Accountability and Transparency

July 19th, 2013

Transparency in any organization is the first step to accountability.  But CSA has a peculiar notion of transparency.  They seem to believe that transparency should apply to everybody except CSA.  And CSA targets nearly “everybody” for transparency.  For instance;

-  In its Product Category Rules Program, CSA boasts that they have “expanded its sustainability portfolio to provide services to organizations and industries that are seeking to provide greater transparency […]” And again, that “CSA Group will work with stakeholders to help ensure transparency” of their customers conduct.

-  In 2010, CSA released a new standard for large events (like the Olympics).  This new standard would ensure the “ethical behaviour, accountability and transparency” of the customers of CSA. Bonnie Rose, CSA’s President of Standards, claimed that this standard would make events more “ethical and transparent.”

-  In another CSA certification, this time Greenhouse Gas Inventory Qualifiers, CSA claims that their new certification provides “transparency and accountability […] for qualifying GHG professionals.”  Not for CSA mind you, transparency is for “professionals.”

-  In 2009 CSA allied itself with World Energy to “streamline” the carbon market “while delivering transparency.” 

-  In its sales pitch to other companies, CSA attributes the general lack of public trust in business to the specific lack of transparency.  In CSA’s words, the “skepticism is largely attributed to a lack of transparency.”

-  In promoting its role on verification processes, CSA advised that entities could enhance “integrity by promoting consistency, transparency and credibility.”

-  Even in its volunteer committees, CSA demands “respect for diverse interest and transparency.” 

-  This “respect for diverse interest and transparency” is repeated in its description of what it requires of “third party” entities contributing to standards.

-  In its forest management standards, CSA demands that companies offer “a mechanism to measure participants’ level of satisfaction with the process” and that they have a “transparency section” to ensure accountability.

-  CSA even contributes on major government accountability and transparency initiatives such as the Governance and Financial Accountability Accord.

For all this however, CSA isn’t terribly interested in applying transparency or accountability to its own actions. 

On accountability, CSA’s Values page claims that it applies “CSA’s values and mission and [takes] responsibility and are accountable for our work and our actions in the decisions we make for our colleagues, our customers and our members.” At no point does CSA outline a specific accountability process.  There is no mention of whether accountability is exclusively internalized or whether an independent, external party is reviewing CSA activities. On accountability, CSA makes a pleasant sounding statement, backed up with absolutely no substance.

CSA’s Values page makes doesn’t even mention transparency.  In fact, the only internal policy or guideline that we could find which mentions transparency is CSA’s Code of Conduct.  This Code of Conduct states that “Transparency requires that accurate records are kept, both in paper and in electronic form. CSA Group requires honest, accurate and timely recording and reporting of information in order to make appropriate business decisions. As employees, we are responsible for the integrity and accuracy of CSA Group’s documents, records and business information. We must never falsify documents, records or business information including test reports, procedures, personnel records and communications.”

Note that CSA’s interest in transparency is purely internal, its only done “to make appropriate business decisions.”  Nothing in their transparency policy allows for external audit or independent review.  Note also that CSA claims it must never “falsify documents,” yet P.S. Knight poignantly experienced the chasm separating CSA policy and practice as regards document falsification.

CSA ought to know better. Not only do their own publications demand higher standards from everyone else, but their own internal reports demand the same things of all organizations.  One such report bluntly states that “it is difficult to see how accountability of practice can be satisfactorily claimed without external and independent auditing.” And again, “the involvement of an external body is, therefore, indispensable.” And yet again, “that external agent is presumed to have rights of authority over those who are accountable -including the rights to demand answers and impose sanctions. Thus, if there is no possibility of external compulsion to change practices, there can be no accountability.”

This is what is doing, by the way, we are providing “external compulsion to change practices.”

“In a 1995 report to the Canadian Standards Association, I made a rough distinction between the accountability of policy, of procedures, and practice.”  This report by Colin Bennett eventually became CSA’s Implementing Privacy Codes of Practice.  The CSA was happy to publish transparency and accountability requirements applicable to other companies, provided that CSA itself is exempted from such requirements.

And CSA likes being exempted from things. Whereas other government agencies have to report the details of their financial transactions, CSA’s financial reporting is characterized by Enron-like levels of impenetrable obscurity.  Entire classes of expenditure are grouped and summated with a non-descriptive heading.  Its like reporting $400 million dollars of annual expenditure on “things.”  If any other government agency did that the department they report to would have an absolute fit over it. 

But CSA is also exempted from the transparency and accountability regulations standard to every government department and agency. 

And they’re also exempted from the Freedom of Information and Protection of Privacy Act.  Normally, this Act ensures that agencies like CSA are held to account for their treatment of the public and the taxpayer dollars they receive.  This exemption means that everything FOIP would normally cover at CSA can be concealed from the people who pay for it.

And CSA is also beyond the reach of law enforcement.  The RCMP’s Commercial Crimes Unit is unable to investigate CSA because CSA is federally chartered, they report to the Minister of Industry, and are therefore a government regulatory entity.  Industry Canada’s Competition Bureau likewise can’t hold CSA accountable because the Bureau’s mandate covers private industry, not government agencies.

And Industry Canada has given CSA an alarming degree of immunity from civil litigation.  Effectively then, CSA is being protected from accountability to the people its supposed to be serving.  Yet accountability is precisely what CSA is demanding of everyone else.

The Canadian Standards Association is currently functioning without accountability or transparency, it is beyond the reach of law enforcement, it is preying on the people its supposed to be serving, it is a rogue regulator; in its present state CSA is a corrosive, destructive and expensive influence in Canada.  For all these reasons the CSA desperately needs renovation to restore its purpose, its performance and its reputation.