The Procurement Ombudsman’s 2021-2022 Annual Report

1. Growth in alternative dispute resolution

Over the last 4 years I have championed the benefits of mediation for its ability to find fast and effective solutions to contract disputes. At the beginning of my term as Ombud, I set out to grow my office’s alternative dispute resolution practice, which has consisted of facilitation and mediation services.

I reached out to the heads of 83 departments in 2019 and again in 2021 to request that they include language about my office’s mediation services in their procurement documents. The best way to let Canadian businesses know that Parliament intended OPO to provide quick and effective mediation services is to include language to this effect directly within federal government contracts. However, some of these departments have not yet done so. I will be writing to all departmental heads again in 2022–23 to request that they maximize transparency and directly reference OPO’s services within their solicitation documents, contracts and regret letters to Canadian businesses.

Although OPO-led mediations usually lead to successful resolutions of contract disputes, we have not seen an increase in the use of our services. This year my office received only 7 requests from suppliers for mediation. In 3 of these instances, the department declined OPO’s invitation to participate in the mediation process.

It is frustrating to have departments refuse to try and resolve issues through mediation, as suppliers want to try to resolve their contract dispute outside of costly legal proceedings. Mediation provides parties with an opportunity to work through their issues with a neutral and impartial mediator, and find a mutually agreeable solution. I cannot emphasize enough the importance of coming to the mediation table and working to find a resolution before disputes escalate to litigation.

2. Simplification

My office regularly hears from both Canadian businesses and federal officials who believe the contracting process is unnecessarily complex. This is one of the reasons I have made simplification a priority throughout my term.

In OPO’s procurement practice reviews, my office highlights examples of and opportunities for simplifying the federal procurement process. Examples of simplification include bundling similar requirements, refraining from using unnecessary evaluation criteria, and replacing the reference check process with a more efficient process.

In my annual report last year, I highlighted that 52% of competitive solicitations we reviewed resulted in only 1 bid, as suppliers often decide that it is just not worth their while to go to the effort and expense of submitting a bid. This year, this number has fallen from 52% to a lower but still concerning 36%.

3. Transparency

This year my office was contacted by numerous stakeholders about the lack of transparency associated with the government’s efforts to procure items related to the COVID-19 pandemic. OPO received several complaints from suppliers about their inability to gain information about the results of solicitation processes, and why their bid was unsuccessful.

In the early months of 2020, the Government of Canada took an unprecedented approach in applying a blanket National Security Exception (NSE) to all procurements supporting Canada’s response to the COVID-19 pandemic. To provide insight to our stakeholders on the national security exception, we drafted a Knowledge Deepening and Sharing study on the topic, which will be published on the Office of the Procurement Ombudsman's website along with other procurement-related research studies.

Issues with file documentation also remained a persistent observation in our reviews of departmental procurement practices in 2021–22. In the majority of reviews conducted this year, we found that the failure to maintain appropriate records of key decisions impacted the transparency of the procurement process. Even in the context of emergency procurement, it is of paramount importance to clearly document the steps taken and decisions made during the procurement process.

4. Knowledge Deepening and Sharing

Since 2018–19, my office has undertaken independent research into procurement topics of interest to our stakeholders. This year we completed 2 Knowledge Deepening and Sharing (KDS) studies.

The first study builds on our previous examination of social procurement and explores more deeply the topic of set-aside programs. The report examined case studies from within Canada and abroad including established programs in Australia and Europe. This study offers a critical examination of different approaches to set-aside programs. It identifies several themes, including the need to overcome the criticism of reduced competition, the importance of establishing realistic targets, monitoring progress, and collecting meaningful data.

Our second study explores the construct and application of the NSE and its impact on government procurement through the lens of fairness, openness and transparency. This study demonstrates how the overly broad application of the NSE can result in a lack of transparency. The NSE insulates procurements from traditional accountability mechanisms that would both scrutinize the application of the NSE and provide a recourse for suppliers through the Canadian International Trade Tribunal’s bid review mechanism. It concludes that while certain reductions to fairness, openness, and transparency are justified and appropriate where the procurement is tied to Canada’s national security interests, the negative impacts of the NSE can be minimized through targeted, transparent and proportionate application of the NSE.

