Office of the Saskatchewan Information and Privacy Commissioner. A Guide to Submissions. Effective Sept. 2020. Updated Dec. 2022. 19 Where the personal information or personal health information exemption is claimed: • Have you identified which information in the record constitutes personal information or personal health information, why it should be considered such, and to whom it relates. • Have you considered whether the information is the requestor’s personal information or personal health information? If this is so, did you consider the specific provisions of the applicable Act granting access to one’s own personal information (section 31 of FOIP, section 30 of LA FOIP, and section 12 and 32 of HIPA). • Have you contacted the third party to see if there is any objection to the release of their information. Consider Whether an Exemption Applies to Multiple Records or Pages The author of the submission should determine if they can provide arguments under one heading for each exemption. Under each heading, the author can provide the sequential page number and sequential severance number to which it is applying the exemption and the arguments. For example, if there are 100 pages in the record, and it is applying subsection 16(1)(a) of LA FOIP to every 10th page, the submission could be as follows: Subsection 16(1)(a) Public Body XYZ applied subsection 16(1)(a) to portions of pages 10, 20, 30, 40, 50, 60, 70, 80, 90, and 100 as they relate to topic ABC. Before Writing, Consider the Outline of Your Submission Below is an outline for a submission that can work. The outline can be structured to have a heading on exemptions claimed, sequential page number and sequential severance number and a lower sub heading of the tests or questions (from the IPC Guide to FOIP). For example, the headings may look like: A. Introduction B. Preliminary Matters C. Exemptions Claimed 1. Decision to refuse release of records under subsection 17(1)(a) of FOIP a. Records or pages 1 to 5 and severances 1 to 5
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