EMPLOYEE DEPARTURE PROCESS AUDIT OVERALL - · PDF fileEMPLOYEE DEPARTURE PROCESS AUDIT OVERALL CONCLUSION ... • consider the use of system-generated log-on screen displays to remind

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At the time the Terms of Reference for the audit were developed it was known that the department didnot have a policy or process for employee departures. The emphasis of our work was therefore shifted tosubstantiate that information and assets were protected at time of departure and that the departmentwas complying with policies.

EMPLOYEE DEPARTURE PROCESS AUDIT

OVERALL CONCLUSION

Fails to meet basic requirements/established standards and/or objectives.

Lack of a corporate approach and undefined roles, responsibilities and accountability, has led toorganizations initiating their own processes, none of which fully comply with TBS policies. Thishas resulted in an abundance of disparate procedures that are inadequate in recovering assets andprotecting information when employees leave the department. While attempts are made to recoverassets, little is done to ensure continued confidentiality of sensitive information.

In most cases where managers are taking the initiative to recover assets, the information at theirdisposal is unreliable or there is no information available.

The development and implementation of a comprehensive Employee Departure Policy, integratedprocess and associated management control framework is critically required.

1. AUDIT OBJECTIVE CONCLUSIONS

1.1 The overall lack of corporate focus, accountability and awareness is resulting in severaldisparate processes to recover and protect information and assets when employees leave thedepartment, none of which adequately address requirements of Treasury Board Secretariat(TBS) policies.

1.2 While several policies reference various aspects of employee departure, these policies havenot been incorporated into a comprehensive departmental employee departure policy orprocess. Furthermore, the existing policies are not consistently followed.

2. MAIN POINTS

2.1 During the course of their employment, employees are normally given access to electronictools and systems. This access is provided through such things as LAN, email and systemuser accounts. Deactivation of user accounts at the time of departure is an important step toensure the proper safeguarding of departmental information. The Control Objectives forInformation and related Technology (COBIT) stipulate that management should establishprocedures to ensure timely action relating to suspending and closing of user accounts. We

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expected all user accounts to be disabled immediately on or before an employee’s departuredate. In most cases we found that user access is not disabled in a timely manner leaving thedepartment vulnerable to unauthorized access.

2.2 During the course of their employment at AAFC employees are also provided with materialresources to help discharge their responsibilities. When employees leave the department,TBS policy requires the recovery of those material resources. We expected to find processesto maintain, monitor, report assets allocated to employees and recover them uponemployment termination. We found recovery processes and asset inventories inadequate toprovide management with reasonable assurance that all assets were recovered. We noted thatdeparture processes differ between regions, and to some extent, within regions. It wasevident that managers have varying degrees of knowledge of the required employeedeparture controls.

2.3 Upon employment most employees are provided with security assets such as identification(ID) cards and associated access control cards or keys. The TBS Personnel Security Standardrequires that “departments must establish policies and procedures for dealing with thetermination of employment that ensures a timely and complete separation.” The policies andprocedures should, among other things, incorporate “The revocation of all authorities andreclamation of property (e.g. identification badges, access authorities, keys and locks) ondeparture or, when appropriate, on giving notice of departure.” We expected immediaterecovery and deactivation of ID and access control cards. In most cases we foundcancellation of ID and access control cards is not being performed in a timely manner,leaving departmental premises vulnerable to unauthorized access.

2.4 To minimize the possibility of an employee leaving the Public Service owing money or anyother material, the TBS Comptrollership Policy on Pay Administration has guidelines fordeparture processes. The guidelines recommend that final payment be released to employeesonly when the department has ensured there is no money owed to the crown. We thereforeexpected to see processes in place that would exercise authority under section 33 of the FAAto hold back final payments if necessary. No such processes are in place. As a result, thedepartment is not respecting the requirements of TBS Account Verification Policy andexercising appropriate authority under Section 33 of the FAA.

2.5 Departure practices are typically considered for employees permanently leaving thedepartment. However, there are various short-term leaves of absence that should also beconsidered in the development of appropriate policies and procedures. We expecteddepartmental policies and processes to reflect the TBS Leave Without Pay Policy requiringmanagers to inform employees about “The importance of exercising caution in their actionswhile on leave in terms of political partisanship, conflict of interest and criticism ofgovernment policy, as such actions may jeopardize either their status as a public servantwhile on leave or their return to the Public Service upon the termination of the leave.”Managers were generally unaware of this requirement. In addition, we found that departureprocesses are inconsistently followed for short-term departures. We also noted cases whereemployee access to information, security access and users accounts remained intact for theduration of their leave.

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2.6 The TBS Personnel Security Standard requires that departments must “establish policies andprocedures for dealing with the termination of employment that ensures a timely andcomplete separation.” The policies and procedures should cover a “formal debriefing toremind individuals of their continuing responsibilities relating to the confidentiality of thesensitive information to which they have had access in the course of their employment.” Wetherefore expected that the department would have policies and procedures developed andimplemented to address this requirement. There are no policies, procedures or formallyassigned responsibility for security debriefings of departing employees.

