PROTECTEDB MEMORANDUM FOR MR. W. DAVERN JONES IMPLEMENTATION OF NEW MEASURES WITH RESPECT TO CHARITIES ENGAGED IN POLITICAL ACTIVITIES (Information Only) PURPOSE To advise the Commissioner about the Charities Directorate's (Directorate) implementation of the new measures set out in Budget 2012 with respect to political activities carried on by registered charities. BACKGROUND Budget 2012 proposed several new measures related to reporting, compliance, and transparency for political activities carried on by registered charities. The new measures came into effect on June 29,2012, when the legislation received Royal Assent. The Budget provided the Directorate with additional resources to allow it to implement these changes, which include: • amendments to ensure that all funding intended for political activities is reported in a charity's annual informati on return (Form T3010, Registered Charity Information Return and related documents); • requirement of registered charities to report more information about political activities, including the extent to which funding from foreign sources is used to carry on political activities; • new intermediate sanctions for non-compliance with the political activities rules and the requirement to file an accurate and complete Form T301O; and • increased education and compliance activities. ...12 000037
Transcript
PROTECTEDB
MEMORANDUM FOR MR. W. DAVERN JONES
IMPLEMENTATION OF NEW MEASURES WITH RESPECT TO CHARITIES ENGAGED IN POLITICAL ACTIVITIES
(Information Only)
PURPOSE
To advise the Commissioner about the Charities Directorate's (Directorate) implementation of the new measures set out in Budget 2012 with respect to political activities carried on by registered charities.
BACKGROUND
Budget 2012 proposed several new measures related to reporting, compliance, and transparency for political activities carried on by registered charities. The new measures came into effect on June 29,2012, when the legislation received Royal Assent.
The Budget provided the Directorate with additional resources to allow it to implement these changes, which include:
• amendments to ensure that all funding intended for political activities is reported in a charity's annual information return (Form T3010, Registered Charity Information Return and related documents);
• requirement of registered charities to report more information about political activities, including the extent to which funding from foreign sources is used to carry on political activities;
• new intermediate sanctions for non-compliance with the political activities rules and the requirement to file an accurate and complete Form T301O; and
• increased education and compliance activities.
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The funding for the Budget 2012 measures has been allocated by the Resource and Investment Management Committee and is included in the Treasury Board 2012 omnibus submission. As it has not yet received this funding, the Directorate will likely request a carry-forward.
CURRENT STATUS / INITIATIVES
POLICY
The Directorate is developing additional guidance for registered charities to assist them in assessing whether their activities comply with the requirements of the Income Tax Act.
POLITICAL ACTIVITIES WORK PLANS
To implement these initiatives the Directorate has developed Budget 2012 work plans, which are divided into three broad themes:
• transparency; • education and information activities; and • monitoring and compliance acti vities.
TRANSPARENCY
The Directorate made specific revisions to the annual information return to increase reporting on political activities. The revised return and accompanying guide will be available in January 2013 and the system changes to the program database and Internet display will be released in April 2013. These changes will apply to registered charities with fiscal periods ending on or after January 1, 2013.
A registered charity is required to file its annual information return no later than six months after the end of its fiscal period. Therefore, the Directorate will receive the first significant filing of returns with the new political activities information by the Fall of 2013.
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The proposed revisions are consistent with the current guidance on political activities. The Department of Finance was consulted extensively on the revisions and has indicated its support. A select group of sector representatives was also consulted and much of their feedback was incorporated in the revisions.
EDUCATION AND INFORMATION ACTIVITIES
The Directorate developed a political activities education and information plan that includes:
• January to March 2013: Creating and releasing a general information package on political activities, as well as Fact Sheets on specific topics of interest.
• April to June 2013: Producing a political activities webinar, which will be uploaded to the Canada Revenue Agency's (CRA) Web site and YouTube; carrying out a mail-out campaign; and, delivering a number of face-to-face presentations to registered charities .
• October to December 2013: Creating and releasing short videos that will be uploaded to the CRA's Web site and YouTube.
