Audit of Communications Services

November 22, 2024

Internal Audit Branch
Internal Audit and Evaluation Sector

Table of Contents

• Executive Summary
• 1 Statement of Conformance
• 2 Acknowledgement
• 3 Background
• 4 Audit Objective
• 5 Audit Scope
• 6 Audit Approach
• 7 Findings, Recommendations and Management Response and Action Plan
  • 7.1 Organizational Structure Enabling Strategic Planning and Direction
  • 7.2 Operationalizing the Delivery of Services through organizational change
  • 7.3 Performance Management and Continuous Improvement
• 8 Audit Opinion
• Appendix A: Audit Criteria

Executive Summary

Purpose of the Audit

This audit examined the adequacy and effectiveness of the management controls and practices in place to support Justice Canada’s Communications Branch in delivering effective and innovative communications services and advice related to the department’s and Minister’s key priorities.

The Government of Canada’s (GoC) Policy on Communications and Federal Identity and its related directive was implemented in 2016 and modernized the GoC’s communication in several key areas. The Communications Branch underwent a restructuring (in Spring 2023), and the audit focused on the relevant processes, plans and procedures implemented by the Branch to support the restructuring and its expanded role under the Policy.

Key Findings

The Communications Branch is well positioned within the department and has sound representation at the senior management level and with various business partners to receive strategic planning information early and often. However, the Branch needs to clarify roles and responsibilities with their business partners across the department.

The restructuring process lacked key change management constituents, and better workload management and prioritization are needed to support employees and increase service consistency.

Key areas of the Branch had difficulty adjusting to increased workload and handling urgent and time-sensitive requests. At the time of the audit, new hires from the restructuring and forward-planning workload reallocation practices had not alleviated workload pressures for some employees.

Service standards were in place for requests coming from the Minister’s and Deputy Minister’s offices, and media and public enquires. However, these standards did not apply to business partners across the department.

The Communications Branch lacked key performance measurement and reporting practices to demonstrate whether they were meeting their goals and objectives. They were also missing processes to gather feedback from their business partners or to measure the effectiveness of their activities.

Audit Opinion and Conclusion

The Communications Branch has the proper organizational structure, positioning, and levels of access to the departmental information to enable effective communication services. The organizational restructuring of the Communications Branch allowed the Branch to adjust to the growing demands and to support the department in the delivery of key plans and priorities. To further improve the delivery of communication services, there is a need to clarify and establish formalized roles and responsibilities and service standards for the Branch and business partners to set expectations and establish accountability.

The Communications Branch needs to provide the necessary technical training opportunities, materials, guidance, and tools, and look towards prioritization processes for requests to address the growing workload pressures. Implementation of a new Corporate Communications Strategy that includes key performance indicators would enable the Branch to work towards planned objectives and to make informed data-driven decision-making.

Management Response

Management agrees with the audit findings, has accepted the recommendations included in this report, and has developed a management action plan to address them. The management action plan has been integrated in this report.

1 Statement of Conformance

In my professional judgment as Chief Audit and Evaluation Executive, the audit conforms to the International Standards for the Professional Practice of Internal Auditing, as supported by the results of the Quality Assurance and Improvement Program.

Submitted by:

2 Acknowledgement

The Chief Audit and Evaluation Executive would like to thank the audit team and those individuals who contributed to this engagement and particularly, employees who provided insights and comments as part of this audit.

3 Background

Communications are central to the Government of Canada’s (GoC) work and contribute directly to the Canadian public’s trust in their government. The government communicates with the public in both official languages to inform Canadians of policies, programs, services, and initiatives.

In May 2016, the GoC put in place the Communications and Federal Identity Policy (Policy) and the Directive on the Management of Communications (Directive). The Policy and Directive stress the importance of a recognizable federal identity and consistent messaging across departments in both official languages, the need to leverage new technology in tandem with traditional methods of engaging with Canadians, and the importance of collaboration within and across government departments, resulting in timely, accurate, objective, and cost-effective communications that meet the diverse information needs of the public.

