Report 28 - Access to Information Review Task Force

THE INFORMATION COMMISSIONER INVESTIGATIVE POWERS AND PROCEDURES

VI - Structural Model for the Review Process

a) Internal Review

• Should there be an intermediate level of redress whereby an individual who is not satisfied with a government institution's response to an access to information request has an opportunity to appeal that response to some other level within the institution?

Such internal reviews do not exist in any of the Canadian jurisdictions which we have canvassed, but an internal review procedure does exist in the U.S., Ireland ⁽¹⁵²⁾ and Australia ⁽¹⁵³⁾ (and will exist in the United Kingdom). These jurisdictions view their internal review process as productive.

To the extent that an internal review process would require a department to introduce more rigour into its own practices and processes, such an approach would be beneficial. It may also provide a relatively quick and cost effective method of resolving misunderstandings which, no doubt, are at the root of some complaints. A process whereby requestors could actually approach a third party, even an internal official, and make arguments as to why information ought to be released, particularly if he or she has an opportunity to address some of the reasons which might be put forward by the co-ordinator for having refused the information, may well result in fewer full blown complaints and investigations. Such a process may well foster more open and better communication between requestors and departments.

On the other hand, there really is no domestic model for such an internal review process for us to analyse and consider. Intuitively, imposing another layer in the complaint and redress process would only lengthen that process. While the cost may well be minimal, it would nevertheless be an additional cost. Finally, it is not clear that such an internal redress procedure could be structured in such a way that it would not be an unreasonable imposition on the time of the senior management who would be required to deal with the internal appeal.

Such a model might well have some benefits if the department knows that it is then facing a process before the Information Commissioner which could result in an order by the Commissioner that the information be released. However, if the intermediary internal review would only be preceding a process whereby the Commissioner acts only as an Ombudsman and makes a recommendation, it may well be that there would be insufficient incentive for such a process to develop into a truly effective method of the department taking a good hard second look at its decision. No one to whom we spoke, including the Commissioner's Officials was of the view that an internal appeal or grievance process would make the complaint and appeal process more effective or more efficient.

b) Adjudicative or Ombudsman Model?

• What is the appropriate structural model for the review function? In particular, should the Commissioner continue to be an Ombudsman or should he be a quasi-judicial authority with the power to make orders?

The most substantial change to the role and powers of the Information Commissioner which the Task Force must consider is whether the Commissioner should continue to operate as an Ombudsman or whether the office should become an adjudicative body with the power to make orders. As we have seen, this is the prevailing model in the provinces and is essentially the model which has been adopted in other jurisdictions. As far as we are aware, the experience in provinces such as British Columbia, Alberta, Ontario and Québec with a quasi-judicial body making a binding determination with respect to the release of records has been successful.

On the other hand, the Commissioner's Office argues that the federal experience is actually more successful. Leaving aside the recent flurry of activity in the courts on procedural issues and disputes over the Commissioner's jurisdiction, the Commissioner's officials advised us that less than 1% of complaints end up in court. While this does not prove that requestors are happy with the outcome of the investigation in the other 99% of cases, it certainly does suggest a high degree of success in resolving complaints on the part of the Commissioner's Office through persuasion, negotiation, mediation and sometimes arm-twisting, ⁽¹⁵⁴⁾ and, one must surmise, co-operation of the institutions involved. At the provincial level, more cases go on to the court even though the courts have expressed a great deal of reluctance to interfere with the findings of Commissioners.

Nevertheless, in my view there are a number of positive features to the adjudicative or order making model which make it an option which ought to receive consideration.

Firstly, a Commissioner with order making powers provides a far more effective avenue of redress for complainants. Under the current system, a complainant who is not satisfied with a recommendation made by the Commissioner or the government's response to such a recommendation, must go to the trouble and expense of taking the matter before the Federal Court. This is not only an expensive proposition, but is also a time consuming proposition. No doubt many requestors do not pursue this option, even though they are dissatisfied with the response which they have received, because it simply is not a viable option for them. Under the adjudicative model, a requestor receives a more immediate final determination of the issue. The cost to the requestor is significantly less. The ability to seek redress from the courts by way of a judicial review is limited and it is likely that in most cases where the Commissioner rules that information ought to be released it will be released. The decision as to whether to seek review of an order of the Commissioner ordering the release of a record lies with the government department, and departments will have to think carefully about whether they want to seek judicial review.