MONITORING AND COMPLIANCE ACTIVITIES
In the summer of 2012, the Directorate assembled a multi-disciplinary team to conduct increased monitoring and compliance activities with respect to the political activities of registered charities. The team established a framework within which these activities will be conducted. The framework describes monitoring and screening functions, as well as a range of interventions that could be applied. Depending on the circumstances, these interventions could include a full audit, a focused political activities audit, office review/monitoring, transfer to regular audit, notification of an error in Form T30l 0 reporting, or no action required. The framework clearly sets out the criteria that must be considered and applied by the team when selecting a particular intervention.
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The audit of six organizations engaged in political activities currently in progress will continue to be handled by this new team. The team will also initiate five new audits of organizations based on the compliance framework by March 31, 2013. The framework has been established to ensure the process is fair, consistent, and transparent.
In 2013-2014, the Directorate will use the framework to identify an additional 20 audits, and they will be initiated. The screening of files will continue and be ongoing over the next four years.
A thorough audit of a registered charity is often complex and may be followed by legal challenges. The Directorate will learn from these audits and use this business intelligence to improve future implementation plans.
Attached for your information is the Political Activities Education and Information Plan, the Compliance Framework for Files with Identified Political Activities, the Budget 2012 Political Activities Project Performance Management Framework, and the Budget 2012 Political Activities Critical Path and associated Timeline.
Should you require additional information, please do not hesitate to contact me at 613 957-3708 or Ms. Cathy Hawara, Director General, Charities Directorate at 613 954-0931.
Brian McCauley Assistant Commissioner Legislative Policy and Regulatory Affairs Branch
Attachments
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DRAFT Budget 2012 Political Activities Critical Path November 1, 2012
PROTECTED "B"
Year 1: 2012-2013
October-December January-March
2012 2013
Transparency/ • Revise all publications to include political activities content: • Release revised publications:
Guide T4033, Campleting the Registered Charity 0 Guide T4033
0
Infarmatian Return 0 Form T1236 0 Form RC297
0 Form T1236, Qualified Danees Warksheet / Amaunts Provided ta Other Organizatians
0 Form RC297, Impartant infarmatian far yaur charity (this document is an insert that is included with all registration letters for new cha rities)
• Sign off on form and final system changes for t he cha rities program database changes
• Develop performance indica tors to measu re the im pact of se lect initiatives undertaken
Education and • Establish principles on political activities gu idance products - • Make information package on political activities available at
information clarify limits and add explanatory boxes to CPS-022, Palicy the end of Ja nua ry Statement - Palitical Activities • Develop communication products on key political activity
• Develop information package on political activities, includi ng: messages for registered charities
0 Presentation
0 Fact sheets
0 Q&A's
• Communicate impact and changes of Budget 2012 to Directorate staff
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DRAFT Budget 2012 Political Activities Critical Path November 1, 2012
PROTECTED "B"
Year 1: 2012-2013
October-December January-March
2012 2013
Monitoring and • Select organizations for audit based on compliance framework • Continue with file screening
compliance 0 Charities from across the entire spectrum of charitable • Implement system changes to capture this new workload data activities will be included in review and audit activi ties • Develop a process to handle the files with reporting errors, and
0 Organizations will be selected from across Canada begin to action those files
0 File selection process for reviews and audits will be • Initia te office reviews/monitoring of identified files and clearly documented develop a process to handle these files
• Develop new training material and provide trai ni ng to auditors and team leaders in the field who will be auditing orga nizations engaged in political activities
• Advance audits already in progress (6 audits)
• Start five new audits of organiza t ions identified through the
screening process
• Develop tools to help the auditors in their audits
• Develop system changes to capture this new workload data
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DRAFT Budget 2012 Political Activities Critical Path November 1, 2012
Monitoring • Begin some of the 20 files selected • Va lidate performa nce
and for audit for 2013-2014 indicators
compliance 0 Assess lessons
lea rned fro m
rollout
0 Adjust plan
J accordingly ,
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October 9, 2012
Compliance Framework For Files with Identified Political Activities
Introduction
Budget 2012 provided new resources for increased education and compliance activities by the Charities Directorate in the area of political activities. As the Directorate develops its work plans, it will be important to be mindful of a number of considerations and challenges, including:
the existing complexities in understanding and applying rules related to political activity;
the public perception of political involvement in the audit selection process;
the difficulty of managing high-profile audits; and
the need to reach a diverse audience (charities, legal representatives, umbrella organizations, the media and the public) .
