Annual Report on the Access to Information Act 2017-2018

Table of Contents

• Introduction
• The Public Prosecution Service of Canada
• Commissioner of Canada Elections
• ATIP Office
  • Organizational structure
• Delegated authorities
• Interpretation of the statistical report
  • Requests received under the Access to Information Act
    • Number of requests
    • Subject matter
    • Sources of requests
    • Informal requests
  • Requests closed during the fiscal year
    • Disposition of requests
    • Number of pages processed
    • Completion time
    • Exemptions
    • Exclusions
    • Format of information released
    • Complexity
    • Deemed refusals
    • Requests for translation
  • Extensions
  • Fees
  • Consultations received from other government institutions and organizations
    • Number of consultations
    • Sources of consultations
    • Disposition and recommendations
    • Completion time
  • Completion time of consultations on Cabinet confidences
  • Resources related to the Access to Information Act
• Training activities
• Policies, guidelines, procedures and initiatives
  • ATIP governance structure
  • Information about Programs and Information Holdings
  • Initiatives
• Complaints, audits and investigations
• Court action
• Monitoring compliance
• Reading room
• Appendix A – Delegation Order
• Appendix B – Statistical Report on the Access to Information Act

Introduction

The Access to Information Act (the Act) came into force on July 1, 1983. The purpose of the Act is to provide a right of access to information in records under the control of a government institution in accordance with the principles that government information should be available to the public, that necessary exceptions to the right of access should be limited and specific, and that decisions on the disclosure of government information should be reviewed independently of government.

The Public Prosecution Service of Canada (PPSC) became subject to the Act when it was established as an independent organization on December 12, 2006, with the coming into force of the Director of Public Prosecutions Act (Part 3 of the Federal Accountability Act).

Pursuant to section 72 of the Act, this 2017-2018 Annual Report on the Access to Information Act has been prepared for tabling in the House of Commons and the Senate. This Report provides an analysis of the information contained in the PPSC’s Statistical Report on the Access to Information Act. In addition, it reports on emerging trends, training activities, internal policies, guidelines and procedures with respect to the PPSC’s administration of the Act.

The Public Prosecution Service of Canada

The PPSC’s mandate is set out in the Director of Public Prosecutions Act (DPPA). The DPPA empowers the Director of Public Prosecutions (DPP) as Deputy Attorney General of Canada to:

• initiate and conduct federal prosecutions;
• intervene in proceedings that raise a question of public interest that may affect the conduct of prosecutions or related investigations;
• issue guidelines to federal prosecutors;
• advise law enforcement agencies or investigative bodies on general matters relating to prosecutions and on particular investigations that may lead to prosecutions;
• communicate with the media and the public on all matters that involve the initiation and conduct of prosecutions;
• exercise the authority of the Attorney General of Canada in respect of private prosecutions; and
• exercise any other power or carry out any other duty or function assigned by the Attorney General of Canada that is compatible with the office of the DPP.

The DPPA also empowers the DPP to:

• initiate and conduct prosecutions under the Canada Elections Act; and
• act, when requested by the Attorney General of Canada, in matters under the Extradition Act and the Mutual Legal Assistance in Criminal Matters Act.

The DPP has the rank and status of a deputy head of a department, and in this capacity is responsible for the management of the PPSC as a distinct governmental organization.

Commissioner of Canada Elections

The Commissioner of Canada Elections (CCE) is responsible for ensuring that the Canada Elections Act and the Referendum Act are complied with and enforced. While the CCE is part of the PPSC, it remains operationally independent.

All access to information requests and consultations regarding the CCE are processed by the PPSC’s ATIP Office.

ATIP Office

The ATIP Office holds primary responsibility for the implementation and administration of the Access to Information Act. The Office deals directly with the public in relation to access to information (ATI) requests, liaises with Offices of Primary Interest to prepare responses, and serves as the centre of expertise for access to information and privacy (ATIP) within the PPSC.

