Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 4, Exemptions from the Right of Access. Updated 24 July 2025. 102 Advice includes the views or opinions of a public servant as to the range of policy options to be considered by the decision maker even if they do not include a specific recommendation on which option to take.363 Advice has a broader meaning than recommendations.364 The legislative intention was for advice to have a distinct meaning from recommendations. Otherwise, it would be redundant.365 While “recommendation” is an express suggestion, “advice” is simply an implied recommendation.366 A recommendation is a specific piece of advice about what to do, especially when given officially; a suggestion that someone should choose a particular thing or person that one thinks particularly good or meritorious.367 Recommendations relate to a suggested course of action more explicitly and pointedly than “advice”.368 It can include material that relates to a suggested course of action that will ultimately be accepted or rejected by the person being advised.369 It includes suggestions for a course of action as well as the rationale or substance for a suggested course of action.370 A recommendation, whether express or inferable, is still a recommendation.371 363 John Doe v. Ontario (Finance), [2014] 2 SCR 3, 2014 SCC 36 (CanLII) at [26] and [47]. Relied on in ON IPC Order PO-3799 at [29]. It should be noted that this is based on Ontario’s FOIP subsection 13(1), which does not include “policy options” in its wording. Saskatchewan’s FOIP includes ‘policy options’ in its wording as a separate type of information. 364 John Doe v. Ontario (Finance), [2014] 2 SCR 3, 2014 SCC 36 (CanLII) at [22] and [24]. Relied on by Justice Danyliuk in Britto v University of Saskatchewan, 2018 SKQB 92 at [77]. 365 John Doe v. Ontario (Finance), [2014] 2 SCR 3, 2014 SCC 36 (CanLII) at [24]. Relied on by Justice Danyliuk in Britto v University of Saskatchewan, 2018 SKQB 92 at [77]. 366 John Doe v. Ontario (Finance), [2014] 2 SCR 3, 2014 SCC 36 (CanLII) at [22]. Relied on by Justice Danyliuk in Britto v University of Saskatchewan, 2018 SKQB 92 at [77] and Justice Gabrielson in Hande v University of Saskatchewan, QBG 1222 of 2018 at [41]. 367 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1526. 368 John Doe v. Ontario (Finance), [2014] 2 SCR 3, 2014 SCC 36 (CanLII) at [22]. Relied on by Justice Danyliuk in Britto v University of Saskatchewan, 2018 SKQB 92 at [77] and Justice Gabrielson in Hande v University of Saskatchewan, QBG 1222 of 2018 at [41]. 369 John Doe v. Ontario (Finance), [2014] 2 SCR 3, 2014 SCC 36 (CanLII) at [23]. Relied on by Justice Danyliuk in Britto v University of Saskatchewan, 2018 SKQB 92 at [77] and Justice Gabrielson in Hande v University of Saskatchewan, QBG 1222 of 2018 at [41]. 370 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 4 at pp. 166 and 179. The SK OIPC relied on this definition for the first time in Review Report LA-2010-001 at [28]. Also relied on in SK OIPC Review Report F-2014-001 at [282]. The term “substance” was added to the definition following SK IPC Review Report 019-2017 at [21]. 371 John Doe v. Ontario (Finance), [2014] 2 SCR 3, 2014 SCC 36 (CanLII) at [24]. Relied on by Justice Danyliuk in Britto v University of Saskatchewan, 2018 SKQB 92 at [77] and Justice Gabrielson in Hande v University of Saskatchewan, QBG 1222 of 2018 at [41].
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