My office also continued research on the potential role of a CPO at the federal level, a topic which we published a KDS report about last year. Our study revealed that the establishment of a CPO in other jurisdictions has resulted in greater consistency and standardization in procurement. A CPO can contribute to modernization by acting as an agent of change and creating a clear focal point for procurement information and the professionalization of the function. CPOs can provide leadership, oversight and guidance in the procurement function, help ensure the consistent application of policy, and support talent management and innovation in the procurement community. It is an option that warrants further consideration.

1. Recommend compensation greater than 10% of the value of the contract

OPO’s ability to review complaints regarding the award of a contract are tied to the thresholds of the Canadian Free Trade Agreement (CFTA). As a result, when I find that a complaint has merit, the maximum compensation I can currently recommend is $3,030 for goods contracts, and $12,120 for services contracts. In many cases, these amounts are insufficient to cover the supplier’s lost profits or bid preparation costs, let alone the time and expense required to file a complaint and submit documentation to my office. This 10% cap disincentivizes suppliers with legitimate complaints from seeking recourse. To increase fairness, I recommend the compensation cap be increased to reflect the amount of lost profit a supplier would have received had they properly been awarded the contract.

2. Compel federal departments to provide documentation

The Regulations empower the Ombudsman to request that federal departments share any relevant documentation with OPO. As such, departments are currently able to disclose only what they choose to disclose, and can suppress information vital to conducting fair and transparent reviews without fear of potential consequences. There have been instances where we have had to write to departments during the course of a review to remind them to provide documents that we know exist. The ability to compel the production of documents necessary to conduct investigations and procurement reviews would increase both the fairness and transparency of the procurement process.

3. Review complaints related to the Procurement Strategy for Indigenous Businesses

When the set-aside program for Indigenous businesses was originally created, there was no redress mechanism for complaints regarding contracts awarded pursuant to the strategy. Such complaints remain outside the jurisdiction of my Office and that of the Canadian International Trade Tribunal (CITT). As was recently highlighted by the CITT in a December 2021 order, excluding Indigenous suppliers from accessing the CITT’s bid challenge mechanism means that “Indigenous suppliers currently have less rights of access to justice than non-indigenous Canadians, and foreign suppliers, who can access the Tribunal when the trade agreements are applicable.”^{Footnote 1} This represents a systemic barrier that must be removed. This proposed change to the Procurement Ombudsman Regulations will enable my office to review complaints related to the award and administration of contracts under the Procurement Strategy for Indigenous Businesses. This would provide Indigenous suppliers with access to the same impartial and independent review as other Canadian suppliers.

4. Change Ombudsman to Ombud

The title of my position and the name of the office should be changed to reflect the nature of the role and office. Similar changes have recently been implemented for newly appointed ombuds at the federal level, and we have fallen behind the times with this long overdue change. It is important that an ombud represent all people, and for this reason I strongly recommend that the name of the role and the office be changed from the “Procurement Ombudsman” to the “Procurement Ombud.” The proposed change allows for gender and linguistic neutrality. Throughout the remainder of my Annual Report, we have referred to my role as the Procurement Ombud.

Nature of cases

Image description of nature of cases

Nature of cases that OPO received in 2021-22:

• 327 cases related to general procurement inquiries
• 151 cases related to the award of a contract
• 50 cases related to the administration of a contract

Who contacted us

Image description of who contacted us

Types of stakeholders who contacted the office in 2021-22:

• 448 supplier/supplier association/sub-contractors
• 42 Federal department representatives
• 8 Members of Parliament/Members of Provincial Parliament/other levels of government
• 30 Anonymous

How we reached our stakeholders

Image description of how we reached our stakeholders

Types and number of outreach activities that OPO held or attended to reach out to its stakeholders in 2021-22:

• We hosted or participated in 17 information sessions for suppliers
• We attended 6 trade shows
• We held 7 information-sharing sessions with other federal organizations
• We met 21 times with Members of Parliament
• We delivered 13 presentations at procurement events
• We had 73,959 twitter impressions
• We had 12,608 LinkedIn impressions

1. Acquisition of project evaluation services by the Department of Foreign Affairs, Trade and Development

On August 4, 2021, OPO received a written complaint regarding a contract awarded by the Department of Foreign Affairs, Trade and Development (DFATD). The contract was to perform a summative evaluation of the Canada-Ukraine Trade and Investment Support Project. The contract was awarded on August 3, 2021, and valued at a maximum of $97,339 (applicable taxes extra).

