Privacy Act
Canadian Centre for Occupational Health and Safety
Annual Report to Parliament
April 1, 2024 – March 31, 2025

Table of Contents

Introduction

The Canadian Centre for Occupational Health and Safety (CCOHS) is pleased to present to Parliament its annual report on the administration of the Privacy Act for the fiscal year commencing April 1, 2024, ending March 31, 2025.

About the Privacy Act

The purpose of the Privacy Act (the Act) is to protect the privacy of individuals with respect to personal information about them held by a government institution and to provide individuals with a right of access to that information and the right to request the correction of that information.

This report has been prepared in accordance with Section 72 of the Privacy Act. Section 72 of the Act requires that the head of every federal government institution submit an annual report to Parliament on the administration of the Act during the fiscal year. This report outlines CCOHS’ accomplishments in carrying out its privacy responsibilities and obligations during the 2024-25 reporting period.

About the Canadian Centre for Occupational Health and Safety

The Canadian Centre for Occupational Health and Safety (CCOHS) is Canada's trusted source for the advancement of workplace health and safety. Created by Parliament in April 1978, CCOHS promote the right of workers in Canada to a healthy and safe working environment. CCOHS is governed by a tripartite council representing governments (federal, provincial and territorial), employers, and labour. It is a departmental corporation under Schedule II of the Financial Administration Act, and is accountable to Parliament through the Minister of Jobs and Families and Minister responsible for the Federal Economic Development Agency for Northern Ontario. CCOHS is subject to the Access to Information Act and Privacy Act. More information about CCOHS is available on its website.

Privacy Management at CCOHS

As CCOHS is a small department with very few requests, minimal time is spent administering the Act. The President and Chief Executive Officer (PCEO) directly manages all aspects of the Act, supported by the Corporate Secretary.

Under Section 73 of the Privacy Act, institutions within the same ministerial portfolio can work together to process requests. CCOHS was not party to any service agreements with other government departments related to access to information during the reporting period.

Delegation Order

Section 73 of the Privacy Act empowers the head of the institution to delegate any of the powers, duties or functions assigned to them to employees of the institution. During the current reporting period, the responsibilities under the Act were administered by the PCEO. Some responsibilities were delegated to the Corporate Secretary.

A signed and dated copy of the Delegation Order can be found in Annex A.

Performance and Summary of Key Data

This section provides key statistics and analysis on CCOHS’ request processing performance during the 2024-25 fiscal year.

Requests Received and Completed Under the Privacy Act

CCOHS did not receive any requests under the Privacy Act in 2024-25. No records were released, nor were any exemptions or exclusions applied. There were no active requests at the end of 2024-25.

Table 1: Number of requests received and completed

Table 1 shows the total number of requests received and completed, as well as the percentage of requests completed within legislated timelines, for the past five fiscal years.

PRIVACY REQUESTS 2024-25 2023-24 2022-23 2021-22 2020-21
REQUESTS RECEIVED DURING
CURRENT REPORTING PERIOD
0 2 2 3 1
REQUESTS OUTSTANDING
FROM PRIOR PERIODS
0 0 0 1 0
REQUESTS COMPLETED 0 2 2 4 0
REQUESTS CLOSED WITHIN
LEGISLATED TIMELINES
N/A 100% 100% 100% 0%

Exemptions and Exclusions

Canadians have a right of access to their personal information, but the Privacy Act identifies specific exemptions for which the need for confidentiality of certain information is recognized. An exemption is a provision under the Act that authorizes the head of the government institution to not disclose personal information in response to a privacy request.

No exemptions have been invoked during this reporting period.

Consultations Received from Other Government of Canada Institutions and Other Organizations

In 2024-25, CCOHS did not receive any consultation requests from any Government of Canada institution.

Complaints

There were no active complaints at the end of the fiscal year.

Training and Awareness Activities

In 2024-25, CCOHS continued to build on its mandatory training for employees to raise awareness of obligations under the Privacy Act. All managers, leadership team members, and human resources team members were required to complete a mandatory online training course. This course will be mandatory for all new managers and leadership team members in the future.

Policies, Guidelines and Procedures

CCOHS conducted a review of privacy practices, which coincided with the launch of the revised Policy on Privacy Protection and the associated directive. CCOHS made updates to some privacy protocols in order to comply with the new requirements. CCOHS also updated the number of standard Personal Information Banks (PIBs) listed in its statistical report, to correct a previous misstatement where they were labeled as central PIBs rather than standard.

Initiatives and Projects to Improve Privacy

CCOHS has made substantial improvements to its information technology infrastructure and cyber security capabilities. This ensures that personal information is protected from external threats.

Summary of Key Issues and Actions Taken on Complaints

Under the Privacy Act, individuals may lodge complaints to the Office of the Privacy Commissioner (OPC) about the processing of their requests if they were refused access to their personal information or if they feel there was an undue delay. They can also lodge complaints about personal information handling practices, including the collection, use, or disclosure of their personal information.

One complaint was received by the OPC in 2024-25 and was resolved using the OPC’s early resolution process. CCOHS did not receive the details of the complaint, and no action was taken.

Material Privacy Breaches

No material privacy breaches were reported to the Office of the Privacy Commissioner during the current reporting period.

Privacy Impact Assessments

The Policy on Privacy Protection requires that federal government institutions are to develop and maintain privacy impact assessments (PIA) for all new or modified programs and activities that involve the use of personal information for an administrative purpose.

During this reporting period, CCOHS did not initiate any PIAs and, therefore, no assessments were forwarded to the Office of the Privacy Commissioner.

Public Interest Disclosures

In accordance with paragraph 8(2)(a) of the Privacy Act, personal information collected by CCOHS in the course of its programs and activities is being disclosed only for the purpose for which it was collected. During 2024-25, CCOHS did not disclose personal information for any other purposes as outlined in paragraphs 8(2)(b) through (m) inclusively.

Monitoring Compliance

Due to the low volume of requests received, CCOHS does not have an automated tracking system to monitor requests. Instead, a manual record is used to track the progress of each request which is monitored by the PCEO and Corporate Secretary. Monitoring is ongoing as requests are processed.

CCOHS includes standard language in many of its contracts and terms and conditions that highlight the application of the Privacy Act. CCOHS is not part of any information sharing agreements or arrangements in the reporting period.

Annex A: Delegation Order

Access to Information Act and Privacy Act Delegation Order

The President and CEO of the Canadian Centre for Occupational Health and Safety, pursuant to section 73 of the Access to Information Act and section 73 of the Privacy Act, hereby designates the persons holding the positions set out in the schedule hereto, or the persons occupying on an acting basis those positions, to exercise the powers, duties and functions of the Access to Information and Privacy Coordinator of the Canadian Centre for Occupational Health and Safety, 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 Access to Information Act and Regulations Privacy Act and Regulations
Corporate Secretary 4(2.1), 8(1), 9, 11(1-6), 12(2-3), 26, 27, 28(1, 2-4)
Regulations: 6(1), 8
15, 17(2)(b), 17(3)(b)

Dated, at the City of Hamilton, this 7th day of July, 2024

(original signed by)

Anne Tennier P. Eng. EP
President and CEO
Canadian Centre for Occupational Health and Safety