The Communications Branch provides services and advice to both its external-facing partners and intra-departmental business partners. The external partners receive support and services such as strategic litigation communications, support on key engagement activities and the management of stakeholder relationships, event coordination for the Deputy Minister’s Office (DMO) and Minister’s Office and more. The intra-departmental business partners receive support and advice that include communications to staff on key initiatives, supporting the integration of communications thematically and strategically within the department, the maintenance of internal communications platforms (e.g. JUSnet) and more. The Communications Branch also responds directly to media and the public through enquires via email and phone. This service engages all Justice Canada’s business partners as necessary to respond within established standards outlined in Justice Service Data and as required under the Government’s Directive on the Management of Communications.

Corporate Communications Strategy

At Justice Canada, the Communications Branch is led by the Director General of Communications, the senior official who reports to and supports the Deputy Minister in managing the department’s communication function.

To reflect expectations and requirements set out by the 2016 Policy and Directive, the Communications Branch developed a Corporate Communications Strategy (2018-2021) (Strategy) to reflect the expectations set out in the new communications Policy and Directive. The Strategy defined the following eleven core responsibilities:

The Strategy also aligned communication activities with key departmental priorities and related strategies as outlined in the departmental Strategic Plan (2017-2022). As laid out, the objectives of the Strategy are to do the following:

1. Educate the public about why the work we do is needed and what outcomes it is aimed at achieving;
2. Support the department’s public and stakeholder engagement to generate informed decisions and solicit views among Canadians and stakeholders on how to achieve these outcomes;
3. Manage issues effectively;
4. Increase awareness of how Government Initiatives are part of the broader outcomes narrative;
5. Sustain the narrative with a focus on the link between related policy, programming and legislative initiatives; and
6. Empower every member of Canada’s Legal Team to own this mission.

Organizational Restructuring in 2023

While implementing the Strategy, the Communications Branch focused on building strategic partnerships and delivering modern and effective communications, in support of the federal government’s ministerial and departmental priorities. To respond to increasing demand, the Communications Branch developed a business case, that included the following four new objectives:

1. Enhancing delivery of professional communications advice through improved workload management;
2. Adjusting to the growing demand for services within the department and with OGDs through a more effective communications function at Justice Canada;
3. Delivering on the Minister’s mandate and the department’s Strategic Plan, providing results for Canadians and supporting Justice Canada’s employees; and
4. Ensuring diversity, inclusion, equity, and accessibility efforts guide communications efforts.

The business case highlighted the need to realign its structure and assignment of file responsibilities, that included:

• Focused support for UN Declaration on the Rights of Indigenous Peoples;
• Regional resources as strategic branch assets;
• Translation;
• Prioritized employee communication efforts; and
• Improved planning and coordination for ministerial and DMO support.

The Communication Branch received additional funding in 2022. The organizational restructuring included the addition of seven new positions and was implemented in spring 2023.

4 Audit Objective

The objective of this audit was to provide assurance on the adequacy and effectiveness of the management controls and practices in place to support Justice Canada’s Communications Branch in delivering effective and innovative communications services and advice related to the department’s and Minister’s key priorities.

5 Audit Scope

The scope for this audit included all relevant management controls and practices supporting Justice Canada’s Communications Branch in delivering effective and innovative communications services and advice related to the department’s key priorities.

As Justice Canada’s Communications Branch underwent a restructuring in spring 2023 to enable it to achieve an expanded role, the audit focused on the relevant processes, plans, and procedures implemented by the Branch to support the restructuring and its expanded role.

The audit covered the period from January 1, 2023 to October 31, 2024. This is the period to which the audit conclusion applies.

6 Audit Approach

This engagement was conducted in accordance with the Treasury Board of Canada Secretariat’s Policy and Directive on Internal Audit, and the Institute of Internal Auditors’ International Standards for the Professional Practice of Internal Auditing. These standards require that the engagement be planned and performed in such a way as to obtain reasonable assurance that the objectives of the engagement were achieved.

7 Findings, Recommendations and Management Response and Action Plan

This section provides the findings and recommendations resulting from the audit work carried out. The audit was conducted based on the lines of enquiry and audit criteria identified during the planning phase, which are presented in Appendix A of this report.