2.7 When leaving the Public Service, the Conflict of Interest and Post-Employment Policy statesthat “The deputy head as designated official must ensure that employees are informed of therequirements of the Conflict or Interest and Post-Employment Code and that they complywith all its requirements” In addition, the policy states that the department must “conductexit interviews with employees subject to the post-employment compliance measures beforethey leave the Public Service or review with employees their responsibility in this regard.”We therefore expected to find processes and procedures developed and implemented toaddress these requirements. We found no processes or evidence of this being done.Managers were generally unaware of this policy or their responsibility to undertake postemployment activities with departing employees.

2.8 The AAFC Exit Survey Program Policy states that “...departing employees be given anopportunity to indicate their reason(s) for leaving, to express their views on their workingexperience as well as offer suggestions on improving working conditions.” We expected thatemployees would be made aware of the policy and that information would be collected asrequired. Managers were generally unaware of this policy and HR was not consistentlycollecting the information and providing required reports.

RECOMMENDATIONS:

The department should:• Develop a comprehensive Employee Departure Policy and integrated process, specifically

defining the respective roles, responsibilities and accountability of Human Resources, Finance,Assets, IST, Security, departmental managers and employees. The policy and process shouldensure:• deactivation of user accounts done on or before the employee’s departure date

• include policy statements clearly prohibiting the removal of departmental files orinformation by departing employees

• consider the use of system-generated log-on screen displays to remind employees thatinformation is the property of the employer and is not to be copied or removed

• consideration should be given to assigning responsibility for deactivating systemaccounts to a central point of contact (i.e. Helpdesk)

• where required for operational reasons, an employee’s email should be backed up to thesystem for continued access to information not stored on the network after deactivation

• the recovery of material assets and cancellation of associated accounts and contracts• the immediate deactivation and recovery of all security identification, access cards and keys

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• use an appropriate security reporting system to centrally monitor departed employees andthe deactivation of employee access

• final salary payment is released only when money or any other material owing to the crownhas been recovered

• a formal debriefing is conducted with employees to remind them of their continuingresponsibilities relating to the confidentiality of the sensitive information to which they havehad access in the course of their employment

• conflict of interest and post-employment activities are conducted with employees• departing employee are provided the opportunity to participate in an exit interview and

complete the “Questionnaire for Departing Employees”• short and long-term departures are defined and that departure guidelines exist for these

departures or leave situations• Consider assigning accountability for the employee departure process to Human Resources

• best practice information indicates that in most organizations responsibility andaccountability for employee departures rests with Human Resources

• Develop associated standard tools, documentation standards and reporting requirements• see appendix B• regional requirements should be considered when developing tools

• Communicate roles and responsibilities to all employees and managers• Expand the use of inventory systems to track all assets by employee, including assets under

$10,000, i.e. cellular phones and other hand-held devices, etc.

The Human Resources Team should:• Provide managers with the necessary training about the policy and its requirements

• Develop a kit or talking points for managers to use for communicating to departingemployees on all policy requirements

• Monitor compliance to the new Employee Departure Policy and integrated process• Collect survey results

• Data should be used to compile statistical information and prepare periodic reports formanagement

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3. OBJECTIVES

The objectives of the Employee Departure Process Audit were to:

• Assess the effectiveness of departure processes used to recover and protect information andassets when employees leave the department.

• Assess departure processes for compliance with departmental policies, Treasury Boardrequirements, laws and other governmental agency requirements.

4. SCOPE AND APPROACH

The scope included the following elements in the areas of security, human resources, finance,assets, IM/IT and legal as they relate to employee departures:• Management framework• Processes and sub-processes of termination (corporate, teams and branches)• Roles, responsibilities and accountability• Performance reporting• Controls and risk management

The methodology used in conducting the audit was based on federal government guidelinespertaining to the termination of employees and best practices, including:• Risk assessment;• Documentation and process review;• Research (including best practices review);• Interviews;• Sampling and Testing;• Sampling Period: April 1, 2001 to March 31, 2002 inclusive; and• Analysis.

The audit included sampling from all regions. PeopleSoft records were utilized to determine thenumber of employees leaving the department on an annual basis; this served as the basis for makinga selection of employee records for testing. The following table indicates departures by region andcategory.

April 01, 2001 to March 31, 2002

Category/Region Alberta Atlantic BC Mid West NCROntario Quebec TotalVoluntary Departures 32 18 13 184 141 19 23 430Involuntary Departures 1 1 1 6 3 2 14End of term 95 131 61 912 197 117 87 1600Death 1 1 3 5 Total 128 151 75 1103 344 136 112 2049

A random sample of approximately 5% of the number of departures identified in PeopleSoft for thereporting period April 1, 2001 to March 31, 2002 from all regions was utilized. As well, an

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additional judgmental sample of 1% was selected for testing. The judgmental sample was based onthe auditor’s review of the termination profiles and selecting departures that seemed atypical. Intotal, 118 cases were selected as illustrated in the following table.

Category/Region Alberta Atlantic BC Mid West NCR Ontario Quebec TotalVoluntary Departures 11 7 4 17 10 8 5 62Involuntary Departures 1 1 1 6 3 2 14End of Term 2 3 3 13 9 4 4 38Death 1 1 1 3Leave Without Pay 1 1Total 14 12 8 37 24 12 11 118

The audit approach consisted of:

• Identification of key stakeholders and review of background material and relevant policies. • Development of an audit program and data collections:

• Interviews with senior management, project sponsors and regional HR leaders;• Review of employee personnel files;• Questionnaires and interviews with employee managers, LAN managers, security officers;

and• Follow up with administrative assistants, HR and payroll personnel.

