Annual Report on the Privacy Act 2014-2015

Table of Contents

Introduction

The Privacy Act (the Act) came into force on July 1, 1983. The purpose of the Act is to protect the privacy of individuals with respect to personal information about themselves held by government institutions and to provide individuals with a right of access to that information.

The Public Prosecution Services of Canada (PPSC) became subject to the Act when it was established as an independent organization on December 12, 2006, with the coming into force of the Director of Public Prosecutions Act (Part 3 of the Federal Accountability Act).

Pursuant to section 72 of the Act, the PPSC has prepared this 2014–2015 Annual Report on the Privacy Act for tabling in the House of Commons and the Senate. This Report provides an analysis of the information contained in the PPSC’s Statistical Report on the Privacy Act. In addition, it reports on emerging trends, training activities and newly implemented or revised internal policies, guidelines and procedures with respect to the PPSC’s administration of the Act.

Mandate of the Public Prosecution Service of Canada

The PPSC’s mandate is set out in the Director of Public Prosecutions Act (DPPA). The DPPA empowers the Director of Public Prosecutions (DPP) as Deputy Attorney General of Canada to:

The DPPA also empowers the DPP to:

The DPP has the rank and status of a deputy head of a department, and in this capacity is responsible for the management of the PPSC as a distinct governmental organization.

Commissioner of Canada Elections

The Commissioner of Canada Elections (CCE) is responsible for ensuring that the Canada Elections Act and the Referendum Act are complied with and enforced. On October 1, 2014, following passage of Bill C-23, An Act to amend the Canada Elections Act and other Acts and to make consequential amendments to certain Acts, the Office of the CCE was transferred from Elections Canada to the PPSC. As a result, the CCE reports to the DPP, but remains operationally independent.

As of October 1, 2014, all privacy requests and consultations regarding the Office of the CCE are processed by the PPSC’s Access to Information and Privacy Office. Any requests prior to this date would have been processed by Elections Canada.

Access to Information and Privacy (ATIP) Office

The ATIP Office holds primary responsibility for the implementation and administration of the Act. The Office deals directly with the public in relation to privacy requests, liaises with its points of contact to prepare responses, and serves as the centre of expertise for ATIP within the PPSC.

The ATIP Office carries out its responsibilities by:

Organization Structure

Organizational Chart of Access to Information and Privacy Governance Structure
[Text version]

As of March 31, 2014, the ATIP Office is comprised of a Manager, a Senior Analyst, two Advisors and one Junior Analyst. The Executive Director and Senior Counsel, Ministerial and External Relations Secretariat, serves as the organization’s ATIP Coordinator. Counsel for the Ministerial and External Relations Secretariat serves as ATIP Counsel and provides legal advice to the ATIP Coordinator, the ATIP Office and PPSC managers on the application and interpretation of the Act and relevant case law.

Delegated Authorities

Pursuant to section 73 of the Act, the head of a government institution may, by order, designate one or more officers or employees of that institution to exercise or perform any of the powers, duties of function of the head of the institution under the Act.

The DPP, as the “head of institution”, has designated the authority to exercise the powers and to perform the duties and functions conferred to him under the Act to the Executive Director and Senior Counsel, Ministerial and External Relations Secretariat, and the ATIP Manager (see Delegation Order in Appendix A). The ATIP Manager exercises this authority in the absence of the Executive Director and Senior Counsel.

Interpretation of the Statistical Report

The following section provides a summary and analysis of the information contained in the Statistical Report on the Privacy Act located in Appendix B of this report. It also compares statistical data from 2014–2015 with data from previous reporting periods in order to identify possible trends.

Part 1 – Requests Under the Privacy Act

The PPSC received 11 requests for personal information in 2014–2015, which represents a 48% decrease in the number of requests received from the previous reporting period. In addition, three (3) requests were carried forward from fiscal year 2013–2014.

This is the first time since the 2010–2011 reporting period that there has been a decrease in the number of privacy requests received. Although the number of requests fluctuated in the early years since the creation of the PPSC, it had been steadily increasing since 2010–2011, reaching an all-time high of 21 during the last fiscal year.