Secondly, the Commissioner would be required to issue public decisions in which he would necessarily have to articulate the reasons why he has determined that records should or should not be released. This would establish a body of jurisprudence which would be of great assistance to both government institutions and requestors in determining the basis upon which various exempting provisions ought to be applied. In my view, the Commissioner would necessarily be required to become more engaged in the process and take a stronger sense of "ownership" in the interpretation of the legislation. In my view this would lead to a more coherent approach to the interpretation of the legislation by both the Commissioner and individual government institutions.

Under the current model, only the government institution, the requestor and any Third Party receive a copy of the Commissioner's report. There have been comments from co-ordinators that when they receive the Information Commissioner's report they don't always understand the reasoning behind a particular recommendation and therefore can't extract a principle on which to base future consideration of similar access requests. The Information Commissioner does publish a small number of case summaries in his annual reports (8 in the report for 2000-2001 and 14 in the previous report). I am of the view that this practice should be expanded, with a larger number of cases reported and more detail given, particularly as to the reasoning for the Commissioner's recommendations. Everyone involved in the access process would benefit from a greater understanding of his interpretation and application of the Act.

The need for more clarity and consistency in applying the provisions of the Act has been a recurring theme in the consultations of the Task Force with co-ordinators and Departments. The publishing of the Commissioner's interpretive findings would also be of help to requesters under the Act and for investigators in solving complaints.

In respect of oversight of the application of exemptions, the Commissioner continues to favour the Ombudsman model. Indeed, as the Commissioner's officials expressed it during our meeting, the current model where the Commissioner makes recommendations instead of binding rulings, allows him to be "more courageous" with recommendations since they are not binding on institutions.

This view, however, does not seem particularly compatible with the objective of developing a coherent body of precedent and jurisprudence which, along with well developed guidelines for the evaluation of injury and application of discretion, should help to foster more open government.

Thirdly, if the Commissioner is performing an adjudicative function, he would also be more likely to adopt processes and procedures which directly address issues of procedural fairness. It is my view that the investigative process would become more transparent and understandable and, in the process, achieve more legitimacy with both those who have made complaints to the Commissioner and those in government institutions who must respond to complaints and investigations.

Finally, the adjudicative model, particularly if coupled with the imposition of time constraints and an intermediary mediation process, is, in my view, likely to result in a far more efficient and effective process for resolving disputes with respect to whether or not records ought to be released by the government.

However, this view does not appear to be held by others who have studied this issue.

In 1987 the Parliamentary Committee reviewing the Act was of the view that the Commissioner's mandate should not be changed in order to give him adjudicative powers. It had the following to say:

"Several witnesses appearing before the Committee recommended that the Information Commissioner be equipped with the power to order disclosure of records. The Committee has rejected this suggestion. Experience to date suggests that there are considerable advantages to the advisory or more informal role played by the Commissioners under the present Legislation. However, the Committee is of the view that for certain subsidiary issues (e.g., concerning fees, fee waivers, delays and so forth) the Information Commissioner should be empowered to make binding orders)." ⁽¹⁵⁵⁾

The views of the Committee obviously represent a bit of a half-way house trying to reconcile efficiency for timely resolution of process issues with the advantages of a suasion based model for the substantive ones.

The approach suggested by the Committee would be a departure from any of the other models which we looked at. In all cases the Commissioner either had an adjudicative role and the power to issue binding orders or he acted as an Ombudsman and simply issued recommendations. Nevertheless the recommendation of the Committee is worthy of more consideration. Complaints which relate to the issue of delay or to the fees being charged should, and probably can, be resolved more expeditiously.

(i) Delay Issues

Indeed, this question of how to deal with extensions of time which the Commissioner considers to be unreasonable, or with delays, has been a vexing one. At the moment, the Commissioner can investigate and make a recommendation. However, he has no authority to require the government institution to do anything. He may negotiate time frames within which records will be disclosed, or decisions on disclosure taken, but that is the extent of his power. The Federal Court has had to grapple with the issue of time extensions and time limits on at least two occasions. The issue came up in 1994 with respect to a request for records from the Department of National Defence. ⁽¹⁵⁶⁾ The Department extended the time for responding the requests by 120 days. However, at the expiration of the extended time frame the Department still had not provided the requestor with a decision. The requestor complained to the Information Commissioner on the ground that the Department had not met the deadline it had given itself. The Commissioner commenced an investigation and the Department committed to him that it would in fact provide the documents within approximately 15 days. As a result, the Commissioner considered the complaint to have been resolved.

