Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 4, Exemptions from the Right of Access. Updated 24 July 2025. 134 Including means that the list of information that follows is not complete (non-exhaustive). The examples in the provision are the types of information presumed to be involved.478 Proposed means something offered for consideration or acceptance; a suggestion.479 A plan is a formulated and especially detailed method by which a thing is to be done; a design or scheme.480 A detailed proposal for doing or achieving something; an intention or decision about what one is going to do.481 A policy is a standard course of action that has been officially established by the local authority.482 A project is an enterprise carefully planned to achieve a particular aim; a proposed or planned undertaking.483 The information does not have to be proposed plans, policies or projects to qualify. The local authority should describe what the information is. 2. Could disclosure reasonably be expected to result in disclosure of a pending policy or budgetary decision? Subsection 16(1)(e) of LA FOIP includes the requirement that access can be refused where it “could reasonably be expected to disclose” a pending policy or budgetary decision. The meaning of the phrase “could reasonably be expected to” in terms of harm-based exemptions was considered by the Supreme Court of Canada in Ontario (Community Safety and Correctional Service) v. Ontario (Information and Privacy Commissioner), (2014). Although subsection 16(1)(e) is not a harms-based provision, the threshold provided by the Court for “could reasonably be expected to” is instructive: 478 Adapted from British Columbia Government Services, FOIPPA Policy and Procedures Manual at https://www2.gov.bc.ca/gov/content/governments/services-for-government/policiesprocedures/foippa-manual/cabinet-local-public-body-confidences. Accessed June 26, 2019. 479 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1474. 480 Definition originated from ON IPC Order P-229 at p. 10, which drew the definition from the Concise Oxford Dictionary. Adopted in SK OIPC Review Report LA-2011-001 at [78]. Same definition used by the Treasury Board of Canada Secretariat, Access to Information Manual, Chapter 11.18.5. Available at https://www.canada.ca/en/treasury-board-secretariat/services/access-information-privacy/accessinformation/access-information-manual.html#cha11_18. Accessed July 9, 2019. 481 Pearsall, Judy, Concise Oxford Dictionary, 10th Edition at p. 1092 (Oxford University Press). 482 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1401. 483 Pearsall, Judy, Concise Oxford Dictionary, 10th Edition at p. 1143 (Oxford University Press).
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