.1(1) to refuse to act on a majority of the submissions.

As a result, GAC closed 556 of the 597 requests. The remaining 41 requests continued to be processed.

Informal Requests

Global Affairs Canada (GAC) remains committed to transparency by proactively publishing summaries of completed access to information requests monthly. These summaries are made available through the Open Government portal (open.canada.ca), enabling Canadians to identify and request previously-disclosed information.

This practice supports greater access to government-held information and encourages the use of the informal request process, which allows individuals to obtain previously released records more quickly and at no cost. Over the past fiscal years, GAC has observed a significant increase in the volume of informal requests, reflecting growing public engagement with the access to information regime.

Consultations from Other Government Institutions and Other Organizations

Given its mandate and various responsibilities at the international level, the Department plays a key role under the Act on behalf of other institutions of the Government of Canada. Specifically, the Department consulted foreign governments and organizations on behalf of other federal government institutions when the latter needed to determine whether they could release records that originated abroad.

During the reporting period, Global Affairs Canada received 436 consultations from other government institutions (32,063 pages) and 10 consultations from other organizations (comprising 174 pages). Furthermore, the Department closed 553 consultation requests and reviewed 37,878 pages.

Of all consultation requests from other government institution and other organizations closed during the reporting period, 59 requests were closed in 15 days or less (11%), 46 requests closed within 16-30 days (8%), 68 requests closed within 31-60 days (12%), 98 requests closed within 61-120 days (18%), 71 requests closed within 121-180 days (13%), 86 requests closed within 181-365 days (15%), and 125 requests took over 365 days to complete (23%).

Staffing

In 2024-2025, the ATIP Division had 47.75 person years dedicated to access to information activities. This represented a slight increase from the previous reporting period (1.3%), thus demonstrating that the ongoing recruitment strategies were efficient in an ongoing hybrid work context.

Training and Awareness

The ATIP Division continued to develop tools, guidance and training for ATIP analysts, ATIP liaison officers and subject matter experts across Global Affairs Canada.

Again, during the reporting period, the ATIP Division benefited from its Professional Development Program (PDP), which allows the Department to train and promote its ATIP analysts from junior (PM-01) to senior (PM-05) levels. This long-standing program continues to be highly successful in addressing recruitment, retention and succession planning issues. Most of the employees working in the ATIP Division are already part of the PDP and are eligible for promotion to the next level once they meet the required objectives. The PDP aims to build a more robust ATIP capacity within Global Affairs Canada by “growing its own”, thereby addressing the shortage of analysts and team leaders across the federal ATIP community.

During the reporting fiscal year, three employees from the Access to Information and Privacy Division at Global Affairs Canada participated in specialized training offered by the Association des professionels en accès à l’information et en protection de la vie privée (AAPI). Delivered over two weeks, the program consisted of four courses spanning six days, for a total of 42 instructional hours. The training provided in-depth knowledge of the Access to Information Act and the Privacy Act. Upon successful completion, participants were awarded a joint certificate from the Université de Montréal and the AAPI, attesting to the high quality and rigor of the training.

Additionally, the ATIP Division provided the following training modules to GAC employees:

• ATIP for liaison officers
• ATIP for reviewing officers

Due to GAC’s rotational employee structure, ATIP training sessions were made available upon request and attendance varied from one-on-one training to group training with up to 104 participants. During the fiscal year, a total of 67 training sessions were delivered to 1060 Global Affairs Canada employees. Of these, 65 presentations were delivered virtually using MS Teams and 2 training sessions were delivered in person.

Building on the prior years’ process, improvements and training for proactive disclosure, additional drop-in sessions on the proactive publication of contracts were provided to the Reports team this year.   

Monthly reminder emails also continued to be sent to Ministers, senior officials and exempt staff, outlining their responsibilities and deadlines for proactive travel and hospitality disclosure.  

Policies, Guidelines and Procedures

Effective Communication

During the year, Global Affairs Canada introduced a “red-tape reduction initiative” as part of GAC’s transformation implementation plan. To be more proactive and efficient, the ATIP Division worked closely with GAC’s communications bureaux to streamline its communication process when disclosing records in response to ATIA request which could generate additional questioning from requesters.

