APPENDIX C - List of recommendations by objective, Parks Canada’s comments and action plan, and the Commissioner’s comments

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We are satisfied with the measures and timeframes proposed in Parks Canada’s action plan, except for the response to Recommendation 8, with which we are only partially satisfied. When conducting formal consultations with official language minority communities, Parks Canada must not only address the question of language, but also increase their own awareness of the communities’ specific official languages needs in their capacity as visitors. In addition, the Agency must take these specific needs into account in its delivery of bilingual services. Since the institution plans to give managers training on the DesRochers decision, we believe that this training would be an opportunity to communicate the details and methodology for consultations with language communities.

We would like to thank all Parks Canada employees for their cooperation throughout the audit.

Objective 1

Ensure that Parks Canada senior management is committed to implementing Part IV of the Official Languages Act in order to provide visitors with services of equal quality in both official languages.

 

Recommendation 1

The Commissioner of Official Languages recommends that Parks Canada:

a) develop and implement an accountability framework for official languages that clearly defines all of its obligations. This framework must also include coordination mechanisms and indicate how those responsible in the various field units (and service centres) will be held accountable. The framework must be approved by senior management and effectively communicated to all employees;

b) clarify the role and responsibilities of the National Resourcing Programs Unit and establish a formal network of official languages coordinators, including terms of reference. The information and documentation from the network’s meetings and consultations should be properly archived.

Parks Canada’s comments and action plan

Agree. As the protector and presenter of the Canadian natural and cultural heritage under its guardianship, Parks Canada is in a unique position to promote the principles of English and French duality in Canadian society. Parks Canada is committed to offering the visitors to its national parks, national historic sites and national marine conservation areas services in their official language of choice, as well as to highlighting the bilingual nature of Canada in the presence of international visitors.

As one of the priorities in its 2012–2015 official languages strategic plan, Parks Canada will develop a results-based management and accountability framework (RMAF) for Part IV of the Official Languages Act by the end of fiscal year 2012–2013. This framework, which will be implemented during the fiscal year 2013–2014, will specify the accountability mechanisms and the roles of the managers and employees who provide direct services to the public in the field units and service centres. It will also identify the advisory and monitoring roles of the National Resourcing Programs Unit and describe the coordinating mechanisms which will ensure a consistent implementation of Part IV of the Official Languages Act across the organization. The exact form and nature of these coordinating mechanisms will be determined when developing the RMAF on Part IV of the Official Languages Act over fiscal year 2012–2013.

As with any corporate document, the RMAF will need the approval of Parks Canada’s Executive Management Committee before being implemented.

Commissioner’s comments

We are satisfied with the measures proposed in response to this recommendation.

Recommendation 2

The Commissioner of Official Languages recommends that Parks Canada establish and implement a new official languages action plan that includes specific measures regarding its visitor communications activities so that it can ensure services of equal quality in English and French. This plan must include timeframes, performance indicators and an accountability mechanism. Parks Canada must also establish and implement a monitoring mechanism for the official languages action plan.

Parks Canada’s comments and action plan

Agree in principle. The draft 2011–2014 Parks Canada Official Languages Action Plan, which was reviewed by the auditor last summer, sets out the corporate practices needed to comply with the relevant parts of the Official Languages Act, as well as initiatives to support the official languages program objectives and commitments. It also includes the priorities on which the Parks Canada Agency will focus its efforts during the three-year period covered by the plan. It is a high level strategic document setting the standard of compliance that the whole organization must achieve in order to fulfill its obligations under the different parts of the Official Languages Act, allowing operational units the capacity of undertaking specific actions to ensure expected results are achieved. Initiatives contained in the plan also describe the expected goals or results that operational units must achieve, which relate directly to goals at the corporate strategic level.

To facilitate the operationalization of its strategic corporate objectives regarding official languages, Parks Canada will develop, before September 2012, specific, measurable, attainable, relevant and timely (SMART) goals for inclusion in its 2012–2015 Parks Canada Official Languages Plan to help field units and National Office directorates develop their own operational plans. These SMART goals will also be responsive to the recommendations contained in this audit report and will help to address main issues.

The 2012–2015 Parks Canada Official Languages Plan will specify deadlines and accountability related to most objectives and goals. The accountability and timelines associated with this plan, however, will have to take into account the development and implementation phase of the previously mentioned RMAF for official languages (see response to Recommendation 1). This means that some responsibilities and related objectives will not be identified or confirmed before the completion of the RMAF.

Commissioner’s comments

We are satisfied with the measures proposed for implementing the new official languages action plan (2012–2015). Parks Canada must also follow up annually on the implementation of this plan and take the measures necessary to correct any problems that are identified.

Recommendation 3

The Commissioner of Official Languages recommends that Parks Canada develop an official languages policy that takes its activities and programs into account and includes all of the components of Part IV of the Official Languages Act. This policy must reflect the Agency’s new structure in terms of the visitor experience and refer to the DesRochers decision, particularly the principles related to equal access and services of equal quality. Parks Canada must also develop a communications strategy to effectively communicate the policy to all employees.