The review of the complaint concluded that DFATD did not structure the solicitation to exclude the Complainant’s bid, as the wording causing the Complainant’s concern was found to be acceptable.

However, DFATD did not conduct the solicitation process in accordance with its obligations, as the solicitation should have been posted on a government electronic tendering service (GETS) site to maximize visibility and coordination of the solicitation. DFATD also failed to keep sufficient records to document its decisions, making it impossible to conclude whether the Complainant’s bid was properly evaluated and whether it should have been deemed compliant. Finally DFATD did not provide the Complainant with an adequate debriefing, including detailed information explaining its rationale for disqualifying the Complainant’s bid.

The Procurement Ombud recommended DFATD pay compensation to the Complainant in an amount equal to 50 percent of its costs for preparing and submitting its bid.

The complete report is available on the Office of the Procurement Ombudsman's website.

1. Complaint regarding refusal to pay by the National Research Council resolved and review terminated

In December 2021, OPO received a written complaint regarding the refusal of the National Research Council to pay an invoice that had been submitted in June 2021. On December 23, 2021, the Procurement Ombud notified the Complainant and the National Research Council that an investigation had been launched. Shortly thereafter, the Procurement Ombud was notified that the Complainant had received payment from the National Research Council and had withdrawn the complaint. In accordance with paragraph 10(a) of the Procurement Ombudsman Regulations, the Ombud was required to end the review and notify the parties.

2. Complaint regarding the award of phase II upgrade to the fuel system at a minimum security institution by Correctional Services Canada terminated after department canceled contract

In February 2022, OPO received a complaint regarding a contract issued by the Correctional Service of Canada (CSC) for a construction project to upgrade the fuel system for the site generator at a minimum security institution.

The contract represented phase II of the overall initiative to upgrade the fuel system, and was preceded by a phase I contract which, in part, required the contractor to provide full drawings and specifications to be used as technical documentation and as the basis for the phase II solicitation. The phase I contract also required the contractor to provide technical and inspection expertise during the execution of the phase II contract.

The contract at issue (phase II) was awarded to the same contractor who was awarded the phase I contract. The Complainant alleged the winning supplier’s involvement with the phase I contract put them in a conflict of interest position and provided them with an unfair advantage regarding the phase II contract.

In February 2022, OPO launched its review. In March 2022, CSC responded to OPO and acknowledged that it should not have advised the phase I contractor that it could bid on phase II, and should not have awarded both the phase I and phase II contracts to the same supplier. CSC then issued a Suspension of Work notice ordering the contractor to immediately cease working on the contract. In March 2022, CSC terminated the contract by mutual consent.

According to paragraph 10(c) of the Procurement Ombudsman Regulations, when a contract is cancelled, the Ombudsman must end the review. Accordingly, CSC and the Complainant were advised on March 23, 2022, that OPO’s review had been terminated.

1. Transport Canada

OPO concluded that for the files where there was adequate documentation to review the entire file, evaluation criteria and selection plans met requirements set out in applicable laws, regulations and policies and, for the most part, mandatory and point-rated criteria were clearly communicated. However, there were issues regarding unclear evaluation criteria, where mandatory or rated criteria had vague or poorly defined descriptors, and several instances where evaluation criteria appeared to favour a certain bidder.

Solicitation documents and actions taken by Transport Canada (TC) during the solicitation process were, in most cases, consistent with applicable rules. However, certain shortcomings were noted regarding some aspects of correspondence with suppliers, including communications during the solicitation period and when advising bidders of the evaluation results via regret letters.

Regarding the evaluation of proposals, TC staff either missed, or ignored, what could have been a disqualifying flaw in 10 files. File documentation was also found to be incomplete in 30 of the files assessed, however TC’s ability to access hard-copy files during the COVID pandemic was noted.

