Table of Contents
1. Executive Summary
Canada has a longstanding commitment to openness and accountability as a cornerstone of a strong, modern democracy. From the passing of access to information legislation over 30 years ago to current open government and proactive disclosure activities, the Government of Canada has worked to ensure transparency on federal operations to enable Canadians to hold their government accountable. The commitments included in Canada's Action Plan on Open Government 2014-16 will further the progress on the delivery of transparent and accountable programs and services focused on the needs of Canadians.
The proactive release of data and information is the starting point for all other open government activity. Accordingly, the Government of Canada has firmly established an "open by default" position in its mandatory policy framework by issuing the Directive on Open Government.
Under the direction of FINTRAC's Information Management Senior Official (IMSO) and Chief Information Officer (CIO), FINTRAC has identified several priorities and drivers for change related to Open Government. As the Centre works to achieve compliance with the Open Government Directive, FINTRAC's Open Government Implementation Plan will be posted online and updated annually. This plan will include changes to existing and/or new initiatives related to becoming compliant with the Directive over the next five years.
As Canada's financial intelligence unit (FIU), FINTRAC facilitates the detection, prevention and deterrence of money laundering, and terrorist activity financing by engaging in the following activities: receiving financial transaction reports and voluntary information reports; safeguarding personal information under its control; ensuring compliance of reporting entities; maintaining a registry of money services businesses in Canada; producing financial intelligence relevant to investigations of money laundering, terrorist activity financing and threats to the security of Canada; researching and analyzing data from a variety of information sources that shed light on trends and patterns in money laundering and terrorist activity financing; and enhancing public awareness and understanding of money laundering and terrorist activity financing.
As described in the Treasury Board of Canada Secretariat's (TBS) Directive on Open Government, all data and information resources of business value held by Government of Canada departments are to be open by default and released as open data and/or open information unless subject to valid exceptions. This presents several challenges to the Centre as it moves towards compliance with the Directive. The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) establishes stringent rules that govern both the management and disclosure of all information contained in the Centre's transaction reports and other records. Secondly, a cultural change is needed in any organization to support the move to "open by default". Finally, FINTRAC needs to reallocate existing human resources, and may need to reprioritize initiatives to implement the internal changes required to become compliant with the Directive on Open Government.
Through achieving compliance with the Directive on Open Government, FINTRAC has the opportunity to transform its information culture to be in a better position to leverage the information resources we receive and produce. Adopting and integrating open data and information formats will better position the Centre to leverage external resources, such as the Federal Geospatial Platform. Finally, achieving compliance will allow FINTRAC to promote transparency while enhancing public awareness of Money Laundering and Terrorist Financing by continuing to share data and information on the Open Government Portal, while respecting information protection and privacy requirements of the PCMLTFA.
As FINTRAC works towards implementing Open Government, the Centre will integrate its Open Government obligations into activities related to procuring, developing, or modernizing departmental information applications, systems, or solutions. FINTRAC's Information Management (IM) training and awareness program for all staff will be augmented with information related to Open Government.
2. Approvals
Stephane Cousineau
Information Management Senior Official, Deputy Directory and Chief Information Officer
Information Management / Information Technology Sector
Financial Transactions and Reports Analysis Centre of Canada
Date
Gerald Cossette
Director
Financial Transactions and Reports Analysis Centre of Canada
Date
3. Purpose
This document describes FINTRAC's plan to complete activities and deliverables aligned to the requirements of the Directive on Open Government, in order to achieve full compliance by the implementation deadline.
The objective of the Directive is to maximize the release of government information and data of business value to support transparency, accountability, citizen engagement, and socio-economic benefits through reuse, subject to applicable restrictions associated with privacy, confidentiality, and security. (Directive on Open Government, Section 5.1)
The expected results of the Directive on Open Government (Section 5.2) are that Canadians are able to find and use Government of Canada information and data:
- to support accountability;
- to facilitate value-added analysis;
- to drive socio-economic benefits through reuse; and,
- to support meaningful engagement with their government.