7.1 Organizational Structure Enabling Strategic Planning and Direction

The Communications Branch is well positioned within the department and has sound representation at the senior management level meetings and at various business partners’ meetings to receive strategic planning information early and often. However, there is a need to clarify roles and responsibilities post Branch restructuring, and to develop an accountability framework for internal communications and requests from business partners across Justice Canada.

Organizational position and Branch structure enables the delivery of quality services.

As enablers in the organization, the Communications Branch requires accurate and real-time information at all levels of the department to process and provide quality services and sound advice to its external and internal partners.

During the audit review period, the Communications Branch had sound representation at the committees and meetings throughout the various levels at the department. The Director General, Communications Branch, frequently met with the Deputy Minister (DM), the Associate Deputy Ministers, and the Assistant Deputy Ministers (ADMs) from the different Portfolios and Sectors to obtain high-level information on current departmental priorities, government-wide policies, and ongoing litigation files across the department. Furthermore, communications advisors worked with middle management throughout the organization and participated in the underlying project discussions to situate themselves on specialized information and knowledge, which allowed for strategic communications advice and products. The Branch’s exposure, participation and strategic positioning gave them access to the information they needed to exercise their mandate and in a timely manner.

The Branch’s restructuring aligns with new objectives and goals.

The purpose of the restructuring was to enhance the delivery of communications services, allow for the Branch to adjust to the growing demands, further strengthen its ability to support the Minister’s mandate, and ensure that communications efforts are guided by diversity, equity, and inclusion (DEI), and accessibility. To achieve their goals, the Branch created a new division and new teams that included:

• Public Affairs and Regional Coordination Division;
• Ministerial Liaison and Events Coordination Team; and
• Diversity, Inclusion, Values and Accessibility and United Nations Declaration Act (UNDA) Communications Team.

Together, the new division and teams allowed the Communications Branch to handle all forms of public environment monitoring with an emphasis on analysis of short-term and tracking of social media trends. It established a team that would increasingly centralize and coordinate movement of key planning documents and products requiring MO review and approvals. Additionally, the Branch led on communications sent to staff for key DEI initiatives and UNDA activities.

Roles and Responsibilities between the Branch and its Internal Business Partners need to be clarified.

Working with numerous business partners requires coordination from the Communications Branch to facilitate ongoing discussions on strategic communications. According to business partners, coordination on communications intended for external audiences, such as Parliament, media, and the public, is working well. This is in line with the focus on external partners found in and required under Treasury Board’s Directive on the Management of Communications. However, business partners working with communications teams on products destined for internal audiences lacked understanding of roles and responsibilities sharing between them and the Communications Branch, especially in relation to emergency communiques or messages involving multiple stakeholders. Some business partners assumed that the Communications Branch was responsible for preparing and drafting all internal communiques and products, which is not the case. They were also unsure about the services provided by communications advisors and tasks that could be assigned to them. Further clarity on the roles and responsibilities of communications advisors, but also of the Branch and its internal business partners, would help define expectations and alleviate confusion. It would also help communications advisors better coordinate requests amongst each other, especially when multiple teams are involved and need to work together to create a product. In response to this need, the Communications Branch has taken steps to develop an Internal Emerging Issues/Crisis Communications Framework that clarifies roles and responsibilities as well as approval processes for crises or emerging issues.

At the time of the audit, regions indicated they need more information from the Communications Branch to help ensure that regional internal communiques are consistent with messaging at headquarters. In response, the Communications Branch has recently created a new position, Manager of Regional Communications. This role will help to increase consistency of communications advice across all Regional offices. In addition, at the time of the audit report, the Director General of the Communications Branch had just initiated a new practice of holding monthly meetings with the ADM of Management Sector to institute a planning exercise for internal employee communications.

Recommendation # 1

The Director General, Communications Branch, should formally document and communicate roles and responsibilities between the Communications Branch and Justice Canada’s business partners, to set clear expectations for all business partners. This could include, but is not limited to, developing an accountability framework to ensure consistency of regional messaging with headquarters and help stakeholders work together.

7.2 Operationalizing the Delivery of Services through organizational change

In 2022, the Communications Branch sought and received additional funding to help it progress towards delivering on its Strategy.