The Procurement Ombud made 4 recommendations to Transport Canada:

• Establish a quality control framework to ensure evaluation criteria are measurable, fair and do not favour a particular bidder/group of bidders
• Review and update its Contract Procedures Manual and any model templates to reflect current procurement policies, especially as it related to information exchanges with suppliers. In addition, “regret” letters must consistently include an outline of the factors from the bid and criteria that caused the bid to be unsuccessful
• Establish mechanisms to ensure bid evaluations: 1) adhere strictly to the evaluation criteria in solicitations; 2) are carried out in accordance with planned approaches; and 3) are appropriately documented
• Establish a mechanism to enforce the requirement to document every decision of business value and maintain up-to-date and complete procurement files

2. Parks Canada

OPO concluded that evaluation criteria and selection plans were established in accordance with applicable laws, regulations and policies in the majority of the 40 files reviewed. In all files, selection methodologies were clearly communicated, and evaluation criteria were aligned with requirements and were not unnecessarily restrictive. However, several observations regarding unclear evaluation criteria and rating scales for point-rated criteria were noted.

Solicitation documents and actions taken by Parks Canada during the solicitation process were, in most cases, consistent with applicable rules. In all but 2 files, there was evidence of appropriate communications with suppliers during the solicitation period, and in most cases, solicitations contained clear and complete information and instructions for submitting bids. However, information in certain solicitation documents was found to be incomplete, incorrect, or contradictory, which may impact a supplier’s ability to prepare and submit responsive bids.

The majority of files reviewed were adequately documented and demonstrated that evaluation of bids and contract awards were performed in accordance with the solicitation. OPO did, however, observe certain evaluations that were not consistently carried out in accordance with the planned approach or were not adequately documented.

The Procurement Ombud made 4 recommendations to Parks Canada:

• Ensure that its existing Guide for the Bid Evaluation Process is followed and that evaluation criteria and ratings scales are communicated in solicitations in a clear, precise, and measurable manner
• Develop and implement a process to ensure the completeness, consistency and accuracy of all information contained in solicitation documentation to avoid discrepancies in its solicitation processes
• Implement appropriate supervision and review mechanisms to ensure evaluations are carried out in accordance with the planned approach and are appropriately documented to support the transparency of the award process
• Update its procurement guidance to clarify procedures and documentation requirements related to evaluator conflict of interest attestations

3. Immigration, Refugees and Citizenship Canada

OPO concluded that the solicitation documents reviewed consistently identified evaluation criteria and the selection method to determine the successful bid. However, in some limited circumstances, evaluation criteria were not communicated in a clear, precise and measurable manner.

The design and execution of competitive solicitation processes were consistent with applicable rules, regulations and policies in all but 1 of the 35 files reviewed. However, in some limited circumstances, communications with suppliers lacked transparency, both during the solicitation period and when advising bidders of the evaluation results via regret letters.

Immigration, Refugees and Citizenship Canada had established a standard process for evaluating proposals complete with detailed guidance for evaluators. However, in some limited circumstances, evaluations were not consistently carried out in accordance with the planned approach, and in 2 files contracts were awarded to non-responsive bidders.

The Procurement Ombud made 3 recommendations to Immigration, Refugees and Citizenship Canada:

• Establish a quality control process to ensure mandatory criteria are adequately defined and communicated in a clear, precise and measurable manner, and that mandatory criteria are limited to the essential qualifications necessary to fulfill the requirement
• Ensure that the information that is communicated to suppliers both during and after the solicitation process is accurate and that adequate documentation of these communications is retained to facilitate management oversight
• Ensure that evaluations adhere strictly to the evaluation criteria and are carried out in accordance to the planned approach.

4. Canada Border Services Agency

OPO concluded that evaluation criteria and selection plans met requirements set out in applicable laws, regulations and policies and that for the most part, mandatory and point-rated criteria were clearly communicated. However, there were issues regarding unclear evaluation criteria, where mandatory or rated criteria had vague or poorly defined descriptions.

Solicitation documents and actions taken by Canada Border Services Agency (CBSA) during the solicitation process were, in most cases, consistent with applicable rules. However, several issues were noted regarding communications with suppliers, including providing clear instructions for bid submission, communications during the solicitation period, and when advising bidders of the evaluation results via regret letters.

OPO noted considerable deficiencies in bid evaluations and documentation. Certain evaluations were not consistently carried out in accordance with the planned approach or were not adequately documented. Furthermore, OPO observed instances where CBSA failed to disqualify non-compliant bids, and awarded at least one contract to a non-compliant bidder. File documentation was also found to be incomplete and of significant concern in several files.

