Guide to LA FOIP-Chapter 4

Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 4, Exemptions from the Right of Access. Updated 18 Oct 2023. 176 Technical information is information relating to a particular subject, craft or technique. Examples are system design specifications and the plans for an engineering project.624 It is information belonging to an organized field of knowledge which would fall under the general categories of applied sciences or mechanical arts. Examples of these fields would include architecture, engineering, or electronics. It will usually involve information prepared by a professional in the field and describe the construction, operation or maintenance of a structure, process, equipment, or thing. Finally, technical information must be given a meaning separate from scientific information.625 Labour relations information is information that relates to the management of personnel by a person or organization, whether or not the personnel are organized into bargaining units. It includes relationships within and between workers, working groups, managers, employers and their organizations. Labour relations information also includes collective relations between a public body and its employees. Common examples of labour relations information are hourly wage rates, personnel contracts, and information on negotiations regarding collective agreements.626 In the decision Merck Frosst Canada Ltd. v. Canada (Health), (2012), the Supreme Court of Canada recognized that administrative details such as page and volume numbering, dates, and location of information within records do not constitute financial, commercial, scientific, or technical information.627 2. Was the information supplied by the third party to a local authority? Supplied means provided or furnished.628 Information may qualify as “supplied” if it was directly supplied to a local authority by a third party, or where its disclosure would reveal or permit the drawing of accurate inferences with respect to information supplied by a third party.629 624 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 4, p. 191. Definition first relied on for third party exemption in SK OIPC Review Report F-2006-002 at [85]. 625 Definition originated from ON IPC Order P-454 at p. 4. Adopted in SK OIPC Review Report F-2005003 at [26]. Definition endorsed in Consumers’ Co-operative Refineries Limited v Regina (City), 2016 SKQB 335 (CanLII) at [20]. 626 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 4, p. 103. Definition first relied on in SK OIPC Review Report 019-2014 at [37]. 627 Merck Frosst Canada Ltd. v. Canada (Health), [2012] 1 SCR 23, 2012 SCC 3 (CanLII) at [141]. 628 British Columbia Government Services, FOIPPA Policy Definitions at https://www2.gov.bc.ca/gov/content/governments/services-for-government/policiesprocedures/foippa-manual/policy-definitions#supplied. Accessed August 21, 2019. 629 SK OIPC Review Reports F-2005-003 at [17], F-2006-002 at [40].

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