However, thereafter, the Commissioner was informed that the Department had not met the negotiated deadline for responding to the request. Accordingly, he initiated two new complaints, on his own behalf, pursuant to s. 30(3) of the Access to Information Act. He then again discussed a resolution with the Department and they agreed on a new cut-off date for the production of the records. The Department again missed the cut-off date and the Commissioner gave one final deadline indicating that if that deadline was missed he would take the matter up before the Federal Court. That final deadline was in fact missed and the Commissioner commenced a review before the Federal Court on the basis that there had been a deemed refusal as contemplated by s. 10(3) of the Act. However, before the matter came before the Court, the Department finally gave a response in respect of the request. The position which the Commissioner took before the Court was that in light of the deemed refusal, the Department ought to be ordered to disclose any portion of the records for which it would claim a discretionary exemption. Only mandatory exemptions could still be claimed as a result of the deemed refusal.

The motions judge at the trial division held that the final decision of the Department to refuse the records did not constitute a deemed refusal to disclose, but rather a final disclosure out of time. He found that the disclosure out of time did not necessarily nullify the government institution's ability to avail itself of the exemptions provided for in the Act, including discretionary exemptions. The Commissioner and the requestor still had the opportunity to consider the appropriateness of those exemptions and commence a review if they disagreed with any of those exemptions.

The matter was appealed and the Court of Appeal found as follows:

"Under the terms of subsection 10(3) of the Act, where a government institution fails to give access to a record within the time limits set out in the Act, there is a deemed refusal to give access, with the result that the government institution, the complainant and the Commissioner are placed in the same position as if there had been a refusal within the meaning of section 7 and subsection 10(1) of the Act.

The Commissioner may then initiate a complaint under section 30 of the Act. He notifies the head of the institution (section 32). He conducts the investigation, in the course of which the institution is given a reasonable opportunity to make representations (subsection 35(2)) and for the purposes of which the Commissioner has extraordinary powers (section 36), including the power to summon and enforce the appearance of persons in the same manner and to the same extent as a superior court of record (paragraph 36(1)(a)), to enter any premises occupied by the government institution (paragraph 36(1)(d)) and to examine any record, as no record may be withheld from him on any grounds (subsection 36(2)). He provides the head of the institution with a report containing his findings and recommendations (paragraph 37(1)(a). He may specify the time which the head is to give him notice of any action taken or proposed to be taken to implement the recommendations or reasons why no such action has been or is proposed to be taken (paragraph 37(1)(b); and reports the findings of his investigation to the complainant (subsection 37(2)), but where a notice has been requested under paragraph 37(1)(b) no report shall be made until the expiration of the time within which the notice is to be given to the Commissioner.

In the instant case, as soon as the institution failed to comply with the time limit, the Commissioner could have initiated his investigation as if there had been a true refusal. He does have powers to investigate including, at the beginning of an investigation, the power to compel the institution to explain the reasons for its refusal. The Commissioner, who is master of his procedure pursuant to section 34 of the Act, chose another approach. He hoped to persuade the institution to voluntarily give the notice required under sections 7 and 10. He tried to transform, as it were, what was then a deemed refusal into a true refusal. For all practical purposes, he split his investigation into two parts, initially trying to get an answer from the institution, so he could then consider the merits of whatever answer might be provided.

On November 28, 1995, while he was working on the first part of his investigation, the Commissioner lost patience. He gave the institution fifteen days to give its notice of refusal, or else he would pursue the matter in the Federal Court of Canada. He immediately initiated a new complaint (the letter of November 28, 1995 refers to this new complaint, however this complaint is not in the record), which he says he accepted at once, and advised the institution to respond to these requests for access "within 15 days of the date of this letter". It is clear from the tone of this letter and the one he sent the complainant on November 30, 1995, that at this point the Commissioner was still only concerned with having the institution take a position on the requests for access. There was never any question of considering the merits of the refusal, and the Commissioner's recommendation dealt with the answer to be given, not at all with access to the record. That is in fact evidenced in the first conclusion sought in the review application, namely that the institution notify the complainant of its decision whether or not to give access to the record. It was only in his review application dated December 22, 1995, that the Commissioner brought up the issue of disclosure itself for the first time in the second conclusion, and as seen above, this conclusion was substantially watered down during the hearing of the application on September 23, 1996.