The Procurement Ombud made 5 recommendations to CBSA:

• Establish a quality control process to ensure mandatory criteria are adequately defined and communicated in a clear, precise and measurable manner
• Establish mechanisms to: 1) ensure that solicitations contain clear instructions for submitting bids; 2) ensure that relevant information is shared with all suppliers simultaneously; and 3) ensure all relevant communications with suppliers are properly documented
• Establish a mechanism to ensure that evaluations adhere strictly to the evaluation criteria and are carried out in accordance with the planned approach, and that contracts are not awarded to non-compliant bidders
• Establish a mechanism to enforce the requirement to document every decision of business value and maintain up-to-date and complete electronic procurement files
• Ensure that any officials engaging in the procurement process receive adequate support and training to ensure that sound stewardship practices are followed and that Canada’s obligations under applicable sections of national and international trade agreements are respected

5. Natural Resources Canada

OPO concluded that mandatory criteria in solicitation documents were aligned with requirements and were not overly restrictive; however, a majority of files included mandatory criteria that were not defined in a clear, precise or measurable manner.

Solicitation documentation was mostly complete; however, several opportunities for improvement were noted regarding the description of requirements and instructions to bidders. Solicitations also contained inappropriate wording about a certification required before contract award.

Inconsistencies in the evaluation of bids and deviations from the planned approach were noted and in several instances contracts were incorrectly awarded. File documentation was also incomplete in several files.

The Procurement Ombud also noted one instance of the perception of contract splitting, one case where internal procedures were not followed with respect to a requirement subject to the Nunavut Land Claims Agreement, and one case where the estimated value of a requirement was not established before soliciting bids.

The Procurement Ombud made 8 recommendations to Natural Resources Canada:

• Establish a quality control process to ensure mandatory criteria are adequately defined and communicated in a clear, precise and measurable manner
• Update its internal guidance to provide information with respect to the development of evaluation criteria and selections plans and ensure that evaluation criteria, scoring grids and selection methodologies are communicated in solicitations in a clear, precise, and measurable manner
• Correct the wording used in its RFP template(s) so that the purpose of the Indigenous designation certification is clear to all potential bidders
• Establish a process to ensure that information communicated to suppliers prior to bid closing is clear and that adequate documentation of these communications is retained to facilitate management oversight. In addition, NRCan should establish a process to ensure that contract award notices for applicable files are published within the required timeframe and that regret letters are always sent to unsuccessful suppliers in a timely manner
• Establish processes to ensure that: (1) evaluation instructions are consistently provided to evaluators; (2) non-compliant bids are disqualified and not further assessed; and (3) technical evaluations adhere strictly to the evaluation criteria and scoring grids in solicitations; and are carried out in accordance with planned approaches
• Establish processes to ensure: (1) evaluations are appropriately documented to support the transparency of the award process; and (2) procurement files are complete and kept up-to-date
• Establish a process to review planned procurements to ensure aggregate requirements are not inappropriately divided to avoid controls or trade agreement obligations
• Update its Contracting Desktop Procedures to comply with the Nunavut Land Claims Agreement and Treasury Board Directive on Government Contracts, Including Real Property Leases, in the Nunavut Settlement Area and establish a process to ensure its procedures are followed with respect to Comprehensive Land Claims Agreement obligations

6. The Royal Canadian Mounted Police

OPO concluded that evaluation criteria and selection plans were established in accordance with applicable laws, regulations and policies in the majority of files reviewed. Mandatory evaluation criteria were clearly communicated, not unnecessarily restrictive, and aligned with the requirement in most cases. While exceptions were identified, overall, the selection methodology reflected the complexity of the requirement and was clearly communicated in solicitation documents. A contributing factor to these overall positive results was the oversight provided by the Royal Canadian Mounted Police’s (RCMP’s) Contract Quality Control (CQC) function.

OPO concluded that solicitation documents and actions taken by the RCMP during the solicitation process were, overall, consistent with applicable rules. Most solicitations contained clear and complete information and instructions necessary for bidders to prepare a compliant bid and the design and execution of solicitation processes supported fair, open and transparent procurement. OPO did note some problematic exceptions where solicitation processes did not respect the principles of fair, open and transparent procurement, including one file where the requirement was modified after quotes were received in an effort to get the price below a trade agreement threshold, and two files where the required call-up procedures were not followed.

Evaluation of bids and contract award were generally conducted in accordance with the solicitation; however, in one file the contracting authority contacted a bidder after the bidding period had closed to request required documentation that had not been included with the bid, resulting in an improper practice known as bid repair. In addition, OPO noted that greater consistency in the documentation of bid evaluation results is required to demonstrate the equal treatment of bidders.

