Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 4, Exemptions from the Right of Access. Updated 8 April 2024. 231 FOIP contains a unique exemption for accounts for routine services rendered by a government institution to a third party.794 Only the Northwest Territories and Nunavut’s Access to Information and Protection of Privacy Act, S.N.W.T. 1994, c-20, has a similarly worded provision. The following two-part test can be applied: 1. Is the record a statement of a financial account relating to a third party with respect to the provision of routine services? A statement is a formal written or oral account, setting down facts, a document setting out the items of debit and credit between two parties.795 A “statement of a financial account” is not defined in FOIP. However, the following is helpful in interpreting what the Legislative Assembly intended by this phrase: A statement of account is a report issued periodically (usually monthly) by a creditor to a customer, providing certain information on the customer’s account, including the amounts billed, credits given and the balance due;796 a document setting out the items of debit and credit between two parties.797 An accounting means a detailed statement of the debits and credits between parties to a contract or to a fiduciary relationship; a reckoning of monetary dealings.798 An account means a record of financial expenditure and receipts; a bill taking the form of such a record.799 Financial means of or pertaining to revenue or money matters.800 Relating to should be given a plain but expansive meaning.801 The phrase should be read in its grammatical and ordinary sense. There is no need to incorporate complex requirements 794 McNairn, C., Woodbury, C., 2009, Government Information: Access and Privacy, Carswell: Toronto, p. 4-17. 795 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 1 at p. 3006. 796 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1699. 797 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 2 at p. 3006. 798 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 21. 799 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed., (Oxford University Press) at p. 8. 800 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 1 at p. 964. 801 Gertner v. Lawyers’ Professional Indemnity Company, 2011 ONSC 6121 (CanLII) at [32].
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