3214-00380 — Library and Archives Canada
The complainant alleged that Library and Archives Canada (LAC) improperly withheld information under subsections 15(1) (national security) and 19(1) (personal information) of the Access to Information Act. The request sought information related to "Active Measures – The Soviet Bloc Practice of Deception, Disruption and Defamation." Initially, LAC withheld the entire 33-page record but later dropped its reliance on subsection 19(1) and released some information. The Information Commissioner found that LAC failed to demonstrate that the remaining withheld information met the requirements of subsection 15(1), noting the extensive public domain information on the topic. Despite the Commissioner's recommendation to disclose all remaining information, LAC refused to implement it. Consequently, the complaint was found to be well founded.
- 1Whether s.15(1) national security exemption was properly applied
- 2Whether disclosure could reasonably be expected to harm national security
- 3Whether the institution provided sufficient justification for the s.15(1) claim
- 4Whether the information was already in the public domain
- 5Whether s.19(1) personal information exemption was properly applied
- s.19 personal information: Exemption dropped by institution
- s.15 national security: Exemption not justified
- Compliance with recommendation: Institution refused to implement
- Complaint outcome: Well founded
Complaint well founded — disclosure ordered, but institution refused to comply
The institution failed to demonstrate that the withheld information met the requirements of subsection 15(1) and did not provide any justification for the claimed harm. The Commissioner noted that much information on the subject was already in the public domain, undermining the institution's claim.
The Information Commissioner recommended that Library and Archives Canada disclose all remaining withheld information.
- s.15(1) ATIA
- s.19(1) ATIA
This summary is for informational purposes only and does not constitute legal advice.
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