Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 4, Exemptions from the Right of Access. Updated 24 July 2025. 206 LA FOIP contains a unique exemption for accounts for routine services rendered by a local authority to a third party.692 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.693 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;694 a document setting out the items of debit and credit between two parties.695 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.696 An account means a record of financial expenditure and receipts; a bill taking the form of such a record.697 Financial means of or pertaining to revenue or money matters.698 692 McNairn, C., Woodbury, C., 2009, Government Information: Access and Privacy, Carswell: Toronto, p. 4-17. 693 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 1 at p. 3006. 694 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1699. See also SK OIPC Review Report 305-2023 (May 22, 2024) at [15]. 695 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 2 at p. 3006. 696 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 21. 697 Pearsall, Judy, Concise Oxford Dictionary, 10th Edition at p. 8 (Oxford University Press). 698 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 1 at p. 964.
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