Office of the Saskatchewan Information and Privacy Commissioner. A Guide to Submissions. Effective Sept. 2020. Updated Dec. 2022. 16 key issues and anticipated questions the Commissioner’s office would likely ask. Refer to the Index of Records The Index of Records, as prepared, becomes the guide for the Commissioner’s office and the public body/trustee. A well prepared Index of Records makes it easier to navigate through the multiple pages of the record. The greater number of records, it becomes more important for the public body/trustee and the Commissioner’s office to closely follow the Index of Records. Thus, referring to the sequential page number, and sequential severance number in the submission becomes extremely important. It is recommended that the Index of Records be attached to the submission. It should be the same as the Index of Records previously sent to the Commissioner’s office with the records. Focus on the Strongest Arguments As indicated above, organize your submission so that you put your strongest arguments first. Identifying your one or two very strong arguments is an important first step. A public body/trustee is most likely to succeed on the first or second argument. Public bodies have in the past claimed six or eight exemptions for a record. It is highly unlikely that all six or eight will apply. The shotgun approach to exemptions is usually not all that affective. Going for the strongest argument and putting it in your submission first, increases your chances of success. Refer to the Guide to FOIP, Guide to LA FOIP, or Guide to HIPA The Commissioner’s office has developed the Guide to FOIP (for government institutions), Guide to LA FOIP (for local authorities), and Guide to HIPA (for trustees). Before beginning to write the submission, a public body/trustee should read relevant portions of the appropriate guide. This will give the public body/trustee an idea on what the Commissioner will be looking for when the submission is reviewed. One does not have to agree with the tests discussed but needs to know as a starting point what the Commissioner is expecting to receive representations on.
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