With respect to the increased compliance activities, the Directorate will rely on the existing compliance framework. However, it will be important to manage the work more closely and adapt existing tools as necessary to deal with the inherent complexity and political sensitivity of these reviews and audits.
All Charities Directorate activities will be based on the following principles:
Charities from across the entire spectrum of charitable activity will be included in review and audit activities.
File selection process for reviews and audits will be clearly documented.
Our "educate first" approach will continue to be reflected in our overall approach to political activities, when appropriate.
Increased compliance activities
The Compliance Division of the Charities Directorate has created a new Activities Section to conduct increased screening, monitoring and auditing of organizations who engage in political activities. Sixty audits (including full and focused audits) will be started in the next four years and divided as follows:
10 files in year 1 (2012-2013) 20 files in year 2 (2013-2014) 20 files in year 3 (2014-2015) 10 files in year 4 (2015-2016)
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Process
A process has been established in order for file selection to be conducted in a fair, consistent and transparent manner. The following describes the sources from which the organizations will be identified, the criteria that will be used to select files for further action and what possible screening decisions, interventions and outcomes can be expected following screening.
"Screening" is defined as the analysis and research of available information with respect to organizations, leading to a decision regarding the need for further action.
Screening
a) Sources
Files with political activities may be identified through a number of different sources.
T3010 Organizations who have reported engaging in political activities (line 2400 and/or 5030 on their T301 0).
Leads / referrals Leads received from the public on organizations engaged in political activities or referrals from other divisions of the Charities Directorate.
Internal Files transferred from within the Compliance Division transfers 1 (i .e. , random audit, office audit, re,:)ular aUdit). Related files/ Related files found through the course of an audit, which research have not been previously ident ified. Media analysis Organizations identified through the media which do not
fall under the leads cate,:)ory. Registration Organizations identified at the time of registration as letters with a engaging in political activities, and as a result of which, a political political activities caution (CP 24) was included in their activities caution registration letter2.
b) Screening Criteria
Over the next four years, all organizations engaged in political activities identified through the sources noted above will be screened. In view of the time remaining in this fiscal period, all files will be screened in 2012-13, with the exception of organizations who have reported conducting political activities on their T301 O. For this last category, screening will be limited to organizations meeting the following criteria:
1 For systems purposes (CTS and AIMS), this source will be identified as "workload". 2 A process is being developed for CTS to identify these organizations. Since the process is not yet developed, this
source will not be considered during the first year.
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1. Balance - regional
Organizations will be selected from across Canada.
It is important to note that although regional balance will most likely be achieved in year 1, our research and audit findings might reveal that certain regions of the country are home to more charities conducting political activities. This framework will continue to evolve to reflect those findings.
2. Balance - sector segments
Organizations falling under all four heads of charity are allowed to engage in political activities within certain limits. Therefore, organizations will be selected from all four heads of charity: the relief of poverty, the advancement of religion, the advancement of education and certain other purposes that benefit the community in a way the courts have deemed charitable . As a result, the selected organizations will pursue a wide variety of activities/purposes (e.g., anti-poverty groups; churches/religious groups; universities and think tanks; and health, right to life groups, animal welfare, environmental organizations and human rights.)
As with the previous criteria, our research and findings might reveal that organizations engaged in political activities are more likely to fall within certain heads of charity. This framework wi ll continue to evolve to reflect those findings.
