Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 4, Exemptions from the Right of Access. Updated 24 July 2025. 228 If the information is already available elsewhere to the public, there may be no need for the exemption.767 IPC Findings In Evenson v Kelsey Trail Regional Health Authority, (2012), Justice Zarzeczny considered section 20 of LA FOIP. Kelsey Trail Regional Health Authority (KTRHA) had denied an applicant access to certain hospital records including the names of nurses that were on duty at the Melfort Hospital during a specific time. Justice Zarzeczny ruled that KTRHA had not established that the exemption applied. Further, that the concerns about the applicant raised by KTRHA did not have any basis or foundation in fact. Nor were they supported by any circumstances which were established in the materials that were presented to the Commissioner in Review Report LA-2012-002. In Consumers’ Co-Operative Refineries Limited v. Regina (City), (2016), Justice Keene ruled that a Major Hazard Risk Assessment Report (MHRAR) qualified for section 20 of LA FOIP. In making this decision, Justice Keene considered that the MHRAR revealed specific parts of a refinery where the worst possible accidents could occur. Over disclosure of the information could be harmful to the public (i.e. nondisclosure of records can actually promote public safety in certain circumstances). Facilities such as nuclear power plants and refining complexes could be the target of attack, which could pose a public safety risk. As such, the provision was found to apply in the greater sense of the protection of the public. 767 Information Commissioner of Canada resource, Investigator’s Guide to Interpreting the Act, Section 17: Safety of Individuals. Available at https://www.oic-ci.gc.ca/en/investigators-guide-interpretingact/section-17-safety-individuals. Accessed September 6, 2019.
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