Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 4, Exemptions from the Right of Access. Updated 24 July 2025. 261 established that the exemption applied. Further, that the concerns about the applicant raised by KTRHA did not have any basis or foundation in fact. Nor were they supported by any circumstances which were established in the materials that were presented to the Commissioner in Review Report LA-2012-002. In Consumers’ Co-Operative Refineries Limited v. Regina (City), (2016), Justice Keene ruled that a Major Hazard Risk Assessment Report (MHRAR) qualified for the equivalent provision in The Local Authority Freedom of Information and Protection of Privacy Act, (section 20). In making this decision, Justice Keene considered that the MHRAR revealed specific parts of a refinery where the worst possible accidents could occur. Over disclosure of the information could be harmful to the public (i.e., nondisclosure of records can actually promote public safety in certain circumstances). Facilities such as nuclear power plants and refining complexes could be the target of attack, which could pose a public safety risk. As such, the provision was found to apply in the greater sense of the protection of the public. Section 22: Solicitor-Client Privilege Solicitor-client privilege 22 A head may refuse to give access to a record that: (a) contains any information that is subject to any privilege that is available at law, including solicitor-client privilege; (b) was prepared by or for an agent of the Attorney General for Saskatchewan or legal counsel for a government institution in relation to a matter involving the provision of advice or other services by the agent or legal counsel; or (c) contains correspondence between an agent of the Attorney General for Saskatchewan or legal counsel for a government institution and any other person in relation to a matter involving the provision of advice or other services by the agent or legal counsel. Section 22 of FOIP is a discretionary class-based provision. It is intended to protect records that contain: • Information subject to any privilege available at law, including solicitor-client privilege (22(a)); • Information that relates to the provision of legal advice or services and was prepared for specified individuals (22(b)); or
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