3. Quantum/Material ity
Charities that have reported spending over fo r political activities (line 5030 of their T3010) will be screened. 16(1 )(c)
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c) Screening decisions
The screening of files will lead to one of the following possible decisions:
Screening finding Screening decision Possible Outcomes Both the regular charitable Full audit Revocation, sanctions, activities and political activities compliance agreement, appear to have non- education letter. compliance issues. 3
The regular activities appear Focused political Revocation, sanctions, charitable but there appears to activities audit compliance agreement, be non-compliance issues with education letter. the political activities. If, during the course of an audit,
the issues appear to affect the regular activities/purpose and are not restricted only to the political activities of the charity, the audit will be expanded to a full audit.
The regular activities appear Office review/ Reminder letter, with reference charitable and the political monitoring to obtain more information from activities appear to have minor our web/information sessions as issues4 or appear to be necessary. increasing or changing. The organization's name may ,
also be sent to the Outreach Team for further action and/or the file may be monitored for future compliance.
It is apparent that the T3010 report ing Letter, asking them to contact organization does not engage error letters us to have the error corrected. in political activities, yet The letter will also include answered "yes" on line 2400 reference to our web/ and/or placed an amount on information sessions as line 5030 of their return. necessary. No issues have been identified Transfer to regular Transfer to another section of with the political activities, but audit the Compliance Division. potential problems with an organization's objects and/or regular activities have been identified. No issues have been identified No action No action with the political activities and objects/activities.
3 Examples of non-compliance: partisan political activities; political activities exceed 10 %; political activities have
become the organization's main purpose 4 Example of minor issues: political activities are close to 10%; possible lack of linkage to purpose
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Screening may lead to more than 60 files referred to audit (full and focused audits). In that event, the following factors will be taken into consideration in order to select the 60 organizations to be audited as part of this initiative:
• Available resources • Balance - regional • Balance - sector segments • Severity of non-compliance • Materiality (amount)
Any files that have been identified for audit but not assigned will be referred to the Charities Directorate's regular audit program, for possible audit at a future date. The decision to audit at that time will depend on available resources and a risk-based assessment of all non-compliant files.
Documentation
All research completed at the screening stage will be documented and included in the charity's official file, regardless of the screening decision. The reasons for selecting a file for audit/monitoring (including the criteria applied) will be fully and clearly documented. As is the usual practice, all audit/monitoring research, results and outcomes of audits will also be documented on fi le.
Finally, as mentioned previously, this compliance framework will be an evergreen document. The processes described herein will be adjusted when necessary as the work progresses and our understanding of trends and compliance issues continues to grow.
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Charities Directorate Political Activities Education and Information Plan
Issue: On March 29, 2012, the Minister of Finance presented the 2012 federal budget. There were several proposed measures related to reporting, compliance and transparency, for political activities carried on by registered charities. The new measures came into effect on June 29, 2012, when the legislation received Royal Assent.
Registered charities are permitted to take part in a limited amount of political activities if th ey are non-partisa n and connected and subordinate to the organization's purpose. In
introducing the changes in Budget 2012, the Government confirmed its support for the existing rules but also took steps to:
• Ensure that all funding intended for political activities is reported in a cha rity's annual information return; and
• Increase transparency by requiring more information about political act ivities, including the extent to which funding from foreign sources is used to carryon political activities.
Objectives: to provide information about the requirements related to political activiti es for registered charities
Audience: Registered charities, umbrella organizations, head bodies, professional associations, and Web sit e users.
Key Messaging:
• The Government recognizes that charities make a valuable contribution to the development of public policy in Canada and accordingly, the Income Tax Act (ITA) continues to allow charities to engage in a limited amount of political activities.
• The Government also recognizes that charities provide a va lua ble cont ribution to our communities and encourages Canadians to donate generously.
• As the federal regulator of charities, the Canada Revenue Agency has an obligation to ensure that registered charities operate in compliance with the ITA.
• The measures announced in Budget 2012 will provide more guidance to cha rit ies to ensure they are operating within the law and more transparency for Canadians who donate so generously.
