Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 4, Exemptions from the Right of Access. Updated 18 Oct 2023. 200 LA FOIP contains a unique exemption for accounts for routine services rendered by a local authority to a third party.691 Only the Northwest Territories and Nunavut’s Access to Information and Protection of Privacy Act, S.N.W.T. 1994, c-20, has a similarly worded provision. The following two-part test can be applied: 1. Is the record a statement of a financial account relating to a third party with respect to the provision of routine services? A statement is a formal written or oral account, setting down facts, a document setting out the items of debit and credit between two parties.692 A “statement of a financial account” is not defined in LA FOIP. However, the following is helpful in interpreting what the Legislative Assembly intended by this phrase: A statement of account is a report issued periodically (usually monthly) by a creditor to a customer, providing certain information on the customer’s account, including the amounts billed, credits given, and the balance due;693 a document setting out the items of debit and credit between two parties.694 An accounting means a detailed statement of the debits and credits between parties to a contract or to a fiduciary relationship; a reckoning of monetary dealings.695 An account means a record of financial expenditure and receipts; a bill taking the form of such a record.696 Financial means of or pertaining to revenue or money matters.697 Relating to should be given a plain but expansive meaning.698 The phrase should be read in its grammatical and ordinary sense. There is no need to incorporate complex requirements 691 McNairn, C., Woodbury, C., 2009, Government Information: Access and Privacy, Carswell: Toronto, p. 4-17. 692 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 1 at p. 3006. 693 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1699. 694 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 2 at p. 3006. 695 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 21. 696 Pearsall, Judy, Concise Oxford Dictionary, 10th Edition at p. 8 (Oxford University Press). 697 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 1 at p. 964. 698 Gertner v. Lawyers’ Professional Indemnity Company, 2011 ONSC 6121 (CanLII) at [32].
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