After funding was approved, the Branch established new objectives to guide its work. It created seven additional positions and was also restructured into four divisions, each containing multiple teams as follows:

• The Director General’s Office;
• The Public Affairs and Regional Coordination Division;
• The Corporate, Consultations, and Policy Communications Division; and
• The Employee Communications, Digital, Creative and Language Services Division.

The objective of the new structure was to help the Branch deliver its services effectively by, for example, improving workload management; centralizing and coordinating all products requiring approval from the Minister’s and Deputy Ministers offices; and taking the lead on all departmental communications on key DEI and UNDA activities.

The Branch’s restructuring process lacked key change management constituents to mobilize and support employees.

When important organizational changes and restructuring occur, change management is key to prepare, equip and support individuals to successfully adopt change in order to drive success and outcomes. This was particularly critical for the Communications Branch, given the commitments made when receiving additional funding. Prosci’s ADKAR Change Management model suggests that organizations “plan for significant time and effort needed to develop the required knowledge”; to provide effective training programs as well as job aids such as templates, checklists, coaching, user groups and forums; and to fill in knowledge gaps. Although not all change management practices and actions necessarily apply to every organizational change, the audit examined whether employees were provided with the time, support, resources, learning opportunities and tools necessary to adapt to the restructuring.

At the time of the audit, the Branch’s new structure had been in place for less than six months, which the audit team acknowledged as being a short time frame for the Branch to execute all change implementation steps. However, the audit expected to find evidence of basic change management practices important to the success of restructuring. Measuring the impacts or success of the restructuring was not within the objective or scope of this audit. Key elements needed to facilitate the restructuring following a period of crises, such as the COVID-19 pandemic and the strike by members of the Public Service Alliance of Canada in 2023, were missing. Employees in new or acting manager positions lacked management training and, in some cases, had little to no management experience. Some teams lacked standard operating procedures to guide their work. New teams did receive a high-level description of their roles during a divisional meeting that took place before the restructuring, but the document did not provide details of job-specific roles and responsibilities. It is worth noting that for most employees within the Branch, their day-to-day responsibilities and the nature of their work did not change under the restructuring.

To obtain support with its restructuring and expansion, and following regular and ongoing discussions with managers, the Communications Branch engaged Justice Canada’s Business Transformation (BT) and Change Management (CM) teams. One change management session was held in February 2023, prior to the initial restructuring date of April 1st, 2023, and a second and last session was held in June 2023. The CM team recommended holding special sessions with the executive cadre only, but these did not take place. On the CM team’s recommendation, the Branch then worked with the BT team, meeting with them and sharing key information about the restructuring prior to holding two sessions with managers in September 2023, which was more than five months following the restructuring.

A lack of sufficient change management practices or constituents can sometimes lead to adverse consequences. It can impact employees in the exercise of their roles and responsibilities, create confusion and misunderstanding around the restructuring’s purpose and objectives, and impair the restructuring’s success. These sentiments were echoed in interviews held with employees between October 2023 and January 2024, particularly those who had felt their roles and responsibilities shifted under the restructuring.

To address restructuring challenges, at the time of the audit report, the Director General’s office invested in important efforts to improve collaboration and consultation with managers and employees and to foster transparency and open communications. They took steps to address gaps related to knowledge, training, as well as to develop clearer job-specific roles and responsibilities. A staffing process allowed the Branch to staff five new managers in IS-06 positions, and to establish a new management team. A Communications Management workshop was held with the new management team in September 2024, to work on building their relational infrastructure. One of the objectives of the workshop was specifically focused on change management. The first workshop was well received by the management team. Participants commented positively on themes related to collaboration and open discussions. A follow-up session is scheduled for January 2025. A new practice of bi-weekly management meetings was also introduced by the Director General’s office to help the management team work together and to involve managers in organizational solutions and decision making. These activities demonstrate that the Branch has resumed change management practices.

Better workload management and prioritization is needed to support employees and increase service consistency.

One of the goals of the restructuring was to enhance the Branch’s delivery of professional communications advice through improved workload management.