Part 2 – Requests Closed During the Reporting Period

Disposition of requests

The PPSC responded to 12 requests for personal information during the 2014–2015 reporting period. A total of 2,634 pages were reviewed, which represents a 24% decrease in volume from the previous reporting period. Two (2) outstanding requests for personal information were carried over to the next reporting period.

The 12 completed requests can be categorized as follows:

Percentage of the Disposition of Requests
All disclosed (3) Disclosed in part (7) No records exist (2)
25% 58% 17%
No Records Exist

The PPSC’s disclosure rates in 2014–2015 were significantly higher than the average over the previous five (5) years. The PPSC responded to a total of 78 requests for personal information between fiscal years 2010–2011 to 2014–2015. In 63% of cases, the PPSC responded by releasing information in whole or in part. During 2014–2015, full or partial disclosure of the information requested was provided in 83% of cases.

Completion time

The chart below provides a breakdown of the length of time (in days) required to process requests for personal information during the 2014–2015 reporting period.

Percentage of requests by completion time
1 to 15 days (2) 16 to 30 days (7) 31 to 60 days (1) 61 to 120 days (1) more than 365 days (1)
17% 59% 8% 8% 8%

Of the 12 requests that were completed during fiscal year 2014–2015, nine (9) were processed within the 30-day statutory response period. Two (2) requests were responded to within 31 to 120 days, and one (1) request required more than 365 days to complete.

Over the last five (5) reporting periods, 57% of the PPSC’s requests for personal information were responded to within the 30-day statutory deadline.

Exemptions

An individual’s right of access to his or her personal information is subject to limited and specific exceptions. Limitations to the right of access are set out in sections 18 through 28 of the Act.

The following is a breakdown of the exemptions that were invoked by the PPSC during the 2014–2015 reporting period.

Exemptions that were invoked by the PPSC during the 2014-2015 reporting period
paragraph 22(1)(b) paragraph 22(1)(c) Section 26 Section 27
1 1 7 4

Exclusions

Records or parts thereof to which the Act does not apply are considered to be “excluded”. Pursuant to section 69, the Act does not apply to library or museum material preserved solely for public record, and material placed in Library and Archives Canada. Records containing Confidences of the Queen's Privy Council for Canada that have been in existence for less than 20 years are also excluded from the Act pursuant to section 70.

During the 2014–2015 reporting period, no exclusions pursuant to sections 69 and 70 of the Act were applied by the PPSC.

Format of information released

For responses in which information was disclosed, the information was provided to the applicant electronically by e-mail or on a compact disk in 30% of cases. Paper copies of records were provided in 70% of cases.

Complexity

The mandate of the PPSC is to prosecute offences under federal jurisdiction and to provide advice on prosecution-related matters to investigative agencies. Due to the nature of the organization’s work, processing privacy requests is challenging. Records held by the PPSC often contain information relating to criminal or regulatory investigations or prosecutions that also frequently involve other organizations and government departments at the federal, provincial or territorial level.

During the 2014–2015 reporting period, the PPSC consulted with other government institutions on two (2) particularly complex requests. Legal advice was sought in order to respond to one (1) request. Five (5) requests were also considered complex due to the personal information of another individual being intermixed with the information of the applicant.

Deemed refusals

The PPSC was in deemed refusal on two (2) occasions during the 2014–2015 reporting period due to the large volume of records that required processing. On one (1) such occasion, the PPSC took a 30-day extension; however, the organization was unable to complete the processing of the request within the 60-day time period.

Requests for translation

One (1) request for translation was received by the PPSC. The organization granted the applicant’s request to have the records translated from French to English.

Part 3 – Disclosures under Subsection 8(2) and 8(5)

Subsection 8(2) of the Act describes the circumstances under which personal information under the control of a government institution may be disclosed without the consent of the individual to whom the information pertains.

There were no disclosures made to federal investigative bodies for the purpose of enforcing any law of Canada or a province, or for carrying out a lawful investigation [paragraph 8(2)(e)] in fiscal year 2014–2015, nor were any disclosures made in the public interest [paragraph 8(2)(m)].

Part 4 – Requests for Correction of Personal Information and Notations

Paragraph 12(2)(a) of the Act provides that every individual who is given access to personal information about themselves that has been used, is being used, or is available for use for an administrative purpose (i.e. in a decision making process that directly affects the individual) is entitled to request correction of the information where the individual believes there is an error or omission.