The Procurement Ombud made 4 recommendations to the Royal Canadian Mounted Police:

• Expand the scope of procurements that are subject to the Contract Quality Control review to include solicitations with technical evaluation criteria that are not currently reviewed because they are issued under supply arrangements
• Implement a standard approach to record results from the financial evaluation of bids
• Implement an effective mechanism to enforce the requirement to maintain up-to-date and complete procurement files
• Make greater use of technology in their procurements including, but not limited to, allowance for bids to be submitted electronically and alternatives to traditional paper-based methods for managing contract files

7. Review of non-competitive contracts involving WE Charity

The Procurement Ombud conducted a review of contracts awarded to WE Charity and its affiliates to determine whether contracts awarded on a non-competitive basis, and associated amendments, were issued in a manner consistent with applicable legislation, regulations, policies, procedures and guidance. For this review, OPO examined 6 contracts that had been awarded to WE Charity since 2017 by 4 federal departments: Canada School of Public Service (CSPS), Global Affairs Canada (GAC), Privy Council Office (PCO) and the Public Health Agency of Canada (PHAC).

OPO concluded that the use of non-competitive processes for awarding these contracts was consistent with the requirements of the Government Contracts Regulations, and that the decisions to award the contracts without competition were justified and appropriately documented in all contract files. However, issues regarding fairness were identified in the establishment of cost estimates, which should have been established and documented on file prior to contacting WE Charity about the contracting opportunity and requesting pricing.

Several opportunities for improvement were noted in the review, which led the Procurement Ombud to make 3 recommendations:

• To CSPS, PHAC, GAC and PCO: To ensure the fairness of the procurement process, departments should not contact a prospective supplier, share information about an upcoming requirement, and request proposed pricing through a non-competitive process prior to establishing and documenting an estimate for the acquisition of goods or services
• To PCO: Establish a process to ensure mandatory PSPC standing offers and supply arrangements are used when required or alternatively that a timely exemption from their use is sought and received prior to contracting
• To GAC and PCO: Recognizing there will be contract requests that have tight timelines, review existing procurement controls to ensure that processes can be followed with appropriate due diligence and effective stewardship

Mandatory criteria should be clearly defined and limited to essential qualifications

When developing mandatory criteria, all departments should be mindful that criteria are limited to only those qualifications necessary to deliver the requirement and communicated in clear, measurable language.

The inclusion of unnecessary evaluation criteria, particularly as mandatory criteria, unnecessarily complicates the procurement process by making it administratively burdensome for bidders. It also increases the potential for bidders to make mistakes and have their proposal deemed non-responsive for failing to meet a mandatory criterion that was not essential to the performance of the contract. An example of an unnecessary mandatory criterion is requiring bidders to identify a single point of contact. While useful from an administrative standpoint, this criterion is unrelated to the bidder’s ability to perform the work and is not aligned with requirements.

OPO has also observed a high number of solicitations where mandatory criteria were inadequately defined, and were not communicated in a clear, precise and measurable manner. For example, OPO has repeatedly observed mandatory criteria that require bidders to demonstrate ‘experience’ but do not specify how much experience is required. As a result, any amount of experience would result in the criteria being met. OPO has similarly witnessed the inclusion of mandatory criteria that cannot be evaluated on a pass or fail basis at the time of bid close, and can only be demonstrated through the performance of the contract. Requirements such as these belong in the contract awarded to the successful bidder as they relate to the performance of required services in the future, whereas mandatory criteria are more suitable to determine skills or experience held by the supplier at bid close.

Retaining records of business value

Departments are required to ensure that adequate documentation of key decisions is preserved to support management oversight and establish an audit trail. Inadequate documentation remains a frequent observation in OPO’s reviews of departmental procurement practices. Records of key decisions are either absent from the procurement file, as was noted in the summaries of procurement practice reviews completed in 2021–22, or buried in superfluous documentation.

With the transition to electronic record-keeping and many public servants now working remotely, OPO has observed a trend where vast amounts of information that lack business value are being indiscriminately saved. To be clear, the requirement to establish an adequate audit trail supports transparency by ensuring that records can be efficiently accessed when required. Departments should be mindful to assess information for its business value and retain only the information that provides support for decisions made.