• Report based on results of testing and interviews.

To ensure the audit considered practices which may not have been identified from file review andtests, random managers in each region were interviewed separately to obtain their understanding ofdepartmental practices and requirements. These practices were grouped to the extent possible andmapped for each region interviewed. Appendix A contains process flow charts for commonprocesses identified across the department and differences by region.

The internal audit was conducted in accordance with both the Treasury Board Policy on InternalAudit and the Institute of Internal Auditors Standards for the Professional Practice of InternalAuditing. The audit was carried out from November 2002 to April 2003.

5. BACKGROUND

With the proliferation of personal electronic devices (i.e. blackberrys, cell phones), the renewedfocus on security and the growing mobility of employee, there is a pressing need to assure theprotection of government information and material resources when personnel leave anyorganization. Ensuring comprehensive policies are in place and monitored as well as making surethat managers and supervisors follow set guidelines and carefully document both departures andresignations is imperative. A properly developed and implemented employee departure process notonly acts as a security measure, it can actually provide valuable insights to improve an organization.

It is important to set the context of the current practices within the department. Shortly before thisaudit was initiated the department operated 6 regions as follows:

• Western Region (B.C. & Alberta);

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• Prairie Region (Saskatchewan & Manitoba);• Ontario Region (Ontario, excluding NCR);• National Capital Region (NCR);• Quebec Region; and • Maritimes Region.

In the case of the employee departure process, each of the regions operated different processes, in somecases, we noted variations within regions. At the time of the audit, the department had undergone asignificant reorganization whereby certain functions were reorganized into teams and consolidated centrally.As part of the consolidation exercise certain projects were initiated to develop corporate processes wherethere were none in place. One project undertaken was to develop a departmental checklist to help carry outemployee departure requirements. During the audit we endeavored to identify improvements to thechecklist, which are documented and presented in Appendix B.

6. DETAILED FINDINGS

6.1 During the course of their employment employees are normally given access toelectronic tools and systems. This access is provided through such things as LAN,email and system user accounts. Deactivation of user accounts at the time of departureis an important step to ensure the proper safeguarding of departmental information.The Control Objectives for Information and related Technology (COBIT) stipulatethat management should establish procedures to ensure timely action relating tosuspending and closing of user accounts. We expected all user accounts to be disabledimmediately on, or before, an employee’s departure date. In most cases we found thatuser access is not disabled in a timely manner leaving the department vulnerable tounauthorized access.

Most employees are given LAN and email accounts upon employment. Depending on specificrequirements of the position, employees may also be given access to corporate systems (i.e.SATURN, the Correspondence Tracking and Briefing System and PeopleSoft) and team/branchsystems (i.e. Research Study Management System SMS). This access can vary from ‘read only’ tofull access including read, write and delete. There are also employees, depending on specificposition requirements, with access allowing them to modify code or change network and systemconfigurations.

The Control Objectives for Information and related Technology (COBIT) specifically stipulates thatmanagement should establish procedures to ensure timely action relating to suspending and closingof user accounts. The AAFC Electronic Mail Policy states that managers/supervisors are responsibleto ensure the e-mail accounts of employees leaving the Department are disabled or deleted on theirlast day of employment and ensure that all non-transitory records are retained.”

The deactivation of user accounts at the time of departure is an important step to ensure the propersafeguarding of departmental information and assets. Therefore, we expected the department tohave implemented appropriate safeguards related to LAN, email and system accounts and access.

In almost all of the 118 cases selected for the sample we found that user access is not immediately

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disabled leaving the department vulnerable to unauthorized access. Although supportingdocumentation about deactivation of accounts was not consistently available or complete, wherethere was information it substantiated that user accounts were not deactivated immediately on orbefore departure dates.

We found no standard policy or approach to the deactivation of user accounts. The significantdifferences observed during the audit suggest that LAN and system managers are not provided withthe information required to fulfill deactivation requirements. In other cases, information is availablebut deactivation processes and protocols are left to the discretion of individual LAN and systemmanagers. Specifically we noted:• LAN and system managers are not regularly informed of departing employees and therefore

accounts remain open for a considerable period subsequent to employee departure dates.• In some cases managers told us they did not know whom to contact for deactivation

of accounts.• LAN managers give deactivation varying degrees of priority from weeks to months after an

employee has left.• LAN and system managers rely on less reliable means of identifying departed employees,

such as monitoring for lengthy periods of inactivity or from lack of personal contact withemployee.

• Accounts left open by user or manager requests:• Employees wanting email access intact so email can be forwarded to new location or

to access departmental information that the employee may not have filed.• Managers want access to departed employees email accounts to review and respond

to email as required.

This situation is compounded by the fact that at the present time the department has no coordinationof the various systems groups to ensure that departing employee access is removed from all systems.In addition we found that some systems allow web-based access, enabling usage to continue evenafter the deactivation of an employee’s LAN account. In the case of Saturn, accounts are onlylocked after periods of inactivity with the account continuing to remain active for periods of up tothree months after the employee had left the department.

