Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 3, Access to Records. Updated 5 May 2023. 122 be considered. For example, it would take less to interfere with the operations of a small municipality compared to a large ministry. Unreasonably interfere means going beyond the limits of what is reasonable or equitable in time and resources and the impact, which this use of resources would have on the government institution’s day-to-day activities.202 Each of the following factors should be considered: • Are the requests large and complex, rather than confusing, vague, broadly worded, or wide-ranging (e.g., “all records” on a topic), without parameters such as date ranges. • Did the government institution seek clarification and was it obtained. • Did the clarification of the applicant’s requests, if obtained, provide useful details to enable the effective processing of the requests. • Do the applicant’s requests impair the government institution’s ability to respond to other requests in a timely fashion. • What is the amount of time to be committed for the processing of the request, such as: o Number of employees to be involved in processing the request; o Number of employees and hours expended to identify, retrieve, review, redact if necessary, and copy records; o Number of total employees in the same office; and o Whether there is an employee assigned solely to process access requests.203 For the second part of the test, the government institution should address all of the above factors in its application to the Commissioner. Requests for branch-wide searches could be found to amount to unreasonable interference, especially where an applicant is able to name the individuals who may possess the requested information.204 The government institution must meet a high threshold of showing “unreasonable interference”, as opposed to mere disruption. It will usually be the case that a request for information will pose some disruption or inconvenience to a government institution; that is 202 British Columbia Government Services, FOIPPA Policy Definitions at https://www2.gov.bc.ca/gov/content/governments/services-for-government/policiesprocedures/foippa-manual/policy-definitions. Accessed April 23, 2020. 203 NB IPC Interpretation Bulletin, Section 15 – Permission to disregard access request. 204 AB IPC Request to Disregard F2019-RTD-01 at p. 11.
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