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Canadian privacy & access decisions

The comprehensive archive of federal, provincial, and territorial commissioner decisions — each with a plain-language summary.

22,241 decisions in the archive
OntarioFreedom of Information and Protection of Privacy Act
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Order PO-4442

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Federal (Canada)Access to Information ActWell-founded
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Sep 26, 20235822-03293Indexed Jun 30, 2026

Parks Canada (Re), 2023 OIC 26

Parks Canada

The complainant alleged that Parks Canada improperly withheld information under various sections of the Access to Information Act in response to a request for records related to Benga Mining or the Grassy Mountain Coal Project. The institution withheld information under subsection 19(1) (personal information), paragraphs 21(1)(a), (b), (c) (advice, consultations, plans), and section 23 (litigation privilege). During the investigation, Parks Canada disclosed a portion of the record initially withheld under paragraph 21(1)(a) due to the passage of time. The Commissioner found that the remaining information withheld under subsection 19(1), paragraph 21(1)(a), and section 23 met the criteria for exemption and that the institution had reasonably exercised its discretion. The Commissioner also addressed the complainant's concern about records marked as "not relevant," finding that Parks Canada was justified in not processing these records given the complainant's prior agreement to narrow the scope of the request. Despite upholding the institution's application of most exemptions, the complaint was found to be well-founded because the institution initially improperly withheld information under paragraph 21(1)(a) that was later released.

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Access to Information ActWell-founded

Parks Canada (Re), 2023 OIC 26

Sep 26, 20235822-03293
Adjudicator: Caroline Maynard
Plain-Language Summary

The complainant alleged that Parks Canada improperly withheld information under various sections of the Access to Information Act in response to a request for records related to Benga Mining or the Grassy Mountain Coal Project. The institution withheld information under subsection 19(1) (personal information), paragraphs 21(1)(a), (b), (c) (advice, consultations, plans), and section 23 (litigation privilege). During the investigation, Parks Canada disclosed a portion of the record initially withheld under paragraph 21(1)(a) due to the passage of time. The Commissioner found that the remaining information withheld under subsection 19(1), paragraph 21(1)(a), and section 23 met the criteria for exemption and that the institution had reasonably exercised its discretion. The Commissioner also addressed the complainant's concern about records marked as "not relevant," finding that Parks Canada was justified in not processing these records given the complainant's prior agreement to narrow the scope of the request. Despite upholding the institution's application of most exemptions, the complaint was found to be well-founded because the institution initially improperly withheld information under paragraph 21(1)(a) that was later released.

Key Issues
  • Whether s.19(1) personal information exemption was properly applied
  • Whether discretion under s.19(2) was reasonably exercised
  • Whether s.21(1)(a) advice or recommendations exemption was properly applied
  • Whether discretion under s.21(1)(a) was reasonably exercised
  • Whether s.21(1)(b) accounts of consultations or deliberations exemption was properly applied
  • Whether s.21(1)(c) positions or plans developed for negotiations exemption was properly applied
  • Whether s.23 litigation privilege exemption was properly applied
  • Whether discretion under s.23 was reasonably exercised
  • Whether Parks Canada was justified in not processing records deemed 'not relevant' based on complainant's prior agreement
Federal (Canada)Access to Information ActOIC Order (ATIA s.36.1, binding)
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Sep 26, 20235822-07139Indexed Apr 21, 2026

National Defence, 5822-07139

The Information Commissioner ordered National Defence to provide a complete response to the access request on the 36th business day following the date of the final report.

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Access to Information ActOIC Order (ATIA s.36.1, binding)

National Defence, 5822-07139

Sep 26, 20235822-07139

The Information Commissioner ordered National Defence to provide a complete response to the access request on the 36th business day following the date of the final report.

Federal (Canada)Access to Information ActOIC Order (ATIA s.36.1, binding)
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Sep 26, 20235822-07211Indexed Apr 21, 2026

National Defence, 5822-07211

The Information Commissioner ordered National Defence to provide a complete response to the access request on the 36th business day following the date of the final report.

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Access to Information ActOIC Order (ATIA s.36.1, binding)

National Defence, 5822-07211

Sep 26, 20235822-07211

The Information Commissioner ordered National Defence to provide a complete response to the access request on the 36th business day following the date of the final report.

QuebecAct respecting access to documents held by public bodies and the protection of personal information
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2023 QCCAI 311 — Centre de services scolaire de Montréal

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QuebecAct respecting access to documents held by public bodies and the protection of personal information
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2023 QCCAI 347 — Université McGill

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QuebecAct respecting the protection of personal information in the private sector
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2023 QCCAI 364 — Société de gestion du réseau informatique des commissions scolaires (GRICS)

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Prince Edward IslandFreedom of Information and Protection of Privacy Act
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FI-21-422 — Department of Health and Wellness

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British ColumbiaFreedom of Information and Protection of Privacy Act
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F23-80 — BC OIPC order 2691

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OntarioMunicipal Freedom of Information and Protection of Privacy Act
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Order MO-4443-I

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OntarioMunicipal Freedom of Information and Protection of Privacy Act
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Order MO-4444

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Nova ScotiaFreedom of Information and Protection of Privacy Act
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23-09 — Municipal Affairs and Housing

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SaskatchewanLocal Authority Freedom of Information and Protection of Privacy Act
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Review Report 176-2023 — Downtown Saskatoon Business Improvement District

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British ColumbiaFreedom of Information and Protection of Privacy Act
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F23-79 — BC OIPC order 2690

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OntarioMunicipal Freedom of Information and Protection of Privacy Act
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Order MO-4442

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