There were no requests for correction of personal information nor were notations required during this reporting period.

Part 5 – Extensions

Paragraph 15(a) of the Act allows for an extension of the 30-day statutory time limit for a maximum of 30 days in cases where meeting the original time limit would unreasonably interfere with the operations of the institution processing the request, or when consultations with other government institutions are necessary and cannot reasonably be completed within the original time limit.

Reason for extensions

A total of three (3) extensions were taken during the 2014–2015 reporting period. In one (1) instance, the extension was sought on the basis that meeting the original time limit would unreasonably interfere with the operations of the PPSC. On two (2) other occasions, consultations were necessary to comply with the request and could not be completed within the 30-day statutory time limit.

Length of extensions

Of the three (3) extensions taken during the reporting period, one (1) was for a duration of 16 to 30 days. The remaining two (2) instances, required extensions of 15 or less days.

Part 6 – Consultations Received from Other Institutions and Organizations

Number of consultations

The PPSC received seven (7) privacy consultations in 2014–2015, which represents a 46% decrease in the number of consultations received during the previous reporting period. This decrease in consultations can be attributed in part to the Treasury Board Secretariat’s decision to remove the mandatory requirement of government institutions to consult the PPSC prior to exempting information on the basis of solicitor-client privilege pursuant to section 27 of the Act.

Sources of consultations

The Royal Canadian Mounted Police (RCMP) sent four (4) consultations, while the Canada Border Services Agency (CBSA), the Canadian Food Inspection Agency (CFIA) and the Nova Scotia Justice Canada each sent one (1).

Percentage of consultations by other government institutions
RCMP (4) CFIA (1) CBSA (1) Nova Scotia DoJ (1)
58% 14% 14% 14%

Recommendations

The PPSC responded to seven (7) consultations during the 2014–2015 reporting period. A total of 316 pages were reviewed, representing a 2% decrease in volume from the previous fiscal year.

Recommendations made by the PPSC in respect of completed consultations during the reporting period can be broken down as follows:

Percentage of the completed consultations
Disclosed entirely (2) Disclosed in part (4) Consult other institution (1)
29% 57% 14%

The PPSC’s disclosure rates in 2014–2015 are consistent with the average rate over the five (5) previous years. The PPSC processed 68 consultations from fiscal years 2010–2011 to 2014–2015. In 85% of cases, the PPSC recommended that information be released in whole or in part. During 2014–2015, full or partial disclosure of information was recommended in 86% of cases.

Completion time

Of the seven (7) consultations that were completed, three (3) were responded to within 15 days or less. The four (4) remaining consultations required between 16 to 30 days to complete.

Over the last five (5) reporting periods, more than three quarters of privacy consultations received by the PPSC were responded to within 30 days. From 2010–2011 to 2014–2015, 57% of consultations completed were processed in 15 days or less while an additional 22% were completed within 16 to 30 days.

Part 7 – Completion Time of Consultations on Cabinet Confidences

No consultations on the application of section 70 [Cabinet confidences] of the Act were carried out during the 2014–2015 reporting period.

Part 8 – Complaints and Investigations Notices Received

Complaints

Decisions made under the Act are subject to a two-tiered system of review. The first level of review is a formal complaint to the Office of the Privacy Commissioner of Canada (OPC); the second level is an application for judicial review to the Federal Court.

No complaints were filed with the OPC against the PPSC during the 2014–2015 reporting period; however, two (2) exemption complaints were carried forward from previous reporting periods. The OPC has yet to issue its finding in either case.

Federal Court review

During this reporting period, no application for judicial review was filed with the Federal Court pursuant to section 41 of the Act with respect to privacy requests submitted to the PPSC.

Part 9 – Privacy Impact Assessments (PIAs)

A Privacy Impact Assessment (PIA) is a tool used to assist an organization to meet its privacy responsibilities with regard to the management of personal information. PIAs are initiated when assessing the privacy implications of new or substantially modified programs and activities involving personal information.

During this reporting period, a PIA with respect to the PPSC’s proposal to outsource to a private collection agency a portion of the collection work being handled by the National Fine Recovery Program (NFRP) was completed by the PPSC and provided to the OPC.