The ATIP Office fulfills its responsibilities by:

• processing ATI requests in accordance with the Act, its Regulations and the Treasury Board of Canada Secretariat (TBS)’s policies, directives and guidelines;
• responding to consultations submitted by other federal institutions or other levels of government on PPSC records being considered for release;
• providing advice to PPSC managers and employees regarding the application and interpretation of the Act, its Regulations and relevant case law;
• responding to requests received from other government institutions for the review of solicitor-client privilege in records related to criminal proceedings in which the PPSC is involved;
• reviewing PPSC policies, procedures and agreements to ensure that they comply with the requirements of the Act and making recommendations for amendments;
• monitoring the PPSC’s compliance with the Act, its Regulations and TBS policies, directives and guidelines;
• communicating with investigators of the Office of the Information Commissioner of Canada to resolve complaints filed against the PPSC;
• reviewing documents relevant to proactive disclosure, such as audits and evaluations as well as contracts over $25,000, prior to their publication on the PPSC’s website, in order to ensure that they do not contain information that is subject to exemptions or exclusions under the Act;
• delivering training sessions intended to familiarize PPSC managers and employees with the requirements of the Act, its Regulations and the TBS’s policies, directives and guidelines;
• updating the PPSC’s chapter of the federal government’s Information About Programs and Information Holdings publication (formerly known as Info Source: Sources of Government and Employee Information);
• submitting an annual statistical report on the administration of the Act to TBS;
• preparing an annual report on the administration of the Act for tabling in both Houses of Parliament; and
• posting summaries of completed ATI requests on the Open Government portal.

Organizational structure

The Director, Corporate Planning and External Relations Division (CPERD), acts as the PPSC’s ATIP Coordinator. Counsel for the CPERD provides legal advice to the ATIP Coordinator, the ATIP Office and PPSC managers on the application and interpretation of the Act and relevant case law.

During the period from April 1, 2017, to March 31, 2018, the ATIP Office comprised a Manager, a Senior Advisor, two Advisors and one ATIP Officer, who was previously classified as a Junior ATIP Analyst.

During this fiscal year, the ATIP Office had the additional support of a part-time casual employee and one student.

Delegated Authorities

Pursuant to section 73 of the Act, the head of a government institution may, by order, designate one or more officers or employees of that institution to exercise or perform any of the powers, duties or functions of the head of the institution under the Act.

The DPP, as the “head of institution,” has designated the authority to exercise the powers and to perform the duties and functions conferred to her under the Act to the Director, Corporate Planning and External Relations Division (CPERD), as well as the Acting Director General, Corporate Services, and the ATIP Manager (Delegation Order in Appendix A). The ATIP Manager exercises this authority in the absence of the Director, CPERD. The Acting Director General, Corporate Services, exercises this authority in the absence of both the Director, CPERD, and the ATIP Manager.

Interpretation of the Statistical Report

The following section provides a summary and analysis of the information contained in the 2017-2018 Statistical Report on the Access to Information Act in Appendix B of this report.

Requests received under the Access to Information Act

Number of requests

The PPSC received 43 formal access to information requests in fiscal year 2017-2018, which reflects a 4% decrease from the number of formal requests received in the previous fiscal year. Additionally, 12 requests were carried forward from 2016-2017.

The PPSC has received a total of 334 requests since December 12, 2006. Despite some fluctuations, overall, the number of requests received has seen an increase since the creation of the PPSC in 2006.

Note: As the PPSC was created on December 12, 2006, data for 2006-2007 only reflects a three-month period. Additionally, since 2014-2015, the number of requests received no longer includes those that are treated informally. These requests are now reported separately as informal requests.

Subject matter

The subject matter of the requests received in 2017-2018 are quite varied, often involving intersecting themes; however, a few trends can be observed.

Reflecting the mandate of the PPSC, approximately half of requests (51%) related to criminal and regulatory prosecutions and investigations.

Another noticeable theme was the type of information that applicants were interested in receiving: 47% of received requests sought to obtain statistical data on various topics, such as legal costs, expenses, prosecution trends, the PPSC’s staff resources, criminal charges, and fine recovery.

Also of interest to applicants was human resources-related information. Of the total requests received during this reporting period, 19% sought information about the PPSC’s workforce, classifications, selection processes and staffing contracts.

Sources of requests

During the 2017-2018 fiscal period, 47% of requests were from the general public. This aligns with the general trend of the past five fiscal years, where the greatest proportion of the PPSC’s requests (56%) have originated from the general public.

The media accounted for the next greatest source of applicants for the PPSC in 2017-2018, at 23% of all requests that were received. This is a 16% proportional increase from the previous fiscal year and is a level not matched since 2013-2014.