At the time of the audit, some areas of the Branch were still having difficulty adjusting to and handling urgent and time-sensitive requests. Formalized frameworks or guidelines to help employees prioritize requests, manage competing priorities and balance workload pressures had yet to be developed. Most requests from the Minister’s Office were labeled as “urgent” regardless of the nature of the request, resulting in a de-prioritization of requests from other sectors. This practice resulted in some business partners not receiving internal communications services in a timely manner or being denied these services and inconsistencies in the range of services received. This impact was most felt when internal communications needs from Justice Canada’s business partners required support from the Digital Communications team (for graphic design, videography and Web coding services), and that unit prioritized Ministerial requests. One business partner reported having to acquire and develop their own communications expertise within their work division.

During the audit review period, some teams developed measures to alleviate workload pressures, such as the option for managers to redistribute workload from one employee to another, or from one team to another. For example, one division was also implementing an on-call system where one employee works for the weekend on behalf of the team. Although these initiatives were helpful, they were informal and varied from team to team. Furthermore, there was no standardized process to manage urgent requests, where most of the workload issues occur. Analysis of overtime trends from April 2020 to November 2023 showed that overtime tends to be heavier in the last quarter of the fiscal year. Despite the new hires from the restructuring, workload pressures remained and indirectly increased with employee departures and staff turnover.

High and persistent workload pressures should be addressed as they can create a staff retention risk. They can also represent a risk to the health and wellness of employees, and lead to increased absenteeism and burnout. Ultimately, these pressures could affect the Branch’s ability to carry out its mandate and successfully implement its restructuring.

In response to these workload pressures, the Branch began to implement a task management system that uses computer software to track requests and is expected to improve its current workload allocation process. The Branch also has some forward planning practices in place. Effective forward planning takes into consideration opportunities for growth, maximizing time and resources, as well accounting for uncertainties and potential setbacks. Current practices include a Branch-wide calendar, regional litigation trackers, and regular meetings between the Director General, Communications Branch, and the department’s ADMs. Dedicated communications advisors are present for business partners and provide reviews of internal communications, coordinate approvals and support them in external consultations. At the time of the audit report, these practices were in their early stages of implementation or integration, and it was too early to assess their impact on the reallocation of workload or alleviating workload pressures.

Service Standards for business partners were not developed consistently.

Effective service standards are essential to service management excellence. They help clarify expectations for business partners and employees, enable performance management, help manage workloads, and support client satisfaction.

Justice Canada’s Communications Branch had service standards in place for requests coming from the Minister’s and Deputy Minister’s offices. These included timelines for tasks related to requests such as ministerial events and announcements, news releases, and social media posts. These standards, however, were not applicable to other business partners across the department. That said, other business partners reported that service timelines could still be provided informally when services were requested. Formal service standards could help the Branch ensure more consistency and clarify expectations with all business partners, particularly those seeking internal communications advice and services.

The Communication Branch recognized that although communications can at times be unpredictable, there is a need to better clarify expectations on communication products with their business partners, and has undertaken steps to improve planning, workflow and approval processes. These steps were still at an early stage in April 2024.

Recommendation # 2

The Director General, Communications Branch, should explore options that will help ensure consistency in services provided to their business partners and optimize workload management. Options can include but are not limited to:

• Developing service standards for all business partners and types of requests;
• Defining prioritization criteria for non-urgent requests;
• Creating forward planning processes that account for all types of service requests from all business partners; and,
• Implementing procedures to alleviate and redistribute high workloads.

7.3 Performance Management and Continuous Improvement

The Branch Did Not Report on the Corporate Communications Strategy Results.

The Strategy set out goals and objectives for the Branch until 2021. It illustrates high-level action items, but does not include expected timelines for completion, or information on how it will be monitored or what success will look like. The Strategy was not included in the list of departmental Strategies, Plans, Policies and Frameworks linked to Justice Canada’s Strategic Plan 2022-2027 and therefore not reported on the department’s Strategic Plan.

After 2021, the Branch stated internal goals and objectives related to its expansion and restructuring, but did not include these in a new, formal strategic document. During the period of this audit, the Branch did some informal reporting to the Privy Council Office and the Deputy Minister’s Office, but overall did not report on the Branch’s success, or on whether it had met its goals and objectives since its expansion and restructuring. Interviews with senior management confirmed that the Branch had not reported on the results of the Strategy.

There Were No Processes in Place to Measure Performance.