An executive summary of the PIA is available on the PPSC website at: http://www.ppsc-sppc.gc.ca/eng/tra/pia-efp/nfrp-pnra.html.

Part 10 – Resources Related to the Privacy Act

During this reporting period, the PPSC spent a total of $191,222 administering the Act of which salaries accounted for $178,383 and Goods and Services accounted for $12,839. There were no overtime expenditures.

Training Activities

During this reporting period, the ATIP Office provided a training and awareness session regarding the PPSC’s processes and employee obligations under the Act to approximately ten (10) employees of the PPSC’s Alberta Regional Office. An information session regarding the PPSC’s privacy policies was also provided to the organization’s business coordinators.

In addition, ATIP personnel provided informal training to employees on various privacy-related matters on an ad hoc basis.

New or Revised Policies, Guidelines and Procedures

In 2014–2015, the PPSC developed a Privacy Management Framework which will serve as a primary resource for employees and agents of the PPSC seeking information regarding the organization’s privacy management practices. The Framework sets out the PPSC’s organizational practices to ensure compliance with the Act, including the distribution of responsibilities, coordination of privacy work and management of privacy risks.

Monitoring of Processing Time

The ATIP Office maintains a comprehensive statistical reporting and performance measurement system. Monthly reports are provided to the ATIP Coordinator identifying the number of active privacy requests, the sources and due dates of the requests, as well as the length of any extensions taken.

Information relating to the processing time of requests for correction of personal information is included in the monthly reports.

Privacy Breaches

A material privacy breach involves improper or unauthorized collection, use, disclosure, retention or disposal of sensitive personal information which could reasonably be expected to cause serious injury or harm to the individual to whom it relates.

The Office of the Privacy Commissioner and the Treasury Board Secretariat were notified that two (2) material breaches had occurred during the 2014–2015 reporting period.

One (1) breach resulted from the mail-out of Statement 1 income tax forms in connection with the Barreau du Québec fees paid by the PPSC for applicable employees. Due to the type of envelope used and the formatting of the Statement 1 forms, the social insurance number of the intended recipients were inadvertently displayed in the address window of the shipping envelope. The PPSC made available to affected employees the use of a protection service to monitor credit activity. Employees were also advised to remain vigilant about suspicious activity and to check their credit reports and any other financial account statements periodically.

The other breach resulted from an unvetted Information to Obtain (ITO) a search warrant being inadvertently located in a defense counsel’s file. The ITO contained information that could potentially lead to the identification of a confidential informant. Upon being notified of the incident, the PPSC recovered the the document and advised the law enforcement agency involved.

Appendix A – Delegation Order

The Director of Public Prosecutions, pursuant to section 73 of the Access to Information Act and the Privacy Act, hereby designates the persons holding the positions set out in the schedule hereto, or the persons occupying on acting basis those positions, to exercise the powers and functions of the Director as the head of a government institution.

Schedule

Position Privacy Act and Regulations Access to Information Act and Regulations
Executive Director and Senior Counsel, Ministerial and External Relations Secretariat Full Authority Full Authority
Manager, ATIP, Access to Information and Privacy Office Full Authority Full Authority

Dated, at the City of Ottawa, this 11 day of January, 2010.

Signature of Brian Saunders
Brian Saunders
Director of Public Prosecutions

Appendix B – Statistical Report on the Privacy Act

Name of institution: Public Prosecution Service of Canada

Reporting period: 2014-04-01 to 2015-03-31

Part 1: Requests Under the Privacy Act

  Number of Requests
Received during reporting period 11
Oustanding from previous reporting period 3
Total 14
Closed during reporting period 12
Carried over to next reporting period 2

Part 2: Requests Closed During the Reporting Period

2.1 Disposition and completion time

Disposition of requests Completion Time
1 to 15 Days 16 to 30 Days 31 to 60 Days 61 to 120 Days 121 to 180 Days 181 to 365 Days More than 365 Days Total
All disclosed 1 2 0 0 0 0 0 3
Disclosed in part 0 4 1 1 0 0 1 7
All exempted 0 0 0 0 0 0 0 0
All excluded 0 0 0 0 0 0 0 0
No records exist 1 1 0 0 0 0 0 2
Request abandoned 0 0 0 0 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0 0 0 0
Total 2 7 1 1 0 0 1 12

