Office of the Information and Privacy Commissioner. Guide to FOIP, CHAPTER 5, Third Party Information. Updated 9 March 2023. 96 assist the government institution by providing additional information and context to aid the government institution’s decision-making.211 The IPC has issued several guides, blogs, and other resources on how to prepare an effective submission: • A Guide to Submissions: Increasing your chances of success • IPC Guide to FOIP, Chapters 1 to 6 • IPC Guide to LA FOIP, Chapters 1 to 6 • IPC Guide to HIPA • What Makes a Good Submission? • Tips for a Good Submission Third parties should focus their arguments and supporting information on how section 19 applies or why personal information should not be released pursuant to subsection 29(2)(o) of FOIP. The discretion to apply other discretionary exemptions under Part III of FOIP is reserved for the “head” 212 of the government institution only.213 Subsection 36(1)(b) Right to make representations 36(1) A third party who is given notice pursuant to subsection 34(1): … (b) within 20 days after the notice is given, shall be given the opportunity to make those representations The third party must submit its arguments and supporting information to the government institution within 20 days of receiving notice. The 20-day time period allowed for a third party to provide representations begins on the day after the third party notice is given (i.e., the day after the government institution sends the notice), not the date the third party receives it. The 211 British Columbia Government Services, FOIPPA Policy and Procedures Manual at Section 24 - Time limit and notice of decision - Province of British Columbia (gov.bc.ca). Accessed Sept. 1, 2022. 212 The “head” is defined at section 2(1)(e) of The Freedom of Information and Protection of Privacy Act. 213 SK OIPC Review Reports F-2014-006 at [41] to [43], 205-2019, 255-2019 at [11]. See also SNC Lavalin Inc. v. Canada (Minister for International Cooperation), 2003 FCT 681 (CanLII), [2003] 4 FC 900 at [19] to [24].
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