This lack of ‘deactivation’ control leaves the department vulnerable to unauthorized access ofsystems and / or networks through active accounts of former employees.

6.2 During the course of their employment at AAFC employees are also provided withmaterial resources to help discharge their responsibilities. When employees leave thedepartment, TBS policy requires the recovery of those material resources. We expectedto find processes to maintain, monitor, report assets allocated to employees andrecover them upon employment termination. We found recovery processes and assetinventories inadequate to provide management with reasonable assurance that allassets were recovered. We noted that departure processes differ between regions, andto some extent, within regions. It was evident that managers have varying degrees ofknowledge of the required employee departure controls.

In recent years the material assets distributed to employees has changed significantly. Employees

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are now entrusted with a variety of tools including, laptops, printers, modems, cell phones, PDA’s,blackberry’s, acquisition cards, research equipment, calling cards, etc. The Materiel ManagementPolicy states that “Managers should maintain a record of the materiel used by employees offpremises, and the materiel should be accounted for as if it were still held on government premises.Managers should ensure that all the Crown's legal obligations are respected (e.g. softwarelicences). The materiel is always Crown property; when it is no longer being used for work-relatedduties, managers are responsible for its recovery.” Therefore we expected processes to be in placeto track and recover these material assets.

Typically individual assets allocated to employees are less than $10,000 and are not required to betracked and monitored if the associated tracking cost is greater than the cost of the asset. We foundthat assets are inconsistently tracked and monitored by branches and teams. While managers ordesignated individuals are taking steps to retrieve material assets when employees leave thedepartment, we found that they may not have the necessary up-to-date inventory to ensure that allassets are recovered. This situation is compounded by the recent consolidation exercise thatidentified ownership for team assets but no accountability for asset tracking.

While we found that some organizations maintain an inventory of assets (in varying formats, i.e.BassetPro, spreadsheet, etc.) the responsibility for ongoing tracking of the assets is not regularlydefined and communicated, increasing the risk that the inventory will not be maintained.

We noted multiple and inconsistent procedures for recovering assets from departing employees. Inmost cases the procedure amounted to the use of a checklist. These checklists varied in usage andcompleteness. Although the majority of the sample population did not complete a checklist, wenoted the following on the checklists examined:• Twenty year old checklist that did not include any modern technology assets.• Checklists only used for external staff and not for indeterminate employees. • Checklists were not fully and adequately completed; • The responsibility for ensuring the checklist was completed also varies; managers, HR, a

designated individual such as an administrative officer or a security officer. • No consistent approach to collection, retention and filing of completed checklists.

We found organizations with no checklist or procedures but where managers stated that aninterview is conducted to establish whether all assets had been returned from the departingemployee.

While most managers stated they believed that all departmental assets had been recovered, theinconsistent processes, inefficient practices and lack of documentation provide no assurance thatassets are consistently recovered at the time of employee departure.

6.3 Upon employment most employees are provided with security assets such asidentification (ID) cards and associated access control cards or keys. The TBSPersonnel Security Standard requires that “departments must establish policies andprocedures for dealing with the termination of employment that ensures a timely andcomplete separation.” The policies and procedures should, among other things,incorporate “The revocation of all authorities and reclamation of property (e.g.

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identification badges, access authorities, keys and locks) on departure or, whenappropriate, on giving notice of departure.” We expected immediate recovery anddeactivation of ID and access control cards. In most cases we found cancellation of IDand access control cards is not being performed in a timely manner, leavingdepartmental premises vulnerable to unauthorized access.

For the most part employees are provided identification (ID) cards, magnetic swipe access controlcards or metal keys to access departmental facilities. The TBS Personnel Security Standard whichrequires that “departments must establish policies and procedures for dealing with the terminationof employment that ensures a timely and complete separation.” The policies and procedures should,among other things, incorporate “The revocation of all authorities and reclamation of property (e.g.identification badges, access authorities, keys and locks) on departure or, when appropriate, ongiving notice of departure.”

There are no consistent security processes from region to region to ensure access cards aredeactivated at the time of employee departure nor are security personnel regularly informed of anemployee’s departure. Some security personnel informed us they that use a standalone application totrack employee access granted, however it is a common practice to delete the employee’s recordaltogether resulting in a complete loss of information on former employees. Where information wason file to support termination dates there were a significant number of terminations that wereperformed after the departure date, in some cases deactivation was up to six months after theemployee left the department. In numerous instances we were unable to quantify the severity of thisfinding as records were not adequate and security personnel could not provide us with the date whencancellations were performed.

6.4 To minimize the possibility of an employee leaving the Public Service owing money orany other material, the TBS Comptrollership Policy on Pay Administration hasguidelines for departure processes. The guidelines recommend that final payment bereleased to employees only when the department has ensured there is no money owedto the crown. We therefore expected to see processes in place that would exerciseauthority under section 33 of the FAA to hold back final payments if necessary. Nosuch processes are in place. As a result, the department is not respecting therequirements of TBS Account Verification Policy and exercising appropriate authorityunder Section 33 of the FAA.