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Strategic Partnerships:
The Charities Directorate will continue to partner with intermediaries such as umbrella organizations, head bodies and allied professional associations to reach the charitable sector and to provide feedback on behalf of the sector both at the development and the delivery stage of our education and information activities/products.
We will engage other federal departments/agencies and provincial governments as well.
Roles and Responsibilities:
Charities Directorate:
• Developing education, communication and engagement activities and products related to political activities.
Public Affairs Branch:
• Working in partnership with the Charities Directorate to develop messages; and
• Ensuring that language requirements are met.
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Charities Directorate Political Activities Education and Information Plan
Activity/ Activity/
Product Roll out Product
Description Target Audience Objective Lead Stakeholders Status Date
Revised Charities Update the Charities information All Registered Raise awareness and provide Completed
Q3 - 2012-13 Information session presentation with a slide Charities information on the rules CISD Session on Budget 2012. governing for PA Presentation ~ ,
An information package that w ill Registered Charities
To build on and broaden our provide education products for reach and the effectiveness use by the targeted audience at of our education and PPLD- • Allied conferences, seminars and
Umbrella communication activities Presentation, Professionals
organ isations/Head workshops. It will include the Facts Sheets • Lawyers
Bodies/Professional Q4 - 2012-13 PA Information following: and Qs/As • Accountants
Associations Package Take advantage of the forums • Consultants
• Presentation with that intermediaries and the CISD-speaker's notes;
Media media have to inform and Checklist • PAB
• Fact Sheets; educate the sector Parliamentarians
• Qs & As; and
• Checklist - TBD.
Q4 - 2012-13 Registration The RC297, Important Newly Registered Newly registered charities will
CISD/ADM Package Information for Your Charity that Charities be aware of the rules
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Activity/ Activity/
Product Roll out Product
Description Target Audience Objective Lead Stakeholders Status Date
is inserted with all registration governing PA letters will include a paragraph detailing PA messaging with a Web link to the related guidance and information package. , Starting in January 2013, a "What's New" will be included on
13010-2 -the cover page (RC244). It will
Registered Charity
include both PA and other All Registered Raise awareness of the key Q4 - 2012-13
Information changes to the 13010 and related Charities elements in the rules CISO PAB
Return Mail-forms. It will be the exact wording governing PA
out from the Guide T4033-2, Completing the Registered Charity Information Return.
Provide gen eral information A postcard or pamphlet that on th e rules governing PA to illustrates the different
All Registered every registered charity in
Q1- 2013-14 Mail-out categories of activities Cha rities
Canada, including those who CISO (prohibited, political, charitab le) do not rely on the internet PAB
and the key PA messages.
All Registered A one hour interactive webinar Charities based on the
Provide information on the Q1- 2013-14 Webinar presentation/speakers notes in Umbrella
rules governing for PA CISO PAB
the PA Information Package. organisations/Head Bodies/Professional Associations
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Activity/ Activity/
Product Roll out Product
Description Target Audience Objective Lead Stakeholders Status Date
All Registered Charities
Convert the webinar to a webcast Provide information on the
Q1- 2013-14 Webcast and upload on the Web site Umbrella rules governing for PA
CISD PAB (including YouTube) organisations/Head
Bodies/Professional Associations
All Registered Charities
A series of 2 to 3 minute videos Umbrella Utilize social media to raise Q3 - 2013-2014 Video which will outline organisations/Head awaren ess of the rules CISD PAB
the rules governing PA. Bodies / Professional governing PA. Associations
Public ' ,
Where appropriate, . '" representatives of the Charities All Registered Directorate will do presentat ions Cha riti es at various conferences or will
Raise awareness and provide provide the PA information Umbrella Intermediaries
Ongoing Conferences package. organisations/Head
detailed information on the TBD
Bodies/ requirements for PA
See Annex 1 for the list of Professional conferences. Association
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Raise awareness about