It is clear on the face of the letter of November 28, 1995, that the Commissioner could not do what he did "file a complaint and decide on it immediately" without even giving the institution involved the chance to respond. It would be one thing if the Commissioner were content to argue that his recommendation was limited to the first part of his investigation; we could probably accept that the institution had had more than enough opportunity to explain its delay in giving notice, however that is not the issue.

In fact, the Commissioner goes much further. He submits that the effect of the deemed refusal is to prevent the institution from subsequently invoking the exceptions set out in the Act and consequently that the Commissioner's initial investigation allowed him to decide on the merits of the complaint. This argument cannot succeed. The Commissioner was in fact still at the first stage of his investigation. The dispute between himself and the institution had never turned on the subject of actual disclosure of the report. In short, by applying to the Federal Court, the Commissioner skipped a step. He acted as if he had investigated the merits of what until that time had been a deemed refusal, although he had not yet done so.

The investigation the Commissioner must conduct is the cornerstone of the access to information system. It represents an informal method of resolving disputes in which the Commissioner is vested not with the power to make decisions, but instead with the power to make recommendations to the institution involved. The importance of this investigation is reinforced by the fact that it constitutes a condition precedent to the exercise of the power of review, as provided in sections 41 and 42 of the Act.

Accordingly, the Commissioner could not properly apply to the Trial Division of this Court for review as he had not fulfilled the condition precedent required in paragraph 42(1)(a), which provides…"

More recently, the Court has again provided a fairly strict interpretation of the provisions of the Act regarding delays and extensions with the result that there appears to be very little that the Information Commissioner can do. In a case involving the Department of Citizenship and Immigration ⁽¹⁵⁷⁾, the Department was in receipt of 55 requests for access to records. These requests all came from the same requestor and involved approximately 270,000 pages of documents. The Department extended the time for responding to their request to 3 years. The requestor filed complaints with the Commissioner claiming that the extended time limits were unreasonable. The Commissioner conducted an investigation and took the position that the extensions for a 3 year period were not reasonable. On September 20, 2000 the Commissioner wrote to the Deputy Minister. The Commissioner recommended that the Department respond to the requests, which had been divided into two categories, by November 6, 2000 and by December 6, 2000. The Commissioner went on further and made the following statement in his recommendation letter:

"If the requests listed in Annex' A and B have not been answered by the recommended dates, I will have no choice but to compel your Minister or delegate to provide the relevant records to me along with a detailed line-by-line justification for the refusal to disclose. This way of proceeding is my only option as a result of the Decision of the Federal Court of Appeal in Information Commissioner of Canada v. Minister of National Defence, (A-785-96)."

The Deputy Minister agreed to respond to the first category of documents by November 6, 2000, but indicated that it would not be possible, because of the volume involved, to respond as required with respect to the second part of the request.

Accordingly, on November 22, the Information Commissioner issued a subpoena by way of an "order with respect to production of records" pursuant to s. 36 of the Act and required the Deputy Minister to produce those records to him by December 7, 2000.

The Deputy Minister commenced an application to set aside the subpoena and, pending the hearing by the Court, the subpoena was stayed. One of the grounds raised by the Attorney General was the admission that the investigation was closed. The Commissioner had made his recommendation with respect to production, the Deputy Minister had responded, and the investigation was, therefore, at an end. Accordingly, the Commissioner initiated a second complaint in accordance with s. 30(3) on the basis that he was satisfied that there were reasonable grounds to investigate the Department's deemed refusal to disclose those records as well as the actual refusal to disclose others.

He then issued a second subpoena and the Attorney General commenced a second proceeding to quash that subpoena as well.

Accordingly, the Court was faced with two issues. The first complaint by the requestor and subpoena raised the issue of whether the extension period taken by the Department was unreasonable. The self initiated second complaint and related subpoena raised the issue of whether the unreasonable extension of time constituted a deemed refusal to give access to the records. The Attorney General took the position that both subpoenas were issued in excess of the Commissioner's jurisdiction. The Court agreed.

