Procedure for a Formal Access to Information Request
– June 11, 2021
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PROCEDURE
FOR
A
FORMAL
ACCESS
TO
INFORMATION
REQUEST
Procedure
Type:
Management
Initially
Approved:
June 11,
2021
Procedure
Sponsor:
General Counsel
and University
Secretary
Last Revised:
Primary
Contact:
Information
Management &
Privacy Office
Review
Scheduled:
June 11,
2026
Approver:
Executive Leadership Team
A.
PROCEDURES
1.
REQUESTING INFORMATION
1.1
Any individual may file a Formal Access to Information Request by submitting either
an Access to Information Request Form or making a request in writing, to the
Information Management and Privacy Advisor (“IMPA”).
a. If by mail to:
Information Management & Privacy Advisor
Information Management & Privacy Office
Mount Royal University
4825 Mount Royal Gate SW
Calgary, Alberta, T3E 6K6
b. Or by email at E-mail:
foip@mtroyal.ca
c. Or by requesting an appointment using:
foip@mtroyal.ca
1.2
The request must include at minimum the following:
a. A description of the information sought.
b. The date range of the information sought.
c. The Department/Faculty/Area/individual where the information resides, if known.
d. Sufficient detail such that the information can be identified in an efficient manner
as required in section 7(2) of the Act.
e. The contact information of the person requesting the information, such as: name,
address, phone number, and e-mail.
f.
For requests that deal with Personal Information, authentication of identity is
required.
Procedure for a Formal Access to Information Request
– June 11, 2021
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1.3
The Information Management & Privacy Office will review the request, acknowledge
receipt of the request, advise the requestor of the time required to complete the
request, and provide details of any additional fees that are applicable.
1.4
The University will provide its final response to a Formal Access to Information
Request within 30 calendar days of initial receipt. That timeline may be extended
only in accordance with the limited circumstances provided under the Act. The IMPA
will notify the requestor of the date of final response or if a timeline extension is
warranted.
1.5
If the Records sought in a Formal Access to Information Request are teaching
materials, questions on an examination or test or research information of a faculty
member then access will be denied on the basis that the Records are excluded from
the Act.
2.
IDENTIFYING, LOCATING, AND RETRIEVING RELEVANT RECORDS
2.1
The IMPA will provide the Senior Leader(s) of the Department(s) who holds the
Records and information with the specifics of the Formal Access to Information
Request, except for the name and contact information of the person making the
request. A timeline for completion of identifying, locating, and retrieving the relevant
Records will also be established by the IMPA.
2.2
Senior Leaders are responsible to ensure that unredacted copies of all Records and
information which are responsive to the Formal Access to Information Request, and
which are held by their Department are provided to the IMPA.
2.3
The Senior Leader may delegate specific tasks to fulfill the request to Employees in
the Department, however, remain accountable for the Records and information
produced.
2.4
Departments will not exclude any responsive Records or revise, redact, or destroy
any Record or information that is submitted to the IMPA. The IMPA is responsible for
assessing information contained within the Records provided by units, determining
what redactions are necessary and what will be released to the requestor.
2.5
The IMPA may require Departments to use the Access Request Search Summary
for identifying, locating, and retrieving relevant Records and information relating to
the Request to ensure the duty to assist has been fulfilled. This sheet may be used
to assist with any subsequent investigations undertaken by the Commissioner if a
complaint is made.
2.6
Formal Access to Information Requests which seek Health Information subject to the
Health Information Act of Alberta will be directed to the applicable Custodian, as
defined in the Health Information Act.
3.
RELEASING INFORMATION
3.1
The IMPA will make the determination on whether the information contained within
a Record is classified as:
a. Disclosable information that must be released under the Act;
b. Non-disclosable information that must not be released under the Act; and
Procedure for a Formal Access to Information Request
– June 11, 2021
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c. Discretionary information that is not required to be released under the Act but
may be released at the discretion of the University.
3.2
If the IMPA determines that information contained within a Record is deemed to be
disclosable information that must be released under the Act, the IMPA will release
the information to the requestor.
3.3
If the IMPA determines that the information contained within a Record is non-
disclosable information that must not be released under the act, the IMPA will not
release that information to the requestor.
3.4
If the IMPA determines that the information contained within a Record is
discretionary information that may be released at the discretion of the University, the
following steps will be taken:
a. Senior Leaders may assign the responsibility to determine whether or not to
release the discretionary information to the IMPA in writing.
b. If the Senior Leader of the Department who holds the discretionary information
has assigned this responsibility, the IMPA will determine whether or not to
release the discretionary information to the requestor.
c. If the Senior Leader of the Department who holds the discretionary information
has not assigned this responsibility, the Senior Leader will determine, in
consultation with the IMPA, whether or not to release the discretionary
information to the requestor.
4.
ANNUAL REPORTING
4.1
The IMPA will provide an annual report to the Executive Leadership Team. The
report will include:
a. the number and nature of Formal Access to Information Requests received;
b. the number of pages disclosed and a description of any other supporting medium
included in response to Formal Access to Information Requests;
c. the number of Formal Access to Information Requests where no Records are
provided; and
d. the number of complaints made to the Commissioner resulting from a decision
made by the University, including
the Commissioner’s ruling if any has been
made.
B.
DEFINITIONS
(1)
Act, the:
means the Freedom of Information and Protection of
Privacy Act, RSA, 2000, c F-25
(2)
Commissioner:
means the Information and Privacy Commissioner
appointed in accordance with the Act
(3)
Department:
means a faculty within the Academic Division or a
Procedure for a Formal Access to Information Request
– June 11, 2021
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department outside of the Academic Division
(4)
Employee:
means individuals who are engaged to work for the
University under an employment contract, including but
not limited to faculty, staff, exempt, casual and
management employees
(5)
Formal Access to
Information Request:
means a request for access to information/Records
made under the formal processes of the Act
(6)
IMPA:
means the
University’s Information Management &
Privacy Advisor
(7)
Policy:
means the Access to Information policy
(8)
Record:
means a Record of information in any form and includes,
but is not limited to, notes, emails, letters, images,
audiovisual recordings, documents, maps, drawings,
photographs, letters, invoices and any other information
that is written, photographed, recorded, captured or
stored in any manner. Notably, the definition does not
include software or any mechanism that produces or
reads Records.
(9)
Senior Leader:
means either (i) any Employee who both reports to a
Vice-President or President and leads a Department
and (ii) any other person designated as a Senior Leader
by the Executive Leadership Team.
(10)
University:
means Mount Royal University
C.
RELATED POLICIES
• Access to Information Policy
• Information Security Policy
• Privacy Policy
D.
RELATED LEGISLATION
• Freedom of Information and Protection of Privacy Act, RSA, 2000, c F-25
E.
RELATED DOCUMENTS
• Access to Information Request Form
• FOIP Delegation of Authority Table
• Access Request Search Summary
Procedure for a Formal Access to Information Request
– June 11, 2021
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F.
REVISION HISTORY
Date
(mm/dd/yyyy)
Description of
Change
Sections
Person who
Entered Revision
(Position Title)
Person who Authorized
Revision
(Position Title)
01/26/2022
Editorial
Policy Sponsor
Policy Advisor
General Counsel and
University Secretary
04/20/2023
Editorial
Definitions
Policy Advisor
General Counsel and
University Secretary