2.2 Exemptions

Section Number of Requests
18(2) 0
19(1)(a) 0
19(1)(b) 0
19(1)(c) 0
19(1)(d) 0
19(1)(e) 0
19(1)(f) 0
20 0
21 0
22(1)(a)(i) 0
22(1)(a)(ii) 0
22(1)(a)(iii) 0
22(1)(b) 1
22(1)(c) 1
22(2) 0
22.1 0
22.2 0
22.3 0
23(a) 0
23(b) 0
24(a) 0
24(b) 0
25 0
26 7
27 4
28 0

2.3 Exclusions

Section Number of Requests
69(1)(a) 0
69(1)(b) 0
69.1 0
70(1)(a) 0
70(1)(b) 0
70(1)(c) 0
70(1)(d) 0
70(1)(e) 0
70(1)(f) 0
70.1 0

2.4 Format of information released

Disposition Paper Electronic Other Formats
All disclosed 3 0 0
Disclosed in part 4 3 0
Total 7 3 0

2.5 Complexity

2.5.1 Relevant pages processed and disclosed
Disposition of Requests Number of Pages Processed Number of Pages Disclosed Number of Requests
All disclosed 53 53 3
Disclosed in part 2581 1710 7
All exempted 0 0 0
All excluded 0 0 0
Request abandoned 0 0 0
Neither confirmed nor denied 0 0 0
Total 2634 1763 10
2.5.2 Relevant pages processed and disclosed by size of requests
Disposition Less than 100 Pages Processed 101-500 Pages Processed 501-1000 Pages Processed 1001-5000 Pages Processed More than 5000 Pages Processed
Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed
All disclosed 3 53 0 0 0 0 0 0 0 0
Disclosed in part 2 87 4 493 0 0 1 1130 0 0
All exempted 0 0 0 0 0 0 0 0 0 0
All excluded 0 0 0 0 0 0 0 0 0 0
Request abandoned 0 0 0 0 0 0 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0 0 0 0 0 0
Total 5 140 4 493 0 0 1 1130 0 0
2.5.3 Other Complexities
Disposition Consultation Required Legal Advice Sought Interwoven Information Other Total
All disclosed 0 0 0 0 0
Disclosed in part 2 1 5 0 8
All exempted 0 0 0 0 0
All excluded 0 0 0 0 0
Request abandoned 0 0 0 0 0
Neither confirmed nor denied 0 0 0 0 0
Total 2 1 5 0 8

2.6 Deemed refusals

2.6.1 Reasons for not meeting statutory deadline
Number of Requests Closed Past the Statutory Deadline Principal Reason
Workload External Consultation Internal Consultation Other
2 2 0 0 0
2.6.2 Number of days past deadline
Number of Days Past Deadline Number of Requests Past Deadline Where No Extension WasTaken Number of Requests Past Deadline Where An Extension Was Taken Total
1 to 15 days 0 0 0
16 to 30 days 1 0 1
31 to 60 days 0 0 0
61 to 120 days 0 0 0
121 to 180 days 0 0 0
181 to 365 days 0 1 1
More than 365 days 0 0 0
Total 1 1 2

2.7 Requests for translation

Translation Requests Accepted Refused Total
English to French 0 0 0
French to English 1 0 1
Total 1 0 1

Part 3: Disclosures Under Subsection 8(2) and 8(5)

Paragraph 8(2)(e) Paragraph 8(2)(m) Subsection 8(5) Total
0 0 0 0

Part 4: Requests for Correction of Personal Information and Notations

Disposition for Correction Requests Received Number
Notations attached 0
Requests for correction accepted 0
Total 0

Part 5: Extensions

5.1 Reasons for extensions and disposition of requests

Disposition of Requests Where an Extension Was Taken 15(1)(a) Interference With Operations 15(1)(b) Consultation 15(1)(c) Translation or Conversion
Section 70 Other
All disclosed 0 0 0 0
Disclosed in part 1 0 2 0
All exempted 0 0 0 0
All excluded 0 0 0 0
No records exist 0 0 0 0
Request abandoned 0 0 0 0
Total 1 0 2 0