Refine Procedures - Proactive Disclosure

Across Global Affairs Canada, standard operating procedures are in place to meet proactive disclosure requirements. For example:    

For travel and hospitality expenses (sections 75, 76, 82 and 83) the process is outlined on an internal page with guidelines and procedures to assist all officials required to disclose travel and hospitality expenses, including step by step instructions and tools. Additionally, GAC launched a new platform for the disclosure of travel and hospitality expenses, which entails data being published concurrently on the GAC’s Open Government websites. This tool aims to simplify the tracking of proactive disclosure compliance and provide a single point of access for Canadians.

For contracts over $10,000 (sections 77 and 86), the Department developed and published a work instruction (guide) to improve data integrity during the creation of procurement transactions in its Financial Administration System (FAS), where data for proactive disclosure is extracted from.

The process changes implemented last fiscal year have further improvements to publication timeliness, achieving 100% compliance in five new sections (sections 88b, 88c, 74b, 74c, and 74d).

Initiatives and Projects to Improve Access to Information

Working With the Information Commissioner

On April 11, 2024, the Associate Deputy Minister of Foreign Affairs met with the Information Commissioner of Canada, to discuss the ongoing successes and challenges in managing Access to Information priorities at Global Affairs Canada. During the meeting, GAC highlighted the active engagement of its senior management in the administration of the Access to Information Act (ATIA) and reaffirmed its commitment to improving departmental performance.

Integration of ATIP in Executive Performance Management Program (PMP)

In response to recent recommendations from the Office of the Information Commissioner to strengthen Canada’s access to information regime, GAC has taken concrete steps to enhance accountability and performance in this area. For the 2024-2025 fiscal year, GAC designated the “timeliness and completion of access to information and privacy request” as a corporate priority for its executives.

This priority was formally integrated into the Executive Performance Management Program (PMP) for 2024-2025.

ATIP Engagement at GAC’s Executive Committee and Corporate Management Meeting

In the 2024-2025 fiscal year, the Director General and Corporate Secretary of Global Affairs Canada, responsible for the administration of the Access to Information Act, along with the Director of the Access to Information and Privacy Division, participated in key senior-level corporate governance meetings. They attended GAC’s Executive Committee in April 2024 and at GAC’s Corporate Management Meeting in November 2024.

At both meetings, the Director General and Corporate Secretary, and the Director underscored the critical importance of timely responses to ATIP requests and the need to reduce the backlog of outstanding taskings. They also shared best practices and strategies to support improved performance and compliance across the department.

Open Government Departmental Outreach Initiatives

Global Affairs Canada’s Enterprise Data Management (EDM) team is responsible for coordinating and maximizing the release of departmental information and data on the Treasury Board of Canada Secretariat (TBS) Open Government Portal, as designated by the Directive on Open Government. Prior to May 2023, the EDM team conducted extensive outreach activities both at HQ and missions abroad, reaching almost 300 divisions. The early outreach aimed to introduce the mandate and highlight publishing requirements, which resulted in an initial growth from 50 to 159 open information assets for 2023-2024. The method for 2024-2025 shifted to a targeted approach. This was accomplished by locating reports, contacting data stewards and requesting permission to publish to the portal. They worked alongside Library and Archives Canada to assist the GAC Trade Division (TIA) in archiving and publishing older websites. The results of these efforts for the 2024-2025 fiscal year saw an increase in the number of open information assets published to the portal to 933 by March 31, 2025. The EDM team strives to increase awareness and highlight publishing requirements. These outreach activities continue to yield growing numbers of open information assets month over month as teams become increasingly aware of reports that are suitable for publishing on the TBS Open Government portal. 

New Software Solution for Processing Requests

The current case management software used to process requests is becoming obsolete and will no longer be supported by the vendor in the coming years. GAC is using this opportunity to replace the legacy software and leverage new technology to increase efficiencies in our service delivery and to better handle the large volume of ATIP requests. Deployment of the new solution is anticipated for fiscal year 2025-2026.

Human Resources and Talent Development

The hybrid work model continued to support staff retention in the ATIP Division during the 2024-2025 fiscal year. Like other government institutions, Global Affairs Canada faced ongoing challenges in recruiting skilled analysts, particularly at the senior level.

Despite these challenges, the ATIP Division achieved notable recruitment success, appointing 13 new employees – 10 of whom are new to the Department. The Division also leveraged its Professional Development Program to support internal career growth, resulting in the promotion of seven existing staff members.