4. Context
4.1 FINTRAC's Mandate, Vision and Mission
The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) is Canada's financial intelligence unit (FIU). We strive to be recognized as a world-class financial intelligence unit in the global fight against money laundering and terrorist activity financing. FINTRAC facilitates the detection, prevention and deterrence of money laundering, and terrorist activity financing by engaging in the following activities:
- Receiving financial transaction reports and voluntary information on money laundering and terrorist activity financing in accordance with the legislation and regulations;
- Safeguarding personal information under its control;
- Ensuring compliance of reporting entities with the legislation and regulations;
- Maintaining a registry of money services businesses in Canada;
- Producing financial intelligence relevant to investigations of money laundering, terrorist activity financing and threats to the security of Canada;
- Researching and analyzing data from a variety of information sources that shed light on trends and patterns in money laundering and terrorist activity financing; and
- Enhancing public awareness and understanding of money laundering and terrorist activity financing.
FINTRAC is an independent agency that operates at arm's length from the law enforcement agencies and other entities to which it is authorized to disclose financial intelligence. It reports to the Minister of Finance, who is in turn accountable to Parliament for the activities of the Centre. FINTRAC was established by, and operates within, the ambit of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its Regulations.
The Centre employs approximately 350 employees, and is headquartered in Ottawa. It's Montreal, Toronto and Vancouver regional offices have specific mandates related to compliance with the PCMLTFA. Shared Services Canada is mandated to manage FINTRAC's IT-infrastructure services related to e-mail, data centers and telecommunications.
4.2 FINTRAC's Challenges and Opportunities
Some of FINTRAC's challenges and opportunities in putting the Open Government Implementation Plan into action include:
- Legislative constraints: The PCMLTFA establishes stringent rules that govern both the management and disclosure of all information contained in the Centre's transaction reports and other records. The data and information inventory and review requirements related to Open Government represent an opportunity for the Centre to improve internal awareness and protection of these sensitive information resources.
- Cultural change needed to support the move to "open": FINTRAC needs to continue moving towards an environment that is more conducive to sharing data and information with Canadians. An opportunity exists to develop standards and guidelines to streamline the collection of data and information in the future, and to improve the quality, accuracy and clarity of this information. An opportunity also exists for the Centre to consume information and data released through Open Government to improve the products we produce in support of our mandate.
- Reallocation of resources to address Open Government: FINTRAC needs to reallocate existing human resources, and may need to reprioritize initiatives to implement the internal changes required to become compliant with the Directive on Open Government. This shift in focus will allow the Centre to further improve the value of its information through increased quality, usability and findability of its information and data holdings.
5. Outcomes
Transforming our information culture
FINTRAC has a strong organizational culture with regards to the storage and protection of information and data. Due to the sensitivity of some of the information we maintain in support of our mandate, our five year legislative reviews, and biennial audits from the Office of the Privacy Commissioner, we continuously work to build upon these strong practices. A goal of our IM strategic direction is to close the gap between the information we have available and our ability to use it – implementing enhanced recordkeeping processes where required and improving our ability to find information when we need it. Implementing the Directive on Open Government will help us augment this goal by not only optimizing the value and reusability of our data and information internally, but also for the Government of Canada, and Canadians.
Adopting and Integrating Open Data and Information Formats
Increasing FINTRAC's organizational familiarity with standard open data and information formats, and adjusting business processes to consider Open Government requirements when procuring, developing, or modernizing departmental information applications, systems, or solutions will better position the Centre to participate in Government of Canada initiatives, such as the Federal Geospatial Platform. This will also better position the Centre to leverage the breadth of information currently available free of charge on the Open Data portal in support of initiatives related to our mandate.