The TBS Comptrollership Policy on Pay Administration guidelines for departure processes state,“To minimize the possibility of an employee leaving the federal Public Service owing money or anyother material (e.g. outstanding accountable advances such as travel advances, standing advances,emergency salary advances, petty cash funds, change floats, etc.; acquisition cards; travel cards;identity cards; overdrawn leave; and equipment, tools, manuals, etc. on loan), departments shouldestablish a departure report and checklist that would require specific organizations such as humanresources, security, materiel management, administration, library and financial services to sign offbefore the final payment to the employee is released.”

The policy guideline further states “Financial organizations should always sign off last to ensurethat all other areas have been cleared and that no money is owed to her Majesty: only then should

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the final payment be released. If authority under section 33 of the FAA has been delegated outsidethe line authority of the senior financial officer, the organizations to which that authority has beendelegated should be the last to sign off.”

We expected to see controls and processes in place that respected these TBS guidelines andprovided assurance that financial officers are exercising authority under section 33 of the FAA tohold back final salary payments if necessary. Standard processes, reports or checklists, to assist inrecording assets allocated to employees and to facilitate relinquishing these assets prior to employeedeparture, do not exist. While some organizations had developed their own process or checklist,none included the requirement for section 33 authority to be the final sign off, nor did they havecontrols in place to hold back final payment.

Financial Officers with delegated payment authority, pursuant to Section 33 of the FAA, and asrequired by the TBS Account Verification Policy, are responsible for ensuring that all payments,including final salary payments, are verified and certified pursuant to section 34 of the FAA. Assuch, on a daily basis, Financial Officers in each region (Winnipeg, Ottawa and Montreal) accessthe On-Line Pay system and approve pay transactions in bulk. Financial officers carry out thisapproval without documentation to substantiate the accuracy of final payments and confirmationthat departing employees are not owing money or any other material to the crown.

Our examination of employee pay files in the NCR and regions as well as file reviews completedduring the Pay and Benefits Audit and Acquisition Card Audit, revealed no evidence to indicateemployees had relinquished departmental assets prior to their departure.

6.5 Departure practices are typically considered for employees permanently leaving thedepartment. However, there are various short-term leaves of absence that should alsobe considered in the development of appropriate policies and procedures. We expecteddepartmental policies and processes to reflect the TBS Leave Without Pay Policyrequiring managers to inform employees about “The importance of exercising cautionin their actions while on leave in terms of political partisanship, conflict of interest andcriticism of government policy, as such actions may jeopardize either their status as apublic servant while on leave or their return to the Public Service upon the termination ofthe leave.” Managers were generally unaware of this requirement. In addition, wefound that departure processes are inconsistently followed for short-term departures.We also noted cases where employee access to information, security access and usersaccounts remained intact for the duration of their leave.

While there is usually some form of departure procedure conducted for employees who arepermanently leaving the department, there is no standard or consistent departure process foremployees who have been granted short-term leave. We expected there would be a definition ofshort-term (leave of absence, secondment, special leave such as maternity leave, education leave,etc.) and long-term departures and a consistent process in place to manage these departures. Wefound no departmental explanation or definition by which managers could determine the appropriatedeparture process to be conducted. We also found that departure processes are not regularly orconsistently followed for these departures, which can turn into permanent departures. In some casesemployee access to information, security access and user accounts remained intact for the duration

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of their leave.

We also expected managers would adhere to the TBS Leave Without Pay Policy and informemployees at the time they are granted their leave without pay about “The importance of exercisingcaution in their actions while on leave in terms of political partisanship, conflict of interest andcriticism of government policy, as such actions may jeopardize either their status as a publicservant while on leave or their return to the Public Service upon the termination of the leave.”Managers were generally unaware of this requirement.

6.6 The TBS Personnel Security Standard requires that departments must “establishpolicies and procedures for dealing with the termination of employment that ensures atimely and complete separation.” The policies and procedures should cover a “formaldebriefing to remind individuals of their continuing responsibilities relating to theconfidentiality of the sensitive information to which they have had access in the course oftheir employment.” We therefore expected that the department would have policies andprocedures developed and implemented to address this requirement. There are nopolicies, procedures or formally assigned responsibility for security debriefings ofdeparting employees.

Departments are responsible for protecting sensitive information and assets under their control inaccordance with the TBS Security policy and its operational standards. To that end, whenemployees join the department a personnel screening is to be conducted and each employee isrequired to obtain a security clearance level commiserate with the sensitivity of informationexpected with the duties of their position. Individuals are also required to sign a Security ScreeningCertificate and Briefing Form acknowledging that they have been informed of the requirements ofthe Security policy and their responsibilities with respect to safeguarding information.

The Personnel Security Standard requires that all departments establish policies and procedures fordealing with the termination of employment that ensures a timely and complete separation and thata formal debriefing be conducted with employees. This debriefing is intended to remind employeesof their continuing responsibilities relating to the confidentiality of the information to which theyhave had access during the course of their employment.

While there is no departmental policy or process for employee departures, some organizations havecreated their own procedures none of which specifically covered continuing responsibilities forconfidentiality of sensitive information. We also noted that some Managers or HR representativesconducted a verbal interview with departing employees; but again the focus of these interviews didnot address confidentiality issues. Without this formal debriefing the department has no recourse inthe event that a former employee discloses information detrimental to departmental operations orreputation.