With respect to the first investigation the Court had the following to say:

"The subpoena power is 'in relation to the carrying out of the investigation'. In my opinion, when the investigation is completed, the subpoena power is exhausted. I find that the investigation with respect to the complaints that the extensions were unreasonable was completed on September 20, 2000, and that the respondent no longer had the jurisdiction to issue the subpoena on November 22, 2000 ordering the production of the records subject of the access requests."

With respect to the second subpoena, the Court also found that there was an excess of jurisdiction because:

"Parliament has clearly provided for 'deemed refusals' in section 10(3), but not elsewhere in the Act. A 'deemed refusal' is when the department fails to give access to the record within the time limits set out in the Act, i.e. either 30 days as provided in section 7 or an extended time limit under section 9. In my opinion, in this case, the extended time limit has not expired so that there can be no "deemed refusal" to give access. Under the Act there is no provision for the respondent to deem an unreasonable extension of time as a refusal."

As can be seen from these two cases, the power of the Commissioner to have any practical effect with respect to extensions of time or failures to meet the time limit for providing access is extremely limited. He can only negotiate with the departments in order to try to achieve a time frame for responding to a request which will resolve the complaint.

Similarly, the Courts themselves have been reluctant to find that they can issue any coercive orders with respect to the production of records. They have been prepared to issue various declarations but have not been prepared to actually order the release of records on the basis of a deemed refusal. ⁽¹⁵⁸⁾

Accordingly, as presently structured, the Office of the Information Commissioner has limited tools to deal with the issue of delay, whether by lengthy extensions or whether by failure to meet a time limit for responding to a request. It may, in fact be, at least in part, because of this limitation on the powers of the Commissioner and his inability to force compliance with time limitations that the Commissioner has taken some of the steps which he has to publicise the issue of delays, the only avenue he has. As Alasdair Roberts notes: ⁽¹⁵⁹⁾

"The OIC has experimented with targeted enforcement, by using existing statutory powers to elicit the co-operation of institutions with poor grades on its annual reports. This has included the use of subpoena powers to capture the attention of senior manages and encourage internal reforms to improve performance. In one respect, this effort has been a success. Departments that have been the object of OIC investigations have significantly improved their performance in complying with statutory. However, the use of these powers has also had substantial costs. The use of subpoenas has alienated senior officials, perhaps because they suggest a degree of personal culpability, or convey an impression of criminality, that senior officials consider unjustified. The OIC's existing powers are crude tools for responding to problems of maladministration and systematic non-compliance within federal institutions.

Other laws contain better tools for dealing with problems of systemic non-compliance. Under the Employment Equity Act, the Canadian Human Rights Commission uses statistical reports and compliance plans provided by the federal institutions to monitor their progress in eliminating employment practices that harm disadvantaged groups. The Commission is also authorized to undertake compliance audits of federal institutions and negotiate plans for remedial action. If necessary, the Commission can direct institutions to take specific measures to remedy the non-compliance, and may seek to have these directives enforced as thought they were orders of the Federal Court.[Footnote omitted]

The addition of comparable powers to the ATIA would rightly be regarded as a significant strengthening of the authority of the Information Commissioner. Nevertheless, it could also help to restore working relationships between the OIC and federal institutions. These new enforcement tools would reduce the Commissioner's need to rely on other powers to address problems of systemic noncompliance. The task of remedying such problems would be routinized and the taint of criminality removed."

Another suggestion which the Commissioner has made is that the legislation be amended to provide for sanctions against departments that are late in responding to requests. These sanctions would include a prohibition against charging any fees which otherwise might be payable and loss of the authority to invoke any of the discretionary exemptions found in the legislation. The latter sanction would be mitigated by some mechanism which would provide for a "saving clause" which the Commissioner suggested might be invoked only by the Prime Minister. ⁽¹⁶⁰⁾ In his 2000-2001 Report (p. 60) the Commissioner recommended that the prohibition for invoking exemptions be limited to sections 21 and 23.

These solutions do not seem to present the most effective way of dealing with the issues of delays and long extensions. In my view, the better approach is to meet the issue head on. To the extent that the problem is caused by poor records management and lack of resources within departments, the issue needs to be addressed by the government. To the extent that the issue is a deliberate failure on the part of departments to honour their obligations, then an order power on the part of the Commissioner would seem to be the most effective tool. Such an order power would, of course, be subject to judicial review.

