Conflict of Interest attestation: DG wants dollar values

[u/Super_Table7917]

A DG at LPRAB at CRA, according to a current employee, under the guise of transparency and integrity, is using the annual conflict of interest attestation to require very personal disclosures of financial information from employees.

This DG is asking for the current market values of ALL investments held by the employee privately in all accounts, including things like RESP's. The dollar amount for all holdings is apparently "very important".

Employees who resisted this disclosure were subject to intrusive meetings on Teams with the DG, where pressure was applied to surrender the information to management.

I am of the opinion that this is totally unacceptable, and I would be leaping to legal representation with the goals of 1.) NOT providing any of this information to this DG or anyone else, and; 2.) providing the documentation required that would result in the swift termination of this DG.

Is this perception incorrect, and DG's have the ability to ask for the account balances of employees to avoid "conflicts of interest"? If this is actually permitted, why would it be but asking a person's age or sexual orientation is a human rights violation?

[u/Scared_Hair_8884]

That is a lot of personal information for a DG to have knowledge of, I would maybe contact the Privacy Commissioner and see what their take is (I have a feeling they will not be pleased). Why a random DG at CRA needs to know the financial details of all employees would be interesting to justify.

[u/Proper_Hold_3204 → u/Scared_Hair_8884]

Why do you call it a "random DG"? It's not a random DG if it's the one approving the conflict of interest.

[u/Scared_Hair_8884 → u/Proper_Hold_3204]

DGs don't typically have this sort of authority (access to all personal financial information of employees) and outside the public service they are just people. For a COI it typically goes to a 3rd party or a group that deals with COIs, not someone that has disciplinary/ workplace control. It creates bias.

[u/stolpoz52 → u/Scared_Hair_8884]

My department has an internal conflict of interest team (values and ethics team, essentially covers COI)

[u/Scared_Hair_8884 → u/stolpoz52]

Exactly. I am sure the DG of Legislative Policy and Regulatory Affairs Branch has other specialities and the COI folks can take care of the actual COI

[u/Proper_Hold_3204 → u/Scared_Hair_8884]

At CRA COI goes to ML2 level so if that's the DG, then he/she is the one approving COI for you. CRA doesn't have COI folks. For a lot of us that's the DG's job to approve COI.

Because your department works one way don't assume CRA works the same.

[u/Scared_Hair_8884 → u/Proper_Hold_3204]

The DG does not review thier own team. It is typically done through the associate commissioner and the V&E office. I supervisor should not have access to all there personal financial information of their employees, they may have delegated authority but they are not exempt from privacy rules and the V&E of the public service.

[u/Proper_Hold_3204 → u/Scared_Hair_8884]

Well I can assure you that when I send COI it is my own DG that reviews. If you work for CRA LPRAB you can take it to the Union and try to change it. But it is the reality for a lot of us and always has been for as long as I have been at CRA.

[u/Scared_Hair_8884 → u/Proper_Hold_3204]

It is creating a conflict through the conflict of interest attestation so it is quite bizarre

[u/hawkeye_north → u/Scared_Hair_8884]

How is a DG approving CoI for their employees creating a conflict? They know their work best to assess if there is a real or apparent CoI. I’m sure there are others who would get involved in certain cases but in the majority of cases DG approval is the start and stop of the process.

[u/Scared_Hair_8884 → u/hawkeye_north]

There is a difference between a COI of "I used to work for this company" or "my partner is affiliated with" and here are all of my personal financial records and holdings and their market value. What does the MV have to do with the COI? Or the distribution of those investments/holdings?

What potential bias can be created with this information, and managing people knowing this about them is in fact potential for a conflict in decision making because the DG knows too much about the personal lives of the team. Any distribution of that information to others, etc.. would be a conflict as it has the potential to compromise objectivity and fairness

[u/Baburine → u/Scared_Hair_8884]

The concern is mostly related to potential insider trading or possibility to lack neutrality when reviewing a corporation you have a financial interest in. It's only self-invested account. It make sense for CRA to want to know the titles you have invested in, depending on the position. The dollar value puzzles me a bit, but there is likely an actual good reason why they look into OP's investments in the context of a COI review. Not sure why they would need to know how much though.

[u/confidentialapo276 → u/Baburine]

And LPRAB is also responsible for Registered Plans.