Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 4, Exemptions from the Right of Access. Updated 24 July 2025. 57 records withheld pursuant to subsection 15(1)(c) of FOIP were created as a result of the ministerial-appointed inspector recommending an inspection be expanded into an inquiry and that a supervisor also be appointed pursuant to section 422 of The Northern Municipalities Act during said inquiry. Furthermore, Government Relations asserted that an inspection pursuant to section 417 of The Northern Municipalities Act is an investigation into the management, administration, or operation of any municipality. The scope of the investigation is set out in the Minister’s Order. An inquiry is conducted if it is determined during the inspection that a more in-depth investigation is required, which is what occurred in the Northern Village of Pinehouse. Government Relations further asserted that while these provisions use the word inspection and inquiry, both an inspection and inquiry are an investigation that is authorized and permitted by law, specifically sections 417 and 418 of The Northern Municipalities Act. The Commissioner found that based upon the powers provided to an inspector or person of inquiry in The Public Inquiries Act, 2013, an inspection or inquiry under The Northern Municipalities Act qualifies as a ”lawful investigation” for purposes of subsection 15(1)(c) of FOIP. In Review Report 330-2023, 334-2023 the Commissioner noted that the terms “lawful investigation” are not interchangeable with “law enforcement matter”. “Law enforcement” includes investigations conducted for the purpose of enforcing an enactment which leads to or could lead to a penalty or sanction being imposed under the enactment that authorizes the investigation. In that case, the Commissioner found that because investigations by the Office of the Saskatchewan Coroners Service (SCS) do not lead to penalty or sanctions under The Coroners Act, 1999, such that it could be considered a “law enforcement matter” on its own. Had the Coroner’s investigation been handed onto another party, such as a police service, then it would form part of the police service’s investigation and may qualify for exemption pursuant to subsection 15(1)(k). See paragraphs [70] to [72]. Subsection 14(1)(d) Law enforcement and investigations 14(1) A head may refuse to give access to a record, the release of which could: … (d) be injurious to the local authority in the conduct of existing or anticipated legal proceedings; … (2) Subsection (1) does not apply to a record that:
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