We also found cases where at the request of employees, LAN managers copied files to a CD for thedeparting employees. Although the employee’s supervisors approval is normally sought, there is nodetailed checking performed to determine the content of the files. We found no records beingmaintained of the information provided to the departing employees.

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6.7 When leaving the Public Service, the Conflict of Interest and Post-Employment Policystates that “The deputy head as designated official must ensure that employees areinformed of the requirements of the Conflict or Interest and Post-Employment Code andthat they comply with all its requirements” In addition, the policy states that thedepartment must “conduct exit interviews with employees subject to the post-employmentcompliance measures before they leave the Public Service or review with employees theirresponsibility in this regard.” We therefore expected to find processes and proceduresdeveloped and implemented to address these requirements. We found no processes orevidence of this being done. Managers were generally unaware of this policy or theirresponsibility to undertake post employment activities with departing employees.

The Oath or Solemn Affirmation, a requirement of the Public Service Employment Act (PSEA)requires that an employee sign in agreement to “solemnly and sincerely swear (or affirm) that I willfaithfully and honestly fulfil the duties that devolve on me by reason of my employment in the PublicService and that I will not, without due authority in that behalf, disclose or make known any matterthat comes to my knowledge by reason of such employment.” This is the front end of a processintended to prevent real, potential, or apparent conflicts in accordance with the principles of conductand measures in the Conflict of Interest and Post-Employment Code for the Public Service.

When leaving the Public Service, the Conflict of Interest and Post-Employment Policy states thatobligations under the oath signed on employment, are to be communicated to departing employees,as applicable, so that these requirements are observed after official separation. The department isalso required to have in place policies and processes to ensure that exit interviews are conductedwith employees, subject to post-employment compliance measures, before they leave thedepartment and / or the Public Service or that they be given a review of their post-employmentresponsibilities. The department is also required to advise the TBS should the completion rate forexit interviews, for a given year, fall below 95% in any occupational category.

We found no evidence these activities are conducted. Managers were generally unaware of thispolicy or their responsibility to undertake conflict of interest and post employment activities withdeparting employees. Furthermore, it is not clear who is responsible for these activities, managers orHR. Without this formal communication to departing employees the department has no recourse ifobligations under the oath are not respected and former employees misuse information, research,materials and intellectual property subsequent to employment with AAFC.

6.8 The AAFC Exit Survey Program Policy states that “...departing employees be given anopportunity to indicate their reason(s) for leaving, to express their views on their workingexperience as well as offer suggestions on improving working conditions.” We expectedthat employees would be made aware of the policy and that information would becollected as required. Managers were generally unaware of this policy and HR was notconsistently collecting the information and providing required reports.

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The department has developed the Exit Survey Program Policy, which states “It is the policy ofAgriculture and Agri-Food Canada (AAFC) that employees who are leaving the Department begiven an opportunity to indicate their reason(s) for leaving, to express their views on theirexperience of working in the Department, as well as to offer their suggestions on ways of improvingworking conditions at AAFC.” While not mandatory for departing employees, they are to beencouraged to complete a questionnaire and if desired, participate in an exit interview.

Discussions with Human Resources management indicated that one of the purposes of the exitsurvey program was to obtain open and honest feedback on the employee’s work experience atAAFC. The information was to be analyzed and used for strategic purposes including such areas asimproving employee retention. Obtaining accurate and complete information to fulfill theserequirements depends entirely on the effective administration of this policy and analysis andreporting of the results to management.

The AAFC policy clearly defines the roles and responsibilities for the Exit Survey Program:

• Branch Heads are responsible for implementing the Exit Survey Policy in their branch.

• Managers are responsible for providing employees with the questionnaire, encouraging itscompletion and conducting exit interviews upon request by the departing employee.

• Human Resources Team is responsible for developing, implementing, evaluating andupdating the Exit Survey Policy, questionnaire and other related guides and fact sheets.

• Human Resources Personnel (Advisors, Managers, Directors) are responsible forproviding advice and guidance on all aspects of this process to Branch Heads, Managers andemployees.

We noted a significant lack of awareness of this policy and its requirements. Interviews withManagers across the department revealed that the Exit Survey is not consistently promoted todeparting employees. In some cases managers were unaware of the departmental Exit SurveyProgram Policy or their obligation. In other cases managers believed that Human Resources wasadministering departing procedures, including the Exit Survey and still other managers, althoughthey are aware of the policy, do not offer the option of completing the Exit Survey to departingemployees. Consequently, the activities performed may not be achieving the desired departmentobjectives and the information that was expected from this policy is not being obtained formanagement use. We noted that the latest statistical report available on conducted exit interviews isnot current.

