Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 3, Access to Records. Updated 5 May 2023. 69 severance would require on the part of the Department is not reasonably proportionate to the quality of access it would provide. [Emphasis added; pp. 160-61.] [238] That said, one must not lose sight of the purpose of s. 25. It aims to facilitate access to the most information reasonably possible while giving effect to the limited and specific exemptions set out in the Act: Ontario (Public Safety and Security), at para. 67. The IPC discourages the use of white space redacting. White space redacting is where software removes the content of a record in such a way that it renders the redacted content indistinguishable from the blank background of the document. This type of redacting creates uncertainty as to what, if anything, has been redacted. White space redaction lacks specificity because when reviewing the responsive pages, an applicant cannot tell if the white space accounts for a missing line, paragraph, table, image etc. or if the page was naturally left blank. Government institutions have a duty to assist applicants by responding openly, accurately and completely. Invisible white space redactions fall short of this mandatory duty. Applicants should be able to evaluate the amount of missing information.114 The preference is black-out or grey-out redacting which allows sufficient visual context to indicate the length and general nature of the information (e.g., chart, column, list, sentence, or paragraph). A line-by-line review is essential to comply with the principle of severability set out in section 8 of FOIP. This provision grants an applicant a right of access to any record from which exempted material can be reasonably severed.115 For audio and video records that need to be severed, government institutions should have technology in place to enable it to blur out images or audio.116 Each severed item should have a notation indicating which exemption(s) applies in each instance. If the exemptions are clearly marked beside severed line items/sections, it will be clear upon review which of the multiple exemptions applies to the severed items in question. The same procedure should be utilized when providing severed records to applicants even though an applicant is not provided the information that has been severed. This would remove any doubt as to which exemption applies to which line item. Section 7 of FOIP requires that when denying an applicant’s access application, whether in full or in part, the written notice must meet three requirements: 114 Office of the Quebec Information and Privacy Commissioner Order 2017 QCCAI 274 at [46]. Office of the Prince Edward Island Information and Privacy Commissioner (PEI IPC) Order FI-10-008 at [66] and [71]. 115 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 3 at p. 82. 116 See SK OIPC Review Report 023-2019, 098-2019 at [111].
RkJQdWJsaXNoZXIy MTgwMjYzOA==