Promoting transparency while enhancing public awareness of money laundering and terrorist activity financing
Increasing FINTRAC's proactive release of data and information as a result of an "open by default" end state, along with existing transparency initiatives FINTRAC is supporting today: proactive release of Privacy Impact Assessment Summaries, Completed Access to Information Act Request details, Proactive Disclosure of Contracts, Grants and Contribution Awards and Hospitality Expenses, will help ensure transparency on FINTRAC operations and enhance public awareness of money laundering and terrorist activity financing, while still protecting sensitive information at our disposal.
The Access to Information Act assumes the right of the public to access information collected and generated by federal departments and agencies; through the "open by default" perspective, this inherent right will be further supported and promoted. However, while the promotion of transparency and openness may reduce the number of requests from the public that are not relevant to the mandate and functions of FINTRAC (and thereby promoting more efficiency within the agency), it may greatly increase the number of requests directly related to money laundering and terrorist financing, particularly as FINTRAC and its role moves further into the public sphere.
6. Governance Structures and Decision Processes
The following sub-sections describe the governance structures and decision processes that support open government and how those responsibilities are delegated and fulfilled within the institution.
6.1 Roles and Responsibilities – Deputy Head and Information Management Senior Official
The governance of the FINTRAC Open Government Implementation Plan (OGIP) is informed by the responsibilities identified for the Information Management Senior Official (IMSO) and Director in sections 6 (Requirements), 7 (Monitoring and Reporting Requirements), and 8 (Consequences) of the Directive on Open Government.
IMSO and Director
| Role | OG Responsibilities |
|---|---|
| FINTRAC Director |
|
| Information Management Senior Official (IMSO) and Chief Information Officer (CIO) | The departmental IMSO, as designated by the Director, is responsible for the following:
|
Open Government Governance
| Committee | OG Responsibilities |
|---|---|
| FINTRAC Open Government Working Group (OGWG) |
The Open Government Working Group (OGWG) includes representatives with knowledge of FINTRAC programs, including Information Management, Communications, Access to Information and Privacy, Information Technology Security and business area information stewards. OGWG responsibilities include:
|
| Corporate Services Committee (CSC) |
The Corporate Services Committee (CSC) serves as FINTRAC's Information Governance Board. In addition to these responsibilities, the Corporate Services Committee contributes and provides oversight on strategic and program planning, priorities and reporting (finance, asset and real property, human resources and information technology) and on investment planning and reporting (including project updates). Open Government responsibilities include:
|
| Executive Committee (ExCo) |
The Executive Committee (ExCo) ensures the essential conditions—internal coherence, corporate discipline and alignment to outcomes—are in place for providing effective strategic direction, support to the minister, Parliament and Government of Canada priorities, and the delivery of cost effective results. For Open Government, ExCo is FINTRAC's senior executive committee, and may be deferred Open Government deliverables for approval by CSC. |
Open Government Implementation Plan Governance
FINTRAC's plan to address the six Open Government requirements described in the Directive on Open Government will be formed from an analysis of Canada's Action Plan on Open Government 2014-2016 and associated Management Accountability Framework (MAF) requirements. The OGIP will be updated annually, through consultation with sectors throughout the Centre through the Open Government Working.
Figure 1: Figure of the governance process related to the OGIP - Text version
The Open Government Working Group (Lead – Information Management Branch) (image of 7 people sitting around a table) is supported by the FINTRACT's Open Government Commitments including the TBS Directive on Open Government (image of a document), the Canada's action Plan on Open Government (image of the figure representing the Canada's action Plan on Open Government) and the Management Accountability Framework (image representing the Management Accountability Framework). The Open Government Working Group write the draft of the OGIP and send it to the Chief Information Officer (CIO) for review (image of a person at a computer desk). The revised OGIP is sent to the FINTRAC Director (image of a person looking at documents) for approval (image a document representing the Open Government Implementation Plan). For the annual updates, we go back to the Open Government Working Group and restart the process from the Open Government Working Group.
