Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 4, Exemptions from the Right of Access. Updated 24 July 2025. 119 action.423 It can include consultations about prospective future actions and outcomes in response to a developing situation. It can also include past courses of action. For example, where an employer is considering what to do with an employee in the future, what has been done in the past can be summarized and would qualify as part of the consultation or deliberation.424 Deliberation means: • The act of deliberating (to deliberate: to weigh in mind; to consider carefully; to think over); careful consideration. • The consideration and discussions of the reasons for and against a measure by a number of councillors.425 A deliberation can occur when there is a discussion or consideration of the reasons for or against an action.426 It can refer to discussions conducted with a view towards making a decision.427 In Tarasoff v Saskatoon (City), 2025 SKKB 41 at paragraph [67] the Court ruled that this office’s focus on the need for a decision as the result of careful consideration and deliberation was too narrow an interpretation of this section of the legislation. The Court wrote: [67] I accept that the concept of deliberation might suggest an intent to decide. Consultation appears to be a broader term, and need not have that objective, though the definition advanced by the Commissioner suggests that such an 423 Definition originated from AB IPC Orders 96-006 at p. 10 and F2003-016 at [20]. Adopted by SK OIPC in Review Report F-2004-001 at [11] and [12]. 424 Britto v University of Saskatchewan, 2018 SKQB 92 at [88] to [89] and Hande v University of Saskatchewan, QBG 1222 of 2018 May 21, 2019 at [48] and [49]. 425 Canada (Information Commissioner) v. Toronto Port Authority, 2016 FC 683 (CanLII) at [85]. The Federal Court of Canada relied on the definitions found in the Treasury Board Secretariat’s Access to Information Manual which were based on the ordinary meaning of these words. The manual can be found at https://www.canada.ca/en/treasury-board-secretariat/services/access-informationprivacy/access-information/access-information-manual.html#cha11. Definition consistent with The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 1 at p. 409. Similar definition used in R. v. McDonald, 2003 NSPC 34 (CanLII) at p. 3 and Canada (Information Commissioner) v. Canada (Minister of the Environment), [2007] 3 FCR 125, 2006 FC 1235 (CanLII) at [65] and [66]. 426 AB IPC Order 96-006 at p. 10. Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 4, p. 180. Adopted in SK OIPC Review Report F-2004-001 at [12]. 427 Originated from ON IPC Order M-184 at p. 3. Adopted in SK OIPC Review Report 187-2015 at [19].
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