Newsletter Use the Charities Connection All Registered Budget 2012 PA changes and
Ongoing newsletter to promote the Charities available communications
CISD release of new communications and education and education activities/products activiti es/products
Raise awareness about Update the Web site and all
All Registered Budget 2012 PA changes and
Web site/ publications for related PA available communications PAB Ongoing
publications communications and education Charities
and education CISD
prod ucts/activiti es. activiti es/products
Registered Charities
TBD Targeted PA
TBD who received a Provide information on the
TBD Follow-up reminder letter from rules governing for PA
Com pliance Division
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Annex 1
List of Conferences
• Philanthropic Foundations of Canada (Vancouver) - October 3, 2012
• Church & Charity Law Seminar (Toronto) - Carters - November 15, 2012
• Canadian Charity Law Institute (Toronto) - Mark Blumberg - November 28, 2012
• Canadian Council on Refugees (Toronto) - November 29,2012
• Church & Charity Law Seminar (Ottawa) - February 2013
• Canadian Association of Gift Planners (Gatineau) - April 18, 2013
• Vitalize 2013 (Edmonton) - June 13-15, 2013
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DRAFT
November 26,2012
Budget 2012 Political Activities Performance Measurement Framework
1. Introduction
Budget 2012 recognized that registered charities make a valuable contribution to t he development of public policy. However, it also expressed
concern that some registered charities may not be respecting the ru les rega rding politica l activities. The Budget sets out a series of legislative
and administrative initiatives to address these concerns. This performance framework will provide the means to track, analyse, and report on
the im pact of these initiatives over time.
2. Profile
• Purpose - Budget 2012 states the overall objective of the politica I activities initiatives as fo llows:
"Economic Action Plan 2012 proposes measures to ensure that charities devote t hei r resources primarily to charitable rather than
political activities, and to enhance public tra nsparency and accountability in this area"
• To accomplish this objective, Budget 2012 mandates the eRA to :
o "Enhance its education and compliance activities with respect to political activities by charities."
o "Improve transparency by requiring charities to provide more information on their political activities, including the extent to
which these are funded by foreign sources."
• Budget 2012 initiatives can be summarized as:
o Legislation and policy - the basic rules remain generally the same; partisan activities and political purposes are prohibited, while
limited non-partisan political activities are acceptable. The new initiatives relate to:
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• Rules - the Income Tax Act was amended to reflect that where a gift is made by a charity and it can reasonably be
considered that a purpose of the gift was to support the political activities of a qualified donee, the gift will be
considered to be an expenditure made by the charity on political activities.
• Sa nctions - two new sa nctions were added; a one year suspension of tax-receipting privileges for exceeding politica I
activities limits, and a tax-receipting suspension for failing to provide complete and accurate information in relation to
any aspect of an annual return that will only be lifted once the charity submits the information in question.
• Transparency - introduced new reporting requirem ents on types of polit ical activities, foreign donations received for
political activities, and gifts to qualified donees for pol itical activi t ies.
o Administrative measures
• Education and information activities to ensure registered charities have the guidance they need to comply with political
activities regulatory requirements.
• An increase in compliance and monitoring activit ies to detect and address failure to respect the political activities
regulatory requirements.
• Charities Directorate impact - implemen t ing these initiat ives w ill allow the Directorate to fu rther its regulatory and business intelligence
goals by developing a more com prehensive understa ndi ng of registered charities' pol itical involvement. This will assist the Directorate
in:
o identifying issues regarding the interpretatio n and a pp lication of t he ru les governing politica I activities;
o designing guidance products;
o drafting key messages for sector outreach and determining their effectiveness;
o planning public communications; and,
o ensuring Directorate resources are efficiently allocated to promote awareness of, and compliance with, the rules regarding
political activities at every stage of registered status.