Open Government Deliverables Governance
Figure 2: Government Deliverables Governance - Text version
The FINTRACT's Open Government Commitments including the TBS Directive on Open Government (image of a document), the Canada's action Plan on Open Government (image of the figure representing the Canada's action Plan on Open Government) and the Management Accountability Framework (image representing the Management Accountability Framework) help to produce the FINTRACT Open Government Implementation Plan (image of a document). The FINTRACT Open Government Implementation Plan determine the OG Deliverable Commitments.
Based on the OG Deliverable Commitments, the Open Government Working Group (Lead – Information Management Branch) (image of 7 people sitting around a table) draft deliverables and send it to the Chief Information Officer (CIO) for review (image of a person at a computer desk). The revised deliverables are sent to the Corporate Services Committee (CSC) (image of 7 people sitting around a table) and may defer to the Executive Committee (ExCo) (image of 7 people sitting around a table). The approve deliverables are sent to the Information Management Branch (image of a person at a computer desk) who publish the Deliverables on open.canada.ca (screenshot of the website).
6.2 Roles and Responsibilities – Key Stakeholders
| Role | OGIP Responsibilities |
|---|---|
| IM/IT, IM Branch |
|
| Communications Branch |
|
| Access to Information and Privacy Branch |
|
| IT Security Branch |
|
| Legal Services Branch |
|
| All Branches (Information Stewards) |
|
6.3 Communication, Awareness, and Engagement
FINTRAC has started an internal Open Government Working Group to raise awareness about Open Government within the Agency. This working group consists of functional specialists from IM, Access to Information and Privacy, Communications, Security as well as information stewards from the Agency's business areas.
FINTRAC is also working to incorporate elements of Open Government into the Centre's IM awareness program. The Centre's IM awareness program currently consists of:
- Mandatory IM Awareness Training sessions for new staff;
- Ongoing IM Awareness Training sessions for all staff;
- An information portal on our intranet for IM guidance and reference materials;
- IM participation in all projects related to procuring, developing, or modernizing departmental information applications, systems, or solutions.
The IM Awareness sessions and information portal will be augmented with new information specific to Open Government, explaining what it is, why it is important, and the value of Open Government to both the Agency and Canadians.
7. Planning Table
| Ref. | Compliance Requirement | Deliverables / Milestones | Lead | Activities | Start Date | End Date | Resources (Human and Financial) | Status |
|---|---|---|---|---|---|---|---|---|
| DOG 6.1 | Maximizing the release of Government of Canada data and information under an open and unrestrictive licence designated by the Treasury Board of Canada Secretariat | FINTRAC's Data Release Plan | IM/IT Branch | Develop and publish FINTRAC's Data Release Plan (pre-requisite: DOG 6.3 - Data Inventory) | Year 2 (2016) | Year 3 (2016) |
Existing internal resources
|
Not Started |
| FINTRAC's Information Release Plan | IM/IT Branch | Develop and publish FINTRAC's Information Release Plan (pre-requisite: DOG 6.3 - Information Inventory) | Year 3 (2017) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| DOG 6.2 | Ensuring that open data and open information is released in accessible and reusable formats via Government of Canada websites and services designated by the TBS | Listing of accessible and reusable formats (for data and information) to be used at FINTRAC | IM/IT Branch | Develop and publish FINTRAC Open Data and Information Guidelines & Standards | Year 1 (2015) | Year 4 (2018) |
Existing internal resources
|
Not Started |
| Conversion process(es) for data identified for release whose native format is not accessible and reusable | IM/IT Branch | Develop FINTRAC Open Data conversion process(es) | Year 2 (2016) | Year 3 (2016) |
Existing internal resources
|
Not Started | ||
| Conversion process(es) for information identified for release whose native format is not accessible and reusable | IM/IT Branch | Develop FINTRAC Open Information conversion process(es) | Year 3 (2017) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| Release process to support the publication of FINTRAC's data | IM/IT Branch | Review and enhance FINTRAC Open Data release and publication process(es) | Year 2 (2016) | Year 2 (2016) |