C:\Documents and Settings\johnsoncj\Local Settings\Temporary Internet Files\OLK941\Final Report emp term report NOANNEX.wpd

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APPENDIX A

PROCESS OVERVIEWS

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Employee provides letter of resignation to ManagerEmployee provides letter of resignation to Manager

Completion of Exit Survey is offered to

employee

Final cheque generated and issued to employeeFinal cheque generated and issued to employee

Peer verification of employee file*


Verification of monies owed to the Crown (overspent vacation/

sick days)*


sick days)*

Manager accepts or rejects letter of

resignation


resignation

Manager consults HR to discuss employee

termination intentions



Manager notifies employee of termination


HR discusses options regarding benefits/

pensions with employee and/or family



HR sends employee file to archives after at least

one year


one year

Manager informs HR of employee departure


Employee returns Exit Report confirming return of

assets & access to systems/property to

Manager*

Manager signs completed Exit Report and forwards to HR*

HR confirms all assets & access to systems/

property returned and accounted for *

Calculation of financial entitlements


Agriculture and Agri-Food CanadaEmployee Termination Process

- - - - Activity not standardized or consistent across regions* Control pointsExit Report: Checklist used to confirm return of assets/access to system/propertyExit Survey: Opportunity for departing employees to provide feedback on employment at AAFC

The following pages provide a more detailed description of the activities conducted in the various regions for some of the areas identified as not standardized or consistent.

HR initiates transaction in cases of retirement or

death


death

Employee Signs Conflict of Interest Agreement or

Oath*

Employee provides letter of resignation to ManagerEmployee provides letter of resignation to Manager

Completion of Exit Survey is offered to

employee

Final cheque generated and issued to employeeFinal cheque generated and issued to employee




sick days)*


sick days)*


resignation


resignation












one year


one year



Employee returns Exit Report confirming return of

assets & access to systems/property to

Manager*

Manager signs completed Exit Report and forwards to HR*

HR confirms all assets & access to systems/

property returned and accounted for *



Agriculture and Agri-Food CanadaEmployee Termination Process

- - - - Activity not standardized or consistent across regions* Control pointsExit Report: Checklist used to confirm return of assets/access to system/propertyExit Survey: Opportunity for departing employees to provide feedback on employment at AAFC

The following pages provide a more detailed description of the activities conducted in the various regions for some of the areas identified as not standardized or consistent.


death


death

Employee Signs Conflict of Interest Agreement or

Oath*

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Alberta/British-Columbia

Employee returns Exit Report confirming return of assets & access to systems/property to

Manager

Manager signs completed Exit Report and forwards to HR

HR confirms all assets & access to systems/ property returned and accounted for

• The HR representative on site is involved in the termination process.

• In this regard, HR ensures that the employee has duly completed the Clearance Certificate (similar to the Exit Report).

• Three different versions of the Exit Report were identified.

• The HR representative on-site is responsible for ensuring that the employee has obtained the required signatures as indicated in the Clearance Certificate.

• A copy of this certificate is placed on the on-site employee file. The form is not forwarded to regional HR since it has never been requested.

• Regional HR would be notified by the on-site HR representative if the employee does not return any Crown property.

Completion of Exit Survey is offered to employee

• The Exit Survey is inconsistently promoted.

• Managers stated that they were not aware of the Exit Policy and the requirement to offer Exit Surveys to employees.

Three Manager interviews were held for this region.

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Manitoba/Saskatchewan


Manager



• Inconsistencies were found in the area of the confirmation of return of assets/ information/ access to systems.

• One Manager stated that employees are asked to complete an Employee Departure Property Clearance Report to confirm return of property (signed off by Head, Scientific Support).

• Two Managers identified an unclear process for ensuring the proper return of assets/information/access to systems. No checklists or forms are used to track the return of Crown property. It is assumed by Managers that assets/information/access to systems are returned by employees. One person stated that they “assume people act honorably – this is not a prison.”

• Given the inconsistent processes for return of assets/information/access to systems by employees, Managers are not commonly ensuring return of Crown property of their employees.

• One Manager (the Head of Administration) reviews the Exit Report to ensure proper completion and return of Crown property.

• Assurance of the return of assets/ information/ access to systems by HR is not confirmed.

• One Manager (the Head of Administration) was unsure whether the Clearance Report is forwarded to regional HR.



• One Manager reported that HR advises employees to complete the Exit Survey but did not believe that many employees actually completed the survey.

• Two Managers were not sure whether the Exit Survey was always offered to employees.

Three Manager interviews were held for this region.

-5-

Ontario


Manager



• The process for ensuring the return of assets/ information/ access to systems is inconsistent.

• In one location, an administrative assistant on-site is responsible to facilitate the process to ensure return of assets/information/access to systems. The employee is responsible for returning assets/information/access to systems using an informal checklist provided by the administrative assistant.

• In another location, the Supervisor is responsible for ensuring that all assets/ information/ access to systems are returned. There is no formal checklist used.

• There is no formal checklist used to confirm the return of assets/ information/ access to systems.

• There is no formal process for notifying HR of the return of assets/ information/ access to systems as no formal checklists are used.



• One Manager stated that although there is no offer to complete the Exit Survey, an ‘informal chat’ is held to understand the reasons for departure. This discussion is not formally documented.

Two Manager interviews were held for this region.

-6-

Quebec


Manager



• The termination process is led by the Administration Officer or HR Clerk on site.

• In one case, no formal checklist or form is used to ensure return of assets/information/access to systems. The Director interviewed stated that the Administration Officer knows what to verify when an employee leaves.