The Branch gathered data from analytics platforms that collect information related to social media channels, media coverage and media engagement. Monthly reports were shared across the Branch from the social media team. The Branch also monitored the completion of tasks with deadlines and a task management system was being implemented. Although data collection was occurring, the Branch was not collaborating with departmental business partners to further enhance its capabilities for data collection and reporting. Furthermore, the Branch does not have enough employees with the knowledge needed to analyze and leverage the information gathered, which would help assess the effectiveness of the Branch’s activities and identify and resolve issues as they occur.

There were no formal mechanisms in place to obtain feedback from the Branch’s business partners on the services they obtained. Instead, the Branch relied on interactions with its business partners to assess their satisfaction. For example, there were bi-weekly meetings between the Director General, Communications Branch, and the Deputy Minister’s office that allowed for feedback to be provided. Feedback from other clients was also obtained informally through emails and verbal discussions that take place after a service was delivered. Interviews with the Branch’s business partners mostly expressed satisfaction with the quality and timeliness of the services they were provided.

Recommendation # 3

The Director General, Communications Branch, should develop a new Corporate Communications Strategy that includes updated objectives to reflect the Branch’s expanded role, an action plan, performance measures, and reporting commitments. Mechanisms to collect performance information could include, but are not limited to, a formalized process to gather feedback from business partners.

8 Audit Opinion

The Communications Branch has the proper organizational structure, positioning, and proper levels of access to the departmental information to enable effective communication services. With the new organizational restructuring of the Communications Branch, the new division and teams allowed the Branch to adjust to the growing demands and to support the department in the delivery of key plans and priorities. To further improve the delivery of communication services, there is a need to clarify and establish formalized roles and responsibilities and service standards for the Branch and business partners to set expectations and establish accountability. The Communications Branch should provide employees with additional training opportunities, materials, guidance, and tools. It should also look towards prioritization processes for requests to address the growing workload pressures. Implementation of a new Corporate Communications Strategy that includes key performance indicators would help to enable the Branch to work towards planned objectives and to make informed data-driven decision-making.

Appendix A: Audit Criteria

Line of enquiry 1: Organizational Design to Set Strategic Direction

1. The Communications Branch is appropriately positioned within the department to deliver on its expanded role and new objectives, which enables strategic planning and direction.

   1.1 The Communications Branch’s position within Justice Canada’s organizational structure enables it to deliver on its expanded role and new objectives.

   1.2 The Communications Branch’s recent restructuring of its teams was defined, communicated, and enables it to deliver on its expanded role and new objectives.

   1.3 The Communications Branch’s planning processes enables strategic planning and direction, which guide the Branch’s communication services and advice, to be aligned with Justice Canada’s Strategic Plan and the Branch’s expanded role and new objectives.

Line of enquiry 2: Operationalizing the Delivery of Communication Services

2. The Communications Branch provides quality services and advice that meet the expectations of its clients and leverages best practices to manage the Branch’s workload as well as support its employees (i.e., change management, training, etc.).

   2.1 The Communications Branch has established service standards that are communicated and monitored to support the delivery and improvement of communication services and advice (e.g. litigation and other media relations, public inquiries, Public Opinion Research, etc.).

   2.2 The Communications Branch, following its restructuring, provides its departmental clients (i.e., Portfolios and Sectors) with the services and advice required to support them in achieving their goals and objectives.

   2.3 The Communications Branch adopts practices to mobilize and support its employees to fulfill their assigned roles and responsibilities.

   2.4 The Communications Branch has workload management processes or practices in place that support the organization, prioritization, and management, of the Branch’s workload for its employees.

Line of enquiry 3: Performance Management to Inform Decision Making

3. The Communications Branch has performance management practices in place to support data-driven decision making and incorporates best practices to remain current with emerging trends that enable continuous improvement.

   3.1 The Communications Branch has performance measures and mechanisms in place to monitor and assess its success (relative to the Strategy and the Branch’s new expanded role and objectives) and further uses this information to inform its decision-making processes.

   3.2 The Communications Branch integrates and leverages internal data sources to further support its data-driven decision making.

   3.3 The Communications Branch identifies best practices (e.g., benchmarks and industry trends, etc.) to remain current with emerging trends that enable continuous improvement.