Existing internal resources
|
Not Started | ||
| Release process to support the publication of FINTRAC's information | IM/IT Branch | Review and enhance FINTRAC Open Information release and publication process(es) | Year 3 (2017) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| DOG 6.3 | Establishing and maintaining comprehensive inventories of data and information resources of business value held by the department to determine their eligibility and priority, and to plan for their effective release (6.3) | Methodology for establishing a data inventory | IM/IT Branch | Develop FINTRAC open data inventory templates and process(s) | Year 2 (2016) | Year 2 (2016) |
Existing internal resources
|
Not Started |
| Methodology for establishing an information inventory | IM/IT Branch | Develop FINTRAC open information inventory templates and process(s) | Year 3 (2017) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| Data inventory (detailed, itemized list(s) that describe the volume, scope and complexity of the data held by FINTRAC) | IM/IT Branch | Develop FINTRAC Data Inventory | Year 1 (2015) | Year 3 (2017) |
Existing internal resources
|
Not Started | ||
| Information inventory (detailed, itemized list(s) that describe the volume, scope and complexity of the information held by FINTRAC) | IM/IT Branch | Develop FINTRAC Information Inventory | Year 3 (2017) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| Renewal process(es) to maintain the currency of FINTRAC's data inventory | IM/IT Branch | Develop FINTRAC open data inventory - renewal templates and process(s) | Year 2 (2016) | Year 3 (2017) |
Existing internal resources
|
Not Started | ||
| Renewal process(es) to maintain the currency of FINTRAC's information inventory | IM/IT Branch | Develop FINTRAC open information - inventory renewal templates and process(s) | Year 3 (2017) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| Assets included in the data inventory are evaluated to determine their eligibility and priority for release | IM/IT Branch | Develop FINTRAC Data Inventory – release eligibility and prioritization process(es) | Year 2 (2016) | Year 3 (2017) | Existing internal resources
|
Not Started | ||
| Assets included in the information inventory are evaluated to determine their eligibility and priority for release | IM/IT Branch | Develop FINTRAC Information Inventory – release eligibility and prioritization process(es) | Year 3 (2017) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| DOG 6.4 | Developing, posting to the designated website, implementing, and annually updating a departmental Open Government Implementation Plan (OGIP) | Governance structures are in place to oversee the implementation of FINTRAC's OGIP | IM/IT Branch | Plan, develop and implement FINTRAC Open Government Governance | Year 1 (2015) | Year 2 (2016) |
Existing internal resources
|
In Progress |
| FINTRAC's Open Government Implementation Plan (OGIP) | IM/IT Branch | Co-ordinate and manage the development of FINTRAC's OGIP | Year 1 (2015) | Year 1 (2015) |
Existing internal resources
|
In Progress | ||
| Signatures in section 2 (Approvals) of FINTRAC's OGIP | IM/IT Branch | Develop approval process and obtain approval of FINTRAC OGIP | Year 1 (2015) | Year 1 (2015) |
Existing internal resources
|
In Progress | ||
| FINTRAC's OGIP is staffed and funded | IM/IT Branch | Prioritize, staff and fund FINTRAC OGIP activities | Year 1 (2015) | Year 5 (2019) |
Existing internal resources
|
In Progress | ||
| Monitoring and reporting processes for assessing progress and maintaining the currency of the FINTRAC's OGIP | IM/IT Branch | Monitor and report progress on FINTRAC OGIP | Year 1 (2015) | Year 5 (2019) |
Existing internal resources
|
In Progress | ||
| FINTRAC's first annual update to the OGIP | IM/IT Branch | Draft, translate and publish annual updates to FINTRAC's OGIP | Year 2 (2016) | Year 2 (2016) |
Existing internal resources
|
Not Started | ||
| FINTRAC's second annual update to the OGIP | IM/IT Branch | Draft, translate and publish annual updates to FINTRAC's OGIP | Year 3 (2017) | Year 3 (2017) |
Existing internal resources
|
Not Started | ||
