Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 4, Exemptions from the Right of Access. Updated 24 July 2025. 221 made an access to information request to Saskatchewan Power Corporation (SaskPower) for a copy of the investigation report prepared by SaskPower that led to the applicant’s termination along with copies of email conversations and calibration session comments. SaskPower responded to the applicant advising that the investigation report was being withheld pursuant to several provisions of FOIP including subsection 20(a). Upon review, the Commissioner found that the investigation performed by SaskPower would qualify as an audit for the purposes of section 20 of FOIP. However, the techniques or procedures must include specific steps. General information, such as forms and standard policies that did not include specific steps and procedures, would not qualify. Routine, common or customary auditing techniques and procedures would not qualify. The Commissioner found that three portions of the investigation report, which included a section titled, Forensic Analysis Procedures, would constitute auditing techniques or procedures. Further, the Commissioner was persuaded that the release of the auditing techniques and procedures could reasonably be expected to prejudice the use or results of particular tests or audits. As such, the Commissioner found that subsection 20(a) of FOIP applied to portions of the investigation report. In Review Report 231-2015, the Commissioner considered the equivalent provision in The Freedom of Information and Protection of Privacy Act (FOIP), (subsection 20(a)). An applicant made an access to information request to the Ministry of Economy (Economy) for specific potash royalty information. Economy responded to the applicant advising that records were being withheld under several provisions of FOIP including subsection 20(a). Economy applied subsection 20(a) to royalty and tax audit reports. Economy asserted that the royalty and tax audit reports outlined specific steps taken by the auditor to analyze the company’s returns. Furthermore, the identification of the subject areas reviewed represented an auditing technique by which the auditor is able to focus on the areas most likely to reveal shortfalls in tax reported. The Commissioner was persuaded that subsection 20(a) of FOIP applied to the audit reports. Subsection 19(b) Testing procedures, tests and audits 19 A head may refuse to give access to a record that contains information relating to: … (b) details of specific tests to be given or audits to be conducted; if disclosure could reasonably be expected to prejudice the use or results of particular tests or audits.
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