Parks Canada’s comments and action plan

Agree. Parks Canada will review, update or adapt its policies, directives and guidelines related to official languages so that they reflect the components of the Treasury Board Secretariat’s new official languages policy instrument. This will be done progressively as these components are made available to the Agency. For the upcoming 2012–2013 fiscal year, Parks Canada will adopt and adapt the following Treasury Board policies and directives related to Part IV of the Official Languages Act:

  • Policy on the Use of Official Languages for Communications with and Services to the Public
    • Directive on the Use of Official Languages on Web Sites

    • Directive on the Use of Official Languages in Electronic Communications

    • Directives for Implementing the Official Languages (Communications with and Services to the Public) Regulations

A plan will be developed for the communication and training of these new policies, directives and guidelines along with the levels of responsibilities identified in the aforementioned RMAF to be developed in 2012–2013. In the meantime, the revised, updated or adapted policies, directives and guidelines will be made accessible immediately to all employees, in both official languages, through the Parks Canada intranet.

Parks Canada has developed a tool to explain the difference between formal and substantive equality to its managers, as well as to help them to identify the circumstances in which they should consult local official language minority communities, as required by the Treasury Board directive issued subsequent to the DesRochers decision. Once this tool is formally approved by Parks Canada’s Chief Human Resources Officer, all managers will be trained to implement and use it accordingly.

Commissioner’s comments

We are satisfied with the measures proposed for developing and implementing a new official languages policy and directives. We commend Parks Canada’s commitment to training managers on the DesRochers decision.

Recommendation 4

The Commissioner of Official Languages recommends that Parks Canada amend its performance management procedures by including a provision on the implementation of Part IV of the Official Languages Act in the performance evaluations of managers, team leaders and any other employees who are required to communicate with the public in both official languages and who negotiate service agreements with third parties.

Parks Canada’s comments and action plan

Partially disagree. Parks Canada recognizes the importance of its official languages obligations, as well as the responsibilities of its managers and of its employees who serve the public. However, its recently redesigned performance management system is not considered the best way or means to address the issue raised by this audit. Parks Canada’s new performance management system follows Treasury Board’s guidelines for managing performance of executives and aligns objectives contained in a manager’s agreement with the main priorities and strategic objectives that the federal government and the Agency are trying to achieve. The Agency is required to obey the numerous laws and regulations to which it is subject. Respect for the law cannot be viewed as a strategic objective—the law must be respected as a matter of course.

Therefore, Parks Canada will ensure that its managers’ and employees’ responsibilities in regard to Part IV of the Official Languages Act are more properly addressed by the RMAF to be developed during the forthcoming fiscal year (see response to Recommendation 1).

Moreover, all Parks Canada managers and employees are required to demonstrate a series of leadership attributes in order to perform in their current roles and functions. It will certainly be more effective and efficient to address any learning needs related to the Official Languages Act, when assessing leadership behaviours and achievements related to applicable laws and regulations. As this type of assessment is conducted on a yearly basis in the course of the performance appraisal process, this will reinforce managers’ and employees’ commitment in regard to their roles and responsibilities under the Official Languages Act.

Commissioner’s comments

We agree with Parks Canada’s statement that the responsibilities of managers and all employees under the Official Languages Act are more appropriately addressed in the RMAF. When setting employees’ and managers’ official languages objectives, Parks Canada must also ensure it takes into account the provisions related to the negotiation of agreements with third parties.

Recommendation 5

The Commissioner of Official Languages recommends that Parks Canada include in its new service agreements, as well as in those that are being renewed, specific language clauses that reflect the provisions of Part IV in order to fully comply with the Official Languages Act.

Parks Canada’s comments and action plan

Agree. Parks Canada acknowledges and understands its official languages obligations and is committed to including a specific official language clause in all new service agreements, as well as in those that are being renewed, with any third party providing services on its behalf.

Commissioner’s comments

We are satisfied with the measures proposed in response to this recommendation.

Objective 2

Ensure that Parks Canada provides the active offer and services of equal quality in English and French to the public at all of its sites. Ensure that the provision of bilingual services is planned effectively.

 

Recommendation 6

The Commissioner of Official Languages recommends that Parks Canada:

a) conduct an in-depth review of the planning for the provision of bilingual services at all national parks, national marine conservation areas and national historic sites, as well as the assignment of interpreters and attendants to Visitor Services, and implement as soon as possible the necessary effective measures to comply with the requirements of the Official Languages Act;

b) review the activities and interpretive programs of all of its field units to ensure that they are available in both official languages. Notices of activities and interpretive programs must indicate the language in which they will be held so that services are of equal quality and members of the public can communicate in the official language of their choice.

Parks Canada’s comments and action plan

Agree in principle. As recommended by the Commissioner, Parks Canada will undertake a comprehensive review of the planning for the provision of bilingual visitor services at all national parks, national marine conservation areas and national historic sites. This will be done during the implementation phase of the aforementioned RMAF and is expected to take place in fiscal year 2013–2014. The review will result in an action plan showing how Parks Canada will proceed to address any noted or observed shortcomings. This action plan will then be implemented during the fiscal year 2014–2015.