| FINTRAC's third annual update to the OGIP | IM/IT Branch | Draft, translate and publish annual updates to FINTRAC's OGIP | Year 4 (2018) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| FINTRAC's fourth annual update to the OGIP | IM/IT Branch | Draft, translate and publish annual updates to FINTRAC's OGIP | Year 5 (2019) | Year 5 (2019) |
Existing internal resources
|
Not Started | ||
| DOG 6.5 | Maximizing the removal of access restrictions on departmental information resources of enduring value prior to transfer to Library and Archives Canada. | Methodology for the removal of access restrictions from data and information resources of enduring value prior to their transfer to the LAC | IM/IT Branch | Develop methodology to assess IREVs and remove access restrictions from IREVs where appropriate prior to transfer to LAC | Year 2 (2016) | Year 3 (2017) |
Existing internal resources
|
Not Started |
| Methodology for the removal of access restrictions from data and information resources of enduring value prior to their transfer to the LAC is integrated into FINTRAC's disposition plans and procedures. | IM/IT Branch | Integrate into FINTRAC disposition processes the methodology to assess IREVs and remove of access restrictions when appropriate prior to transfer to LAC | Year 2 (2016) | Year 3 (2017) |
Existing internal resources
|
Not Started | ||
| DOG 6.6 | Ensuring that open government requirements in sections 6.1 to 6.5 of this directive are integrated in any new plans for procuring, developing, or modernizing departmental information applications, systems, or solutions in support of the delivery of programs and services | Governance structures are in place to ensure that the requirements of the Directive on Open Government are integrated into any new plans for procuring, developing, or modernizing departmental information applications, systems, or solutions | IM/IT Branch | Review and adjust internal governance structures, as required, to integrate Open Government requirements into plans for procuring, developing or modernizing departmental information applications, systems, or solutions. | Year 2 (2016) | Year 2 (2016) |
Existing internal resources
|
Not Started |
| Directive on Open Government requirements are integrated into FINTRAC's procurement process(es) for information applications, systems, and solutions | IM/IT Branch | Integrate Open Government into FINTRAC procurement processes for application, systems and solutions | Year 2 (2016) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| Directive on Open Government requirements are integrated into FINTRAC's development process(es) for information applications, systems, and solutions | IM/IT Branch | Integrate Open Government into FINTRAC development process(es) for application, systems and solutions | Year 2 (2016) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| Directive on Open Government requirements are integrated into FINTRAC's modernizing process(es) for information applications, systems, and solutions | IM/IT Branch | Integrate Open Government into FINTRAC modernization process(es) for application, systems and solutions | Year 2 (2016) | Year 4 (2018) |
Existing internal resources
|
Not Started | ||
| DOG 7.1 | Departmental information management senior officials, as designated by the deputy heads, are responsible for overseeing the implementation and monitoring of this directive in their department. | Performance framework for the monitoring of FINTRAC's progress against the activities and deliverables / milestones in the OGIP | IM/IT Branch | Establish performance framework to monitor FINTRAC's progress against the activities and deliverables / milestones in the OGIP | Year 2 (2016) | Year 3 (2017) |
Existing internal resources
|
Not Started |
| Progress against the activities and deliverables / milestones in the OGIP is regularly reported to the governance structures in place to oversee the implementation | IM/IT Branch | Implement OGIP performance reporting | Year 2 (2016) | Year 5 (2019) |
Existing internal resources
|
Not Started | ||
| Performance framework for the monitoring of FINTRAC's ongoing compliance to the requirements of the Directive | IM/IT Branch | Plan and implement Compliance management | Year 2 (2016) | Year 2 (2016) |
Existing internal resources
|
Not Started | ||
| Process to ensure significant difficulties, gaps in performance, or compliance issues are reported to the Deputy Head (DH) | IM/IT Branch | Implement OGIP performance reporting | Year 2 (2016) | Year 2 (2016) |
Existing internal resources
|
Not Started |