Informal requests

An informal request is any request for information made to the ATIP Office of a government institution that is not processed under the Act. Fees cannot be charged for informal requests, and there are no deadlines for response. Additionally, the applicant has no statutory right of complaint to the Office of the Information Commissioner of Canada.

The majority of the PPSC’s informal requests are received through the online Open Government portal, where the PPSC publishes a monthly summary of completed ATI requests. Applicants have the ability to submit an informal request through the Portal for any records that were released in response to completed requests.

During the 2017-2018 fiscal period, the PPSC processed 33 informal requests, representing nearly five times the number in 2016-2017, during which only seven (7) informal requests were processed.

Of the 33 informal requests received during the reporting period, the PPSC responded within the first fifteen days of receipt 85% of the time. All informal requests were responded to within 30 days of receipt.

Throughout 2017-2018, the ATIP Office prepared responses to Parliamentary Questions, and provided advice and recommendations to PPSC employees regarding reports on proactive disclosure, audit, harassment, and administrative investigations. The ATIP Office reviewed these reports to ensure that sensitive information, such as information that is subject to solicitor-client privilege and personal information, was identified and protected prior to their publication or disclosure to the relevant parties.

Requests closed during the fiscal year

Disposition of requests

During the 2017-2018 fiscal period, the PPSC responded to 49 formal access to information requests in fiscal year 2017-2018, which represents a 40% increase from the previous fiscal year. Six (6) requests remained outstanding by March 31, 2018, and were carried over to the next fiscal year.

The disposition of closed requests during this reporting period is as follows:

Records were fully or partially disclosed in response to 31 or 63% of all requests closed in 2017-2018. This is an 11% proportional decrease from the previous fiscal year, in which 26 of 35 requests resulted in disclosure. However, the percentage for this reporting period is comparable to the general trend of the last five fiscal years, in which an average of 65% of closed requests have resulted in a full or partial disclosure of records to the applicants.

During this reporting period, two (2) requests were closed in 2017-2018 in which all records were exempted. Other requests that did not result in the disclosure of records were as follows:

No records exist

• A total of nine (9) requests could not be processed because no relevant records under the control of the PPSC existed. When possible, applicants were advised of other government institutions that may have records, and were provided with contact information for the purpose of submitting their request.

Request abandoned

• Six (6) requests were abandoned by applicants. In most abandoned cases, clarification is needed from the applicant in order to process their request. When the applicant does not provide clarification, the applicant’s request is deemed abandoned.

Neither confirmed nor denied

• Subsection 10(2) of the Act was invoked in one (1) request, where the PPSC could neither confirm nor deny that records existed. In this case, the PPSC advised the applicant that if the relevant records did exist, they would qualify for exemption under section 16.31 of the Act. Further information on section 16.31 is available in the section about exemptions.

Number of pages processed

For the requests closed in 2017-2018, a total of 10,263 pages were processed for the requests closed in 2017-2018, representing a 30% decrease in volume from the previous fiscal year.

A summary of the pages processed during the previous five fiscal years is as follows:

Completion time

Of the 49 requests closed in 2017-2018, 37 requests were processed within the initial 30-day statutory deadline.

The following is a breakdown of the number of days taken to respond to requests:

Overall, the PPSC has processed 74% of requests closed in the last five fiscal years within 30 days of receipt. In 2013-2014, 60% of requests were processed within 30 days, a rate which has been exceeded in subsequent fiscal years.

Exemptions

The right of access to information in government records is subject to limited and specific exceptions. Limitations to the right of access are set out in sections 13 through 24 of the Act. Section 26 also sets out an administrative exception relating to the publication of information.

The following is a breakdown of the exemptions that were applied by the PPSC in 2017-2018 for closed requests:

Section 16.31 was enacted on October 1, 2014, and authorizes the DPP to refuse the disclosure of any records requested under the Act that contain information that was obtained or created by a person, or on their behalf, who conducts an investigation, examination or review in the performance of the functions of the Commissioner of Canada Elections under the Canada Elections Act. This is the second fiscal period in which the PPSC exercised its authority under section 16.31 of the Act to refuse disclosure.

Over the last five fiscal years, subsection 19(1) [Personal information] and section 23 [Solicitor-client privilege] of the Act were most often invoked by the PPSC when exempting information from disclosure. This reflects the mandate of the PPSC to conduct federal prosecutions, which often involve personal information about individuals, as well as to provide legal advice to law enforcement agencies and investigative bodies on matters relating to prosecutions.