As for the availability of activities and interpretive programs in both official languages, Parks Canada will study how the concept of substantive equality may help the Agency to develop innovative means of delivery of its interpretative programs, resulting in a more satisfactory experience for both official language communities. Parks Canada’s goal is to provide members of official language minority communities with the same level of enjoyment as members of the official language majority community. This study will also take place during the implementation phase of the aforementioned RMAF in 2013–2014, and its results will guide Parks Canada’s future decisions in this regard.

Commissioner’s comments

We are satisfied with the measures proposed in response to this recommendation. However, we believe that measures could be implemented sooner, particularly those regarding planning, assignments and the work schedules of Visitor Services attendants and interpreters, in order to provide services of equal quality in English and French.

Recommendation 7

The Commissioner of Official Languages recommends that Parks Canada ensure that employees who are required to communicate with the public have language skills that reflect the realities and requirements of their positions in terms of the Agency’s official languages operational obligations. Moreover, the Agency must conduct an in-depth review of the bilingual skills of all of its employees to verify that there is sufficient capacity to provide services of equal quality in English and French.

Parks Canada’s comments and action plan

Agree. Parks Canada intends to conduct an in-depth review of the linguistic capacity of all its operational units that welcome the public or respond to information requests in person within national parks, national marine conservation areas and national historic sites or by telephone or e-mail. The assessment of the linguistic capacity will take into account all resources to meet these needs in a complete, appropriate, uninterrupted and timely manner, in either English or French. This project will be added to the 2012–2015 Parks Canada Official Languages Strategic Plan.

Commissioner’s comments

We are satisfied with the measures proposed in response to this recommendation.

Objective 3

Ensure that Parks Canada consults representatives of official language minority communities in the various regions and takes the results into consideration when planning for the provision of bilingual services.

 

Recommendation 8

The Commissioner of Official Languages recommends that Parks Canada develop a mechanism for regular and formal consultations of national, provincial and regional representatives of official language communities. He also recommends that Parks Canada take the specific needs of these communities into account when developing its activities, programs and services for visitors.

Parks Canada’s comments and action plan

Agree. Parks Canada intends to continue taking positive measures within its mandate and sphere of jurisdiction to enhance the vitality of the English and French linguistic minority communities, as well as to foster the full recognition and use of both English and French in Canadian society, as required by Part VII of the Official Languages Act. In terms of public consultations, Parks Canada consulted with several official language minority communities and other stakeholders in the context of adapting its programs and services to their needs during the latest renewal process. Many field units also regularly participate in activities organized by official language minority communities not only to better understand their needs, but also to develop or maintain relationships with them.

Parks Canada holds public consultations every five years when developing its management plans. Up until now, consultations did not specifically seek to learn the particular needs of official language minority communities, but Parks Canada will look at the possibility of including the language aspect more specifically in these consultations.

In regard to more frequent consultations with official language minority communities as suggested by the Commissioner, the training of Parks Canada managers in the use of its tool to implement the DesRochers decision will stimulate more regular contacts when new programs and services are developed (see response to Recommendation 3).

Commissioner’s comments

We are partially satisfied with the measures proposed in response to this recommendation. Regarding consultation with representatives of official language minority communities, Parks Canada must not merely look at the possibility of including the language aspect more specifically in the public consultations it holds every five years. The Agency must establish a formal mechanism as quickly as possible for regularly consulting official language minority communities at the national, provincial and regional levels to become aware of their specific activity and programming needs.

Objective 4

Ensure that Parks Canada is effectively monitoring the quality of service delivery in both official languages at all of its service points.

 

Recommendation 9

The Commissioner of Official Languages recommends that Parks Canada establish an evaluation framework for the implementation of Part IV of the Official Languages Act, implement an appropriate monitoring mechanism and evaluate all of its services related to bilingual service delivery as well as those offered by thirdparties. The Agency must take necessary measures in the event of non-compliance.

Parks Canada’s comments and action plan

Agree. In compliance with Treasury Board guidelines for the preparation of results-based management and accountability frameworks, Parks Canada’s RMAF on Part IV of the Official Language Act will include a "monitoring and evaluation plan." The key elements of this monitoring and evaluation plan will be:

  1. A performance measurement plan outlining the overall measurement strategy and identifying performance targets, associated performance indicators and sources of data;

  2. An evaluation plan outlining the overall evaluation strategy and providing a rationale as to why this strategy is proposed.

The monitoring and evaluation plan will be developed by the Recruitment and Retention Branch, responsible for the coordination of official languages programs at Parks Canada, with assistance from and validation by the Office of Internal Audit and Evaluation of Parks Canada. The ultimate goal will be to optimize the Agency’s official languages program related to Part IV of the Official Languages Act, in terms of relevance, effectiveness, efficiency and economy.

Commissioner’s comments

We are satisfied with the measures proposed in response to this recommendation.



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