These efforts have contributed significantly to the ATIP Division’s operational success over the past year.

Summary of Key Issues and Actions Taken on Complaints

Complaints Received and Completed

During the 2024-2025 fiscal year, 218 complaints were made to the Office of the Information Commissioner of Canada regarding access to information requests to the Department.

The reasons for the complaints were as follows:

Over the course of the reporting period, 333 complaints against the Department were concluded. The findings on closed complaints were as follows:

The ATIP Division continues to operate a team dedicated to managing complaints from the Office of the Information Commissioner. This team serves as the primary point of contact between Global Affairs Canada and the OIC, working closely and collaboratively to strengthen relationships and improve Global Affairs Canada’s ATIP program performance.

Active Complaints Carried Over to the Next Reporting Period

Proactive Publication

The Department of Foreign Affairs, Trade and Development is a government institution for the purposes of Part 2 of the Access to Information Act.

 The Department is subject to the following proactive publication requirements:

Proactive Publication Requirements Table

* The Department now has an electronic verification system to confirm transactions were entered by the prescribed deadlines in all areas but hospitality. GAC is exploring the means to verify compliance with prescribed timelines for hospitality electronically moving forward.

** The Department is unable to differentiate between Government entities or Departments, agencies, and other bodies subject to the Act and listed in Schedules I, I.1, or II of the Financial Administration Act versus Minister. All contracts are uploaded to the Open Government website at the same time.

Monitoring Compliance

Ongoing Reporting

The ATIP Division prepares and distributes a weekly statistics report to the ATIP Division’s management team that tracks the number of requests that were received and closed, as well as any emerging trends and performance statistics. The report also allows for comparison of workload and completion rates in relation to the previous year to identify changes in ATIP processing.

Additionally, an active tasking report is generated and posted to the intranet weekly to identify all current active taskings within the Department. This report is available for all offices of primary interest (OPIs) to view and lists all open taskings by branch, highlighting late files.

During fiscal year 2024-2025, the Director General and Corporate Secretary continued to send the ATIP Twice Monthly Performance Report to deputy ministers, assistant deputy ministers and directors general, outlining the number of active taskings and compliance within each of the branches/special bureaus. The intent of this procedure is to call attention to the backlog of active taskings to senior management, thereby increasing compliance.

In addition to the Twice-Monthly ATIP Report, ATIP Quarterly Reports are produced in July, October, January and April, and are shared with the same senior officials. These reports provide an overview of the performance of branches and special bureaus in meeting their obligations under the Access to Information Act and Privacy Act, with a particular focus on the completion of taskings and overall compliance rates. The purpose of the Quarterly Reports is to highlight and acknowledge the ATIP-related work accomplished across the department and to promote continued accountability through close monitoring of compliance trends throughout the fiscal year. 

Finally, the ATIP Division also prepares and distributes the Anticipated Response List (ARL), a twice-weekly report that provides Global Affairs Canada officials with advance notice of information scheduled for release under the Access to Information Act. The ARL is issued every Tuesday by end of day, with a follow-up update on Thursday to include any additional responses added since Tuesday. In addition to listing upcoming releases, the ARL also informs departmental officials of the anticipated release date for each response, ensuring coordinated awareness and preparedness across the Department.

In FY 2024-2025, GAC implemented a new system which now allows the department to track compliance with proactive disclosure timelines in all areas except hospitality expenses. Lead divisions managed their requirements independently by monitoring results and ensuring compliance.

Limiting Inter-Institutional Consultations

During the reporting period, the ATIP Division monitored superfluous inter-institutional consultations by having experienced ATIP team leaders oversee the relevant records before they were sent out for consultation. By doing so, ATIP team leaders were able to reduce the number of consultations sent to the other Government of Canada institutions and other organizations outside the Government of Canada, reducing the amount of time to process requests and not overburdening other departments with unnecessary consultations.

Frequently Requested Types of Information

Throughout fiscal year 2024-2025, Global Affairs Canada did not monitor or review frequently requested types of information for the purpose of making the information available by other means.

Right of Access in Contracts, Information Sharing Agreements and Information Sharing Arrangements

All GAC issued contracts include General Conditions found in the Public Service and Procurement Canada (PSPC) Standard Acquisition Clauses and Conditions (SACC) Manual, which include a clause in the General Conditions that relates to the Access to Information Act.

Annex A: Designation Order