5.2 Length of extensions

Length of Extensions 15(1)(a) Interference with operations 15(1)(b) Consultation 15(1)(c) Translation purposes
Section 70 Other
1 to 15 days 1 0 1 0
16 to 30 days 0 0 1 0
Total 1 0 2 0

Part 6: Consultations Received From Other Institutions and Organizations

6.1 Consultations received from other Government of Canada institutions and other organizations

Consultations Other Government of Canada Institutions Number of Pages to Review Other Organizations Number of Pages to Review
Received during reporting period 6 309 1 7
Outstanding from the previous reporting period 0 0 0 0
Total 6 309 1 7
Closed during the reporting period 6 309 1 7
Pending at the end of the reporting period 0 0 0 0

6.2 Recommendations and completion time for consultations received from other Government of Canada institutions

Recommendation Number of Days Required to Complete Consultation Requests
1 to 15 Days 16 to 30 Days 31 to 60 Days 61 to 120 Days 121 to 180 Days 181 to 365 Days More than 365 Days Total
All disclosed 1 0 0 0 0 0 0 1
Disclosed in part 1 3 0 0 0 0 0 4
All exempted 0 0 0 0 0 0 0 0
All excluded 0 0 0 0 0 0 0 0
Consult other institution 0 1 0 0 0 0 0 1
Other 0 0 0 0 0 0 0 0
Total 2 4 0 0 0 0 0 6

6.3 Recommendations and completion time for consultations received from other organizations

Recommendation Number of Days Required to Complete Consultation Requests
1 to 15 Days 16 to 30 Days 31 to 60 Days 61 to 120 Days 121 to 180 Days 181 to 365 Days More than 365 Days Total
All disclosed 1 0 0 0 0 0 0 1
Disclosed in part 0 0 0 0 0 0 0 0
All exempted 0 0 0 0 0 0 0 0
All excluded 0 0 0 0 0 0 0 0
Consult other institution 0 0 0 0 0 0 0 0
Other 0 0 0 0 0 0 0 0
Total 1 0 0 0 0 0 0 1

Part 7: Completion Time of Consultations on Cabinet Confidences

7.1 Requests with Legal Services

Number of Days Fewer than 100 Pages Processed 101-500 Pages Processed 501-1000 Pages Processed 1001-5000 Pages Processed More than 5000 Pages Processed
Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed
Total 0 0 0 0 0 0 0 0 0 0
1 to 15 0 0 0 0 0 0 0 0 0 0
16 to 30 0 0 0 0 0 0 0 0 0 0
31 to 60 0 0 0 0 0 0 0 0 0 0
61 to 120 0 0 0 0 0 0 0 0 0 0
121 to 180 0 0 0 0 0 0 0 0 0 0
181 to 365 0 0 0 0 0 0 0 0 0 0
More than 365 0 0 0 0 0 0 0 0 0 0

7.2 Requests with Privy Council Office

Number of Days Fewer than 100 Pages Processed 101-500 Pages Processed 501-1000 Pages Processed 1001-5000 Pages Processed More than 5000 Pages Processed
Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed Number of Requests Pages Disclosed
Total 0 0 0 0 0 0 0 0 0 0
1 to 15 0 0 0 0 0 0 0 0 0 0
16 to 30 0 0 0 0 0 0 0 0 0 0
31 to 60 0 0 0 0 0 0 0 0 0 0
61 to 120 0 0 0 0 0 0 0 0 0 0
121 to 180 0 0 0 0 0 0 0 0 0 0
181 to 365 0 0 0 0 0 0 0 0 0 0
More than 365 0 0 0 0 0 0 0 0 0 0

Part 8: Complaints and Investigation Notices Received

Section 31 Section 33 Section 35 Court action Total
0 1 0 0 1

Part 9: Privacy Impact Assessments (PIAs)

Number of PIA(s) completed 1

Part 10: Resources Related to the Privacy Act

10.1 Costs

Expenditures Amount
Salaries $178,383
Overtime $0
Goods and Services $12,839
• Professional services contracts $8,885  
• Other $3,954
Total $191,222

10.2 Human Resources

Resources Person Years Dedicated to Privacy Activities
Full-time employees 2.34
Part-time and casual employees 0.00
Regional staff 0.00
Consultants and agency personnel 0.05
Students 0.00
Total 2.39

Note: Enter values to two decimal places.

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