Government Information Policy
CARL/ABRC Response to the draft Management of Government Information Policy:
July 20, 2001
Mme. Francine Frappier
Project Officer
Information Policy Division
Chief Information Officer Branch
Treasury Board Secretariat
Consultation on the Draft Management of Government Information Policy
Dear Mme Frappier:
Thank you for the opportunity to comment on the above document, posted on the Treasury Board website at: http://www.cio-dpi.gc.ca/ip-pi/pols/draft-ebauche1_e.asp .
The following comments are made on behalf of the Board and members of the Canadian Association of Research Libraries/Association des bibliothèques de recherche du Canada (CARL/ABRC).
CARL/ABRC was established in 1976 and comprises Canada's twenty-seven major academic libraries, the National Library of Canada/Bibliothèque nationale du Canada, and the Canada Institute of Scientific and Technical Information /Institut canadien de l'information scientifique et technique (CISTI/ICIST).
CARL/ABRC represents the major research libraries in Canada, so it may lay claim to speak on behalf of the thousands of Canadian scholars, researchers and students in all disciplines who need timely access to comprehensive, accurate information. The combined holdings of the member libraries form the largest and the most comprehensive library resource for study and research in Canada in all fields.
In this context, access to government information for research purposes is central to the mission of serving the research community.
Additional information on CARL/ABRC may be found on the Association's webpage: www.carl-abrc.ca
Critique of the Consultation on the Draft Management of Government Information Policy
- CARL/ABRC compliments the authors of the Consultation Paper for addressing the wider questions of scope, access, preservation, public policy and accountability rather than focusing narrowly on the implementation of a records management regime. We support the following statements made in the Paper and offer comments and recommendations where applicable.
Preface
"Information is a valuable resource and the government is a unique repository of information that must be managed as a public trust on behalf Canadians."
- the draft Access to Information (ATI) Review Consultation Paper states that the ATI Task Force is "...looking at how to modernize access to government information in a way that promotes open and effective government and an informed citizenry in a knowledge society." CARL/ABRC will hope and expect practical implementation of these goals in the Management of Government Information (MGI) policy.
he primary objective of the government Depository Services Program (DSP)
"...is to ensure that Canadians have ready and equal access to federal government information. The DSP achieves this objective by supplying theses materials to a network of more that 790 libraries in Canada and to another 147 institutions around the world holding collections of Canadian government publications." See: http://dsp-psd.pwgsc.gc.ca/dsp-psd/AboutDSP/profile-e.html
- CARL/ABRC recommends MGI adopt as part of its mandate a commitment to strengthen the role of the DSP, developing its role in the Government Online agenda, and ensuring its legal status.
Policy Statement
b) "It is the policy of the government of Canada to.....manage information regardless of medium or format in a manner that is secure and retains its authenticity and integrity for as long as it is required." (sic)
- CARL/ABRC recommends the MGI team address the practical problem of defining at what point(s) anelectronic document becomes 'fixed.' This is true of frequently updated statistical information as well as different recensions of a text.
Application
- Whilst appreciating that strictly speaking this lies outside the mandate of the MGI initiative, CARL/ABRC recommends that the same principles and practices governing the MGI be adopted in the management of Parliamentary publications.
Policy Requirements: 1. Governance
"The leadership required to achieve the objectives of this policy is provided through the government lead agencies' collaboration; namely the Treasury Board of Canada Secretariat, the National Archives of Canada and the National Library of Canada."
- CARL/ABRC is pleased to note that the National Archives of Canada and the National Library of Canada (a CARL/ABRC member) are designated as 'government lead agencies.' Since both are experts in information handling as they fulfil their respective mandates, it is entirely appropriate that they bring their expertise to the MGI.
Policy Requirements: 2. Managing Government Information
- CARL/ABRC finds that this section is well researched, well presented and identifies all major issues: we will expect that the implementation match the stated aspirations
2.3 "Additional Considerations Related to Electronic Media'. to support this commitment, government institutions must:...... d) apply accountabilities and control mechanisms to ensure the authenticity of electronic information by keeping an audit trail of additions, modifications, deletions and the conversion and migration to new systems media and software in the context of continuous changes and decentralized information sources. "
- CARL/ABRC fully appreciates the importance of hardware/software conversion/migration for long-term information handling. For research purposes the integrity and authenticity of the document is critical and it may prove necessary to preserve the "outdated"texts.
Accountability
9. National Library of Canada
- As noted, CARL/ABRC is pleased that the National Library is designated a lead institution for the MGI.
"Under the National Library Act ....all newly published information in various formats from federal departments and agencies must be deposited with the National Library of Canada."
- CARL/ABRC asks that the MGI initiative use its best efforts to ensure compliance with the above.
- CARL/ABRC recommends that legal deposit of publications as stipulated by the National Library Act, be extended to all applicable publications in electronic format.
ITEMS NOT COVERED BY THE DRAFT MGI POLICY
- CARL/ABRC recommends that the MGI policy re-examine the principles and exercise of Crown Copyright, especially as this relates to charges levied against the user. The public policy aspect of these recommendations relates to Section 2.2, Maintaining the Public Trust.
- CARL/ABRC recommends re-examining the practice of user-fees as levied by various government departments and agencies; assessing the limited amount of revenue derived versus the great harm done to university teaching and research.
- CARL/ABRC recommends that MGI management liaise with other organizations or initiatives working in the same field with a view to exchanging ideas and best practices. One such example is the Data Archives project, currently under development by the National Archives and the Social Sciences and Humanities Research Council (SSHRC).
The Board and members of CARL/ABRC wish the members of the MGI policy team a successful outcome to their deliberations.
Yours sincerely,
(signed)
William Maes
President, CARL/ABRC