• Roles and responsibilities:
o Corporate and Information Programs Division (CIPD) - work with Information Technology Branch (ITB) to develop and
implement the required IT systems enhancements
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o Client Interface and Service Division (CISD) - produce a revised 13010 and related publications as well as explanatory outreach
material about the initiatives in collaboration with Public Affairs Branch (EPMD) to present/distribute to registered charities, and
prepare responses related to Issues Management (QPRs, MinMail, Fact Sheets, Media Inquiries)
o Compliance Division (Compliance) - conduct reviews and audits of registered charities selected from six main sources:
• Organizations that have reported engaging in political activities
• Leads received from the public on organizations engaged in politica I activi t ies or referra Is from other divisions of the
Directorate
• Internal transfers received from within the Compliance
• Files found through the course of aud its
• Organizations identified through the media w hich do not fal l under the leads category
• Organizations identified at the time of registration as engaging in pol itical activities, for which a caution regarding
political activities was included in their registration letter
Performance measures wil l be based on the number of reviews and audits conducted and their outcomes - where
applicable, the seriousness of an organization's political activity- related non-compliance will help determine which
intervention is appropriate
o Other divisions - the Review and Analysis Division and t he Assessment, Determination, and Monitoring Division will participate
in working groups and provide input as required
o Policy, Planning, and Legislation Division (PPLD) - develop and review new political activities education and information
materials, assess the requirements for communicating initiatives to the public, and other provide support for initiatives as
required
• Governance structure
The Political Activities Project Steering Committee will be responsible for project governance and will report to senior management
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3. Logic Model
Note: CRA corporate guidance on performance measurement refers to three classes of outcomes: Immediate - first consequences on target
population, often simply awareness of output / Intermediate - changes in behaviour in target population / Ultimate - changes in societal
behaviour beyond initial target population. The first two classes of outcome are most relevant for this framework.
Transpa rency PPLO - ~ Developed political activities content for Info rm at ion is co llected from TBO - to begi n
CIPO - $ 69(1)(g)" (,) publications that addresses: registered charities and made behavioural
• Reporting requirements on types of available to the public assessment after S 69(1 )(g) re (a) tota I political activities first full year of
• Reporting on foreign donations for Indicator: filing - fall of 2014
political activities (total amou nt, amount of each gift, pu rpose and Track completion of political activities
country origin) rela ted lines on forms
• Report ing on gifts to qual ified donees for pol itical activi ties [Note t hat a num ber of the indicators
outl ined under Education and
Revised publications: Information may also help to
• RC244 cover page for printed an nual illu minate success of our efforts to
retu rn increa se transparency]
• Form 13010, Registered Charity Infarmatian Return
• Guide T4033, Campleting the Registered Charity Infarmatian Return
• Form T1236, Qualified Danees Warksheet / Amaunts Provided ta Other Organizatians
• Form RC297, Impartant infarmatian far yaur charity (th is docu ment is an insert that is included with all
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registration letters for new charities)
nOl0s com pleted by cha rities that contain new political activities information posted on Web page
Education CISO - $ 69(1)(g) re (a) October - December 2012: Additional information about political TBD - to begi n and activities is available to registered assessing information
Established principles for political cha rities a nd public behavioural change
activities guida nce products - cia rify after delivery of
limits and add explanatory boxes to CPs- Indicators : products -
022, Policy Statement - Politicol approximately fall
Activities Track the number of hits on political 2015 activities related Web pages
Developed info rmatio n package on Track number of 1-800 telephone political activities enqu iries about po li t ical activities on
Presenta tion an ongoing basis
Fact sheets
Q& A's Prepa re case study to eva luate the effective ness of working with intermed ia ries and track distribution
Communicated im pact and changes of of po litical materials through them Budget 2012 to Directorate staff in Dece mber Charity Business Intelligence Use online surveys of selected Bulletin webinar and webcast participants to
determine their before and after January - March 2013: levels of political activities awareness
Made information package on political Track the use of webcast and video activities available materials Developed communication product on key political activity messages for Include questions on before and after registered cha rities levels of awareness at information
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sessions April- June 2013:
Track the completion of political Made the new communication product activity relevant lines in CARE on key political activity messages available to registered charities Track take up of political activities
initiatives in the media Conducted a webinar on political activities
Converted webinar to a webcast and uploaded it to the CRA's Web site and
YouTube
Updated the Charities Information Session presentations (Face-to-face presentations for registered charit ies in cities across the country) as requ ired
October - December 2013 :
Created short videos outlining t he ru les governing political activities and posted them on Web page
Monitoring Compliance - Organizations selected for audit based Political activities non-compliance is TBD - as level of
and $ 69(1)(g) re (a) on compliance framework and risk addressed within parameters of non-compliance compliance criteria compliance framework among all
- Includes registered charities field audit • Charities from across the entire Indicator: is unknown, we
spectrum of charitable activities ca n not assess
were included in review and audit Track data on files screened, behavioural
activities reviewed, and audited using the changes globally.
