Privacy Act - Annual report 2024-25

Table of contents

• Introduction
  • The Office of the Commissioner of Lobbying
  • Responsibility for Information Rights and Delegation of Authority
• Administration of the Privacy Act
  • Performance 2024-2025
  • Training and Awareness Activities
  • Implemented Policies, Guidelines and Procedures
  • Initiatives and Projects to Improve Privacy
  • Complaints 
  • Material Privacy Breaches
  • Privacy Impact Assessments
  • Disclosure of Personal Information
  • Monitoring Compliance
  • Reading Room
• Annex A — Delegation Order
• Annex B — 2024-25 Statistical Report

Introduction

The Privacy Act (Revised Statute of Canada 1985, Chapter P-21) was proclaimed on July 1, 1983. The Privacy Act extends to individual Canadian citizens and permanent residents, the right of access to information about themselves held by the government, subject to specific and limited exceptions. The Privacy Act also protects the individual’s right to privacy by preventing others from having access to personal information and gives individuals substantial control over its collection and use.

Section 72 of the Privacy Act requires that the head of every government institution prepare an annual report on the administration of the Act within the institution during each financial year for submission to Parliament. 

This annual report is submitted by the Office of the Commissioner of Lobbying (OCL) in accordance with the Privacy Act. It describes how the OCL fulfilled its responsibilities under this Act during the reporting period from April 1st, 2024, to March 31, 2025. 

The Office of the Commissioner of Lobbying

The federal lobbying regime sets requirements and standards for the transparent and ethical lobbying of federal officials. The Commissioner of Lobbying with the support of the Office administers the Lobbying Act and the Lobbyists’ Code of Conduct.

Our primary responsibilities include:

• maintaining and enhancing the Registry of Lobbyists,
• expanding awareness and understanding of the lobbying regime and compliance obligations through education,
• conducting compliance work that supports respect of federal lobbying requirements.

The OCL is a micro-organization of 36 full-time equivalents (FTEs) that supports the Commissioner in achieving her mandate.

The OCL did not have any non-operational (“paper”) subsidiaries during this reporting period.

Responsibility for Information Rights and Delegation of Authority

The Privacy Act provides the authority to the Commissioner of Lobbying to exercise full powers granted under the Act. The OCL’s Access to Information and Privacy (ATIP) Coordinator is delegated the authority via a Delegation Order, of which a copy is attached in Annex A. The OCL has two positions responsible for the administration of the Privacy Act, the ATIP Coordinator and the Manager of Corporate Services.  

The Executive Director of Corporate Services was the ATIP Coordinator from April 1st, 2024, to March 31, 2025. The ATIP Coordinator is responsible for the development, coordination and implementation of effective policies, guidelines and procedures to manage the OCL’s compliance with the Privacy Act. The coordinator makes decisions on the disposition of requests under the Privacy Act, promotes awareness of the legislation to ensure organizational responsiveness to its obligations, as well as monitors and advises on compliance with the Privacy Act, regulations, procedures and policies. Furthermore, the Coordinator acts as the spokesperson for the OCL in dealings with the Treasury Board Secretariat, the Privacy Commissioner, and other government departments and agencies. The coordinator is also responsible for conducting consultations with other governments within Canada and other federal organizations, as required. Finally, the Coordinator is the point of contact on issues involving the collection of personal information and privacy.

The Manager of Corporate Services provides support to the ATIP Coordinator on the process of any requests received under the Privacy Act. 

Due to the limited number of requests received, the OCL did not dispose of any service agreements under section 73.1 of the Privacy Act during the reporting period from April 1st, 2024, to March 31, 2025.  

Under the Lobbying Act, the OCL collects information from registrants and lobbyists and the disclosures filed by registrants are accessible on the Registry of Lobbyists at the following address: lobbycanada.gc.ca.

The OCL’s Annual Report and Reports on Investigations must be tabled in both Houses of Parliament. They are also published on the OCL’s website and proactively disclosed on the Open Government Portal. 

Administration of the Privacy Act

Performance 2024-25

Annex B provides a statistical summary of requests under the Privacy Act received during the reporting period. 

During the reporting period, the OCL did not receive any request under the Privacy Act.  

Requests outstanding from previous reporting periods

At the beginning of 2024-25, the OCL had no request outstanding from previous reporting periods. 

Consultations from other institutions

The OCL did not receive any consultations from other institutions during the reporting period. 

Extensions

The OCL did not take any extensions during the reporting period.  

Training and Awareness Activities 

The Directive on Personal Information Requests and Correction of Personal Information sets out the mandatory training requirements for all government employees. To comply with this Directive, the OCL requested that all its employees complete a training on access to information and Privacy offered by the Canada School of Public Service. The different policies and directives on privacy were also posted on the OCL intranet so that all employees can access them easily. 

The employees of the OCL that have functional or delegated responsibilities for the administration of the Privacy Act already have followed in-depth training on privacy practices. They have not followed any additional training in 2024-2025. 

Implemented Policies, Guidelines and Procedures

During the reporting period, the OCL did not implement new policies, guidelines or procedures related to the Privacy Act.

Initiatives and Projects to Improve Privacy

The OCL is a micro-organization of 36 full time equivalents (FTEs) with very limited resources. For that reason, in addition to the fact that the OCL receives few requests under the Privacy Act, the OCL did not allocate resources to put in place initiatives and projects to improve Privacy. 

Complaints

No complaints related to the Privacy Act were received from the Office of the Privacy Commissioner in 2024-25. Also, the OCL does not currently have any active complaints.  

At the beginning of 2024-25, the OCL had no active complaint concerning the Privacy Act that was outstanding from previous reporting periods.

Material Privacy Breaches

No material privacy breaches occurred in 2024-25. 

Privacy Impact Assessments

During the reporting period, the OCL conducted a Privacy Impact Assessment (PIA) for the implementation of its Microsoft 365 Cloud Tenant. More information about this PIA is available on the OCL website. 

Public Interest Disclosures

There were no disclosures of personal information by the OCL during the reporting period pursuant to the paragraph 8(2)(m) of the Privacy Act.

Monitoring Compliance

Given that the OCL did receive any request during the reporting period, no monitoring compliance was conducted. 

Reading Room

A reading room is available at the OCL’s office, situated on the 8th floor at 410 Laurier Avenue West, Ottawa, Ontario, Canada K1R 1B7.

Annex A — Delegation Order

Access to Information Act and Privacy Act Delegation Order

August 18, 2022

The Commissioner of Lobbying, pursuant to section 95(1) of the Access to Information Act and section 73(1) of the Privacy Act, hereby designates the person holding the position set out in the schedule hereto, or the person occupying on an acting basis that position, to exercise the powers, duties and functions of the Commissioner of Lobbying as the head of the Office of the Commissioner of Lobbying, under the provisions of the Act and related regulations set out in the schedule opposite each position. This designation replaces all previous delegation orders.

Schedule

Position

Executive Director of Corporate Services

Access to Information Act and Regulations

Full authority

Privacy Act and Regulations

Full authority

Nancy Bélanger

Annex B — 2024-25 Statistical report

Statistical report on the Privacy Act

Name of institution: Office of the Commissioner of Lobbying

Reporting period: 2024-04-01 to 2025-03-31

Section 1: Requests Under the Privacy Act

1.1 Number of requests received