• In another case, the Administrative Officer administers a checklist to verify the return of assets/information/access to systems for students and co-op students only.

• No Exit Report is used to confirm the return of assets/information/access to systems (except for students and co-op students in one location).

• The Head of Administration or the on-site HR Clerk verifies that all assets/information/ access to systems are returned, although no formal checklist is employed (except for students and co-op students in one location).


• Employees are offered the opportunity to complete the Exit Survey, however, there is a lack of awareness whether employees actually complete the survey.

• One Director has recently understood that the Exit Survey should also be offered to ‘End of Term’ employees. This will be corrected in the future.

• One Director was not aware of the Exit Policy and Survey.

Two Manager interviews were held for this region.

-7-

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APPENDIX B

SUGGESTED IMPROVEMENTS TO THE EMPLOYEE SEPARATIONCLEARANCE REPORT (ESCR)

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The Employee Separation Clearance Report (ESCR)The absence of a departmental policy and adequate procedures for the timely termination ofemployees and recovery of all assets leaves the department at risk when departures occur. Toaddress this shortcoming, the Asset Management and Capital Planning Directorate developed anEmployee Separation Clearance Report (ESCR) which was approved by the Board ofDirectors in March 2003. The policy states that an ESCR must be completed when any person(employee, contractor, visiting fellow etc) departs an Agriculture & Agri-Food Canada workenvironment or otherwise no longer needs access to departmental resources.

The departing individual is responsible for obtaining appropriate signatures from serviceproviders and the manager once all termination activities have been performed and assetsreturned. Exit procedures are to be undertaken at least two (2) days before the departure date.The policy states that non-compliance could lead to delays in transferring files and issuing finalpayments to the employee.

Although not part of the audit, the ESCR was reviewed in light of the findings noted in theEmployee Departure audit report. Observations about the departure policy and possibleimprovements to the checklist are noted below.

A. THE ESCR POLICY· Ownership of policy and monitoring of process and procedures

The policy fails to identify where accountability for governance should rest. While departureactivities are essential to protect the Department, it is also important to manage the activities andprocedures associated with this policy. The appropriateness of both policy and procedures ascontrol mechanisms should be monitored and changes adopted if objectives are not being met. There are no defined roles and responsibilities for these activities.

· The policy’s definition of departure The ESCR policy applies when an employee departs AAFC’s work environment permanentlyand no longer needs access to departmental resources. Short-term departures, such as maternityleave or leave without pay, etc are not included in this policy and there is no consistency in howthese departures are managed in the department. There is a risk that assets and information arenot properly secured when employees leave for short-term periods. The risk is compounded bythe fact that a short-term departure could turn into complete separation. Appropriate proceduresshould be identified for short-term departures and if required they should also be subject to theESCR.

· Relevance of checklist in regionsOur interviews have indicated that employees are often working on remote locations throughoutthe country and have limited access to service providers. As the ESCR requires that theemployee personally obtain signatures, the use of this checklist as a control in some areas maynot be practical. During interviews, managers indicated that often tools developed atheadquarters are impractical in the regions. It needs to be determined whether the ESCR, as itcurrently exists, is appropriate in all the regions.

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If the ESCR is deemed inappropriate in some regions, it may be necessary to consider a set ofmore than one checklist to account for the specific needs of regions.B. THE CHECKLIST

Review Branch’s audit has identified a list of elements that could be added to the checklist.Part A: To be completed by employeeIn the section Reason for leaving, additional fields should be included to clearly indicate the typeof departure. Fields that could be added are:

· Retirement · Release · Lay-off· Dismissal· Death· Other should be accompanied by Specify.

Part B: Telecommunication ServicesCalling CardsIndividual branches or units also keep track of calling cards issued. Calling cards could bemoved down to Part I, the supervisor’s section.

Part D: Accommodation / SecurityOther cards followed by Specify should be included.Office keys and Combinations Changed could also be included under Part I-Supervisor’sChecklist

Part E: InformaticsReplace Computer Programs by Corporate Systems Access CancelledReplace CPU/Monitor/Printer by Loaned Equipment (Computer, Monitor, Laptop, Modem,Associated Peripheral Accessories)

Part F: LibraryAdd Subscriptions cancelled

Part B to GThroughout sections B to G there should be room for both the signature and the printed name ofsigning officers. Part I: SupervisorThe following may be added:

· Confidential Debriefing· All Files returned· Forwarding address on file· Cancellation of account (after Cell phone)· Office keys (office, desk, briefcase, filing cabinet)· Locks and combinations changed

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Part J: HRThe following could be added:

· Separation Documents followed by a list of expected separation documents in brackets· Other Clearance forms (Student /Region specific)

The need to interface the checklist with an inventory systemThe objective of the ESCR is to protect the Department when employees leave. This objective isfulfilled through the use of a checklist which acts as a control mechanism. However, thechecklist is limited in its function if it is not linked to an inventory system. An inventory systemcan support the information gathered though a checklist and validate whether the terminationand recovery processes are meeting their objectives. It is therefore important to link the ESCR tothe inventory systems used by various functions(Saturn for Finance and Basset Pro for assets) toensure that the Department is fully protected.

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