Exclusions

Records or parts thereof to which the Act does not apply are considered to be “excluded.” Pursuant to section 68, the Act does not apply to published material or material available for purchase by the public, library or museum material preserved solely for public record or material placed in Library and Archives Canada. Records containing Confidences of the Queen's Privy Council for Canada that have been in existence for less than 20 years are also excluded from the Act pursuant to section 69.

No exclusions were applied by the PPSC in 2017-2018.

Format of information released

Where records were fully or partially disclosed, information was provided to the applicant electronically, by email or on compact disk, for 55% of requests that were closed in 2017-2018. Paper copies of records were provided in response to the remaining requests that were closed, whether at the request of the applicant or when the records totaled 50 pages or fewer.

Over the last five fiscal periods, 2017-2018 is the first fiscal year in which electronic responses outnumbered paper-based.

Complexity

Due to the nature of the PPSC’s work, processing requests can be challenging and are regularly deemed “complex” based on a number of factors:

• Records held by the PPSC often contain information relating to criminal or regulatory investigations or prosecutions that also frequently involve other organizations at the federal, provincial or territorial level. For this reason, consultations can be required.
• Requests to the PPSC often pertain to high-profile or sensitive topics, and legal advice is often sought in such matters.
• For a majority of requests, the PPSC must retrieve records from across the country.

Deemed refusals

Requests that are not closed within the initial 30-day statutory deadline or within a timeframe covered by an extension provided by the Act are referred to as “deemed refusals.” Further information on the circumstances in which an extension to the original deadline is permitted by the Act is available in the section to follow about extensions.

There were no requests closed as deemed refusals in 2017-2018. Over the last five fiscal years only a total of two (2) or 1% of the access to information requests closed by the PPSC have been deemed refusals.

Requests for translation

The PPSC did not receive any requests from applicants to translate records from one official language to the other in 2017-2018. Similarly, no requests for translations to an official language were received by the PPSC during the last five fiscal years.

Extensions

Section 9 of the Act allows government institutions to extend the 30-day statutory deadline for processing a request in cases where institutions are required to review or search through a large number of records, or when consultations with other institutions or third parties are necessary.

During the 2017-2018 reporting period, 14 extensions were taken for closed requests. This represents a significant increase from the previous fiscal year and is the most extensions taken by the PPSC since 2013-2014. The increase may be partly attributable to the number of consultations with Elections Canada that were required. By comparison, over the last five fiscal years, the PPSC has taken an average of ten (10) extensions each fiscal year.

Of the extensions taken in 2017-2018, 86% were 120 days or less in length.

The following table sets out the lengths of extensions taken and the reasons for them:

Fees

The Act authorizes the collection of fees for certain activities related to the processing of formal requests for information. In addition to the $5.00 application fee, costs related to the search, preparation and reproduction of records may be recovered in accordance with the Access to Information Regulations.

It should be noted that the Treasury Board’s Interim Directive on the Administration of the Access to Information Act, which came into effect on May 5, 2016, directs government institutions to waive all fees prescribed by the Act and the Regulations, other than the application fee set out in paragraph 7(1)(a) of the Regulations.

The PPSC collected a total of $200 in application fees in fiscal year 2017-2018. The organization waived the $5 application fee in four (4) cases.

Per the Interim Directive, no production, programming, preparation or search fees were charged in 2017-2018.

Consultations received from other government institutions and organizations

Number of consultations

The PPSC received 52 consultations from other government institutions and organizations for processing under the Act in fiscal year 2017-2018. This is a 16% increase from the previous fiscal year. Additionally, three (3) consultations were carried forward from 2016-2017.

The PPSC has received a total of 506 access to information consultations since December 12, 2006.

Note: As the PPSC was created on December 12, 2006, data for 2006-2007 only reflects a three-month period.

Sources of consultations

Approximately one third of the consultations received by the PPSC in 2017-2018 were received from the Treasury Board of Canada Secretariat (TBS). This is a 17% increase of consultations received from TBS compared to the previous fiscal year, when TBS was also the top source for consultations. Typically, these consultations do not involve many pages or complex subject matter.