• Organizations were selected from Charities Tracking System Will limit
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across Ca nada assessment to
• File selection process for reviews Monitor random audits for political group of charities
and audits was clearly documented activities issues screened, reviewed, and audited and
Training materials developed and will be based on
training provided to auditors and team results of leaders in the field who will be auditing interventions as this
organizations engaged in political information
activities becomes available.
Tools developed to help auditors in their audits
IT systems changed to capture new workload data
Process developed to ha ndle files with reporting errors
Process developed for ha nd ling files fro m office reviews and monitoring
4. Performance measurement strategy
• Performa nce indicators - Considerations:
o Uses and Users - CRA upper management will be the primary users of reports arising from analysis of indicators.
o Com pa rability - a limited year-over-year compa rison in terms of total number of charities engaged in politica I activities will be
possible. Additional data will be available during second year and forward for new political activities fields on the 13010.
o Tim ing - will depend on nature of indicator a nd governance requirements (TBD by Political Activities Project Steering
Committee). Generally, provide a baseline (if possible) and then measure again at 3 and 5 years after implementation.
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o Balancing- we will use both quantitative and qualitative measures. Our indicators will include T3010 data, audit results, surveys,
questionnaires, etc. We may also refer to data and analysis generated by external parties.
• Data collection - Considerations:
o Method of collection - T3010 data, audit data, surveys, questionna ires, and other sources as required, will be the primary
sources of measurement information.
o Responsibilities - the Political Activities Project Steering Committee wil l esta blish a schedule for data collection. Additional data
requirements may be identified as the project progresses.
• PPLD/CIPD/ITB/PAB - T3010 data, public surveys and questionnaires
• Compliance - audit-related trends, fi nd ings, and results
• CISD/PAB - sector surveys and question na ires
• Analysis and use of data - Considerations:
o Describing and counting - using T3010 data, audit data , survey, and questionnaire responses
o Aggregating - detecti ng patterns or links in the data
o Disaggregating - brea king down data by re leva nt categories, such type, income/expenditures, a nd activities of cha rities
o Comparability - potential to compa re with ot her ju risdictions and over ti me
o Independent assessments - we wi ll co nsider using assessments from external experts, such as academics, auditors, and
consultants
5. Prepare an evaluation strategy
• The Political Activities Project Steering Committee will obtain feedback about the project while it is ongoing. The Committee will consult
with stakeholders and prepare a schedule for interim reporting, which will be conducted on an informal basis. If an evaluation indicates
that adjustments to the project or performance measures are warranted, the Committee will discuss this with stakeholders.
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• The Committee will produce an evaluation once the major components of the project have been implemented to assess whether it has
fulfilled its initial objectives (based on outputs and immediate outcomes). The Committee will perform follow-up evaluations at 3 and 5
year intervals as appropriate (based on intermediate outcomes) to assess the project's impact over time.
6. Prepare a reporting strategy
• Considerations:
o Timelines - project reporting cycle will be established by the Political Activit ies Project Steering Committee
o Selecting evidence - we will tell a balanced story t hat includes the best evidence reasonably available to support conclusions
o Discussing cause and effect - we will explain cause and effect to link outputs to outcomes, and identify other relevant influences
o Address attribution - we will make an argument for certain measures where conclusive evidence is not available
7. Conclusion
The Political Activities Project Steering Committee wi ll meet to address governance, t imel ine, and reporting requirements. Once
performance measures are approved, the Committee wi ll draft and implement a f inal logical model and project plan.