It is important to note that the number of consultations forwarded by any given government institution or organization does not reflect the actual amount of work required to process them. For example, the other major sources of consultations received in 2017-2018 pertained to prosecutions and elections. Unlike TBS consultation files, consultations related to these topics involve a great deal of records and complexity.

The following table and chart identify the number of consultations sent by each government institution or organization:

Disposition and recommendations

The PPSC responded to 50 consultations in fiscal year 2017-2018. Five (5) consultations remained outstanding on March 31, 2018, and were carried over to the next fiscal year.

A total of 7,031 pages were processed to respond to the 50 consultations, which is a significant increase in the number of pages processed compared to the previous fiscal year. Although the PPSC responded to more consultations (55) in 2016-2017, the average size of completed consultations tripled in 2017-2018.

Of the 50 consultations completed in 2017-2018, the PPSC recommended that the other government institutions and organizations disclose the records entirely in 62% of cases. Of the remaining 38% of cases, the PPSC recommended that the records be disclosed in part.

In recent fiscal years, the PPSC’s recommendations with respect to consultations have on average trended towards increased disclosure, whether in full or in part, rather than full exemption of records.

Overall, the PPSC completed 212 consultations over the last five fiscal years, The PPSC recommended full or partial disclosure of records in 92% of consultations and full exemption in 3%. The remaining consultations involved other types of recommendations, such as referring the consulting institution to other government institutions or organizations.

Completion time

Of the 50 consultations completed in 2017-2018, 36 were processed within 30 days of receipt. This is a 28% decrease from the number of consultations processed within the same timeframe in 2016-2017. This decrease may be explained by the change in the average number of pages processed per consultation, which tripled in 2017-2018, as compared to the previous fiscal year.

The remaining consultations completed in 2017-2018 involved ten (10) consultations processed within 31 to 60 days, three (3) consultations processed within 61 and 120 days, and one (1) consultation processed within 121 to 180 days.

Completion time of consultations on Cabinet confidences

No consultations on the application of subsection 69(1) [Cabinet confidence] of the Act were carried out during fiscal year 2017-2018.

Resources related to the Access to Information Act

In fiscal year 2017-2018, the PPSC spent a total of $187,425 administering the Act, of which salaries accounted for 95% ($177,924) of expenditures, while goods and services accounted for the remaining 5% ($9,501).

No overtime expenditures were incurred in 2017-2018.

Training activities

ATIP personnel provided informal learning to employees on an ad hoc basis regarding various matters related to access to information (ATI).

The ATIP Office also regularly provided advice to PPSC officials on responding to ATI requests and the interpretation of the Act.

No formal training or awareness activities were provided to PPSC employees in fiscal year 2017-2018.

Policies, guidelines, procedures and initiatives

ATIP governance structure

The PPSC ATIP Governance Structure was approved by the PPSC’s Executive Council in October 2011. It outlines the reporting relationships within the PPSC and establishes clear responsibilities for decision-making for the purposes of administering the Act.

Information about Programs and Information Holdings

Information about Programs and Information Holdings (formerly known as Info Source: Sources of Government and Employee Information) is published on the Government of Canada’s canada.ca website. It provides information about the functions, programs, activities and related information holdings of government institutions subject to the Access to Information Act and the Privacy Act.

Each year, the PPSC ATIP Office updates information about the PPSC’s activities and information holdings in the publication.

Initiatives

The PPSC did not implement any new policies or initiatives related to access to information (ATI) during fiscal year 2017-2018. However, the PPSC expects to develop new and revised policies and procedures related to ATI throughout the next fiscal year in preparation for government-wide access to information reform, open government initiatives, and the modernization of ATIP digital services.

ATI tools were updated so that the organization may continue to efficiently process requests under the Act. Notably, a new Statement of Completeness form was developed and implemented in 2017-2018. The Statement of Completeness much be completed by PPSC officials each time they are tasked with responding to a request. The form assists in compliance by requiring officials to attest that they have conducting a thorough search for records and provides a useful means for officials to communicate relevant details about the records for the ATIP Office’s consideration when reviewing the records.

Complaints, audits and investigations

Decisions made under the Act are subject to a right of review. This ensures both compliance by government institutions of their ATI obligations and the fair treatment for all requesters. The first level of review is a formal complaint to the Office of the Information Commissioner of Canada (OIC); the second level is an application for judicial review to the Federal Court. The PPSC reviews the outcomes of all OIC investigations and incorporates lessons learned into business processes, where appropriate.

Five (5) complaints pertaining to four (4) requests were filed with the OIC against the PPSC during fiscal year 2017-2018, four (4) of which were still under investigation as of March 31, 2018.

The other complaint was discontinued by the applicant before the end of the fiscal year, along with three (3) other complaints carried over from previous fiscal years. There were (4) discontinued complaints in total.

The PPSC received findings or recommendations from the Commissioner in connection with three (3) other complaints that were carried over from previous fiscal years. The reasons and findings are as follows:

• Two (2) of these complaints pertained to the same set of missing records. The PPSC had provided records in response to previous requests submitted by the applicant. The PPSC agreed to release the records again to the applicant so that the responses to the newer requests could be considered complete. The OIC concluded its investigations accordingly.
• One (1) complaint was deemed to be not well-founded, in which the Commissioner found that the PPSC applied the Act correctly.

There were no recommendations regarding the PPSC’s ATI activities raised by other Agents of Parliament in 2017-2018.

The following table sets out the reasons for the complaints received by the PPSC in 2017-2018, including those carried over from previous fiscal years, as well as the findings of the OIC’s investigations:

Court action

There were no applications for judicial review filed with the Federal Court pursuant to sections 41, 42 and 44 of the Act in fiscal year 2017-2018.

Monitoring compliance

The ATIP Office maintains a comprehensive statistical reporting and performance measurement system. The ATIP Manager meets with the ATIP Coordinator weekly on the status of active requests, complaints and any issues that have arisen.

The ATIP Office also provides reports to PPSC senior management on its activities, caseload and trends related to ATI on an ad hoc basis.

Reading room

Section 8 of the Regulations requires that institutions maintain a reading room where the public can examine records.

The PPSC’s main reading room is located at 160 Elgin Street, Ottawa, Ontario. Individuals who wish to examine records must schedule an appointment with the ATIP Office. Individuals located outside of the National Capital Region can make arrangements through the ATIP Office to examine records at one of its regional offices.

Appendix A – Delegation order

The Director of Public Prosecutions, pursuant to section 73 of the Access to Information Act and section 73 of the Privacy Act, hereby designates the persons holding the positions set out in the schedule hereto, or with respect to the position of Director General, Corporate Services, any person occupying the position on an acting basis, to exercise the powers, duties and functions of the Director as the head of the Office of the Director of Public Prosecution, under the provisions of the Act and related regulations set out in the schedule opposite each position. This designation replaces ail previous delegation orders.

Schedule

Dated, at the City of Ottawa, this 6^th day of November, 2017.

Kathleen Roussel
Director of Public Prosecutions

Appendix B – Statistical report on the access to information act

Name of institution: Public Prosecution Service of Canada

Reporting period: 2017-04-01 to 2018-03-31

Part 1: Requests Under the Access to Information Act

1.1 Number of requests

1.2 Sources of requests

1.3 Informal requests

Note: All requests previously recorded as "treated informally" will now be accounted for in this section only.

Part 2: Requests Closed During the Reporting Period

2.1 Disposition and completion time

2.2 Exemptions

2.3 Exclusions

2.4 Format and information released

2.5 Complexity

2.5.1 Relevant pages processed and disclosed

2.5.2 Relevant pages processed and disclosed by size of requests

2.5.3 Other complexities

2.6 Deemed refusals

2.6.1 Reasons for not meeting statutory deadline

2.6.2 Number of days past deadline

2.7 Requests for translation

Part 3: Extensions

3.1 Reasons for extensions and disposition of requests

3.2 Length of extensions

Part 4: Fees

Part 5: Consultations Received From Other Institutions and Organizations

5.1 Consultations received from other Government of Canada institutions and organizations

5.2 Recommendations and completion time for consultations received from other Government of Canada institutions

5.3 Recommendations and completion time for consultations received from other organizations

Part 6: Completion Time of Consultations on Cabinet Confidences

6.1 Requests with Legal Services

6.2 Requests with Privy Council Office

Part 7: Complaints and Investigations

Part 8: Court Action

Part 9: Resources Related to the Access to Information Act

9.1 Costs

9.2 Human Resources

Note: Enter values to two decimal places.