While the Commissioner may not be adverse to having order powers with respect to issues such as delay and the extension of time limits, both the present Commissioner and his predecessor, John Grace, have expressed the view that they believe that the current model is the most effective and the one which they believe gives them the most flexibility. Mr. Grace had the following to say in a 1994 speech: ⁽¹⁶¹⁾

The classic ombudsman possess influence and moral suasion rather than power. … Critics of the legislation take aim at the Commissioner's seeming lack of power - his inability to compel release of document. The virtue of the ombudsman's approach is, however, that it allows for a less adversarial, less legalistic, more informal style. The test of a constructive relationship with government institutions is whether it results in the release of more information than under a regime with the power to enforce orders.

However, the issue of delay is one that may require more than moral suasion.

(ii) Publication of Reasons

In my view, some of the disadvantages of the current model could be addressed by having the Commissioner issue summaries of his decisions on points of general interest where other requestors and other departments would benefit from his views on matters which have a broad interest. In fact, we note that this request has been made to the Privacy Commissioner, particularly in the context of his role under the Protection of Personal Information and Electronic Documents Act. He has in fact posted some of his recent decisions. The UK Parliamentary Ombudsman overseeing the application of the Code of Practice also publishes his interpretative findings.

Indeed, even if the Commissioner continues to function as an ombudsman, there is no reason why he could not report his conclusions in the same way that an adjudicative officer publishes decisions. In Nova Scotia, the oversight of access to information is by the Information Review Officer who is an ombudsman and who only has the power to make recommendations. ⁽¹⁶²⁾ The Review Officer does, however, publish his findings and recommendations and these are available on his web site. ⁽¹⁶³⁾ These are structured in much the same way as a decision, setting out the issue, background, the government's position, the applicant's position and a conclusion that refers to statutory provisions and caselaw. Most of the decisions are four to seven pages in length. The Review Officer has been writing and publishing his Review Reports for several years and has, to date, issued over 300 such reports. Approximately 100 can be found on Quicklaw.

The published Reports are used as reference points by public bodies covered by the legislation. While the Reports are not binding precedents, we are advised that they are often used by public bodies in considering access requests and do give a clear direction to public bodies as to how the Review Officer views the issues. ⁽¹⁶⁴⁾ There is no reason why the federal Commissioner could not provide his reports, or at least a selection dealing with issues that address the interpretation of the Access to Information Act and the exempting provisions, in this manner as well.

(iii) Other Considerations

Clearly, both the adjudicative model and the ombudsman model have advantages and disadvantages. To date the federal preference seems to have been for the ombudsman model in a number of areas. Indeed, the Information Commissioner is but one of a group of federal Ombudsmen who all operate under legislation which gives them similar powers to investigate and report, by way of recommendation. ⁽¹⁶⁵⁾ It may, therefore, be appropriate to undertake an examination of the question of whether the ombudsman model continues to be the most appropriate as part of a more comprehensive review which would consider these other pieces of legislation as well.

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152. Section 14

153. Section 54

154. John Reid, supra note 10

155. "Open and Shut" supra note 146 at p. 37

156. Canada (Information Commissioner) v. Canada (Minister of Defence), [1999] F.C.J. No. 522 (QL) (FCA), A-785-96, judgment dated April 19, 1999; aff'g in part (1996), 120 F.T.R. 207 (F.C.T.D.)

157. Supra note 6

158. Canada (Information Commissioner) v. Canada (Minister of External Affairs), [1989] 1 F.C. 3 (T.D.)
Canada (Information Commissioner) v. Canada (Minister of External Affairs), [1990] 3 F.C. 514 (T.D.)

159. Roberts, supra note 7 at p. 18

160. John Reid, Remarks to Conference on Access to Information Reform, Ottawa, Ontario, May 1, 2000.

161. The Access to Information Act: 10 Years On, 1994 Ottawa, Ontario, Office of the Information Commissioner. See also: Roberts, supra note 7

162. Supra note 134, Section 39

163. http://www.gov.ns.ca/foiro/content/reviewreports.htm

164. Task Force discussions with Darce Fardy, Nova Scotia's Information Review Officer and with Bob Doherty, a senior Access to Information co-ordinator in the Nova Scotia Department of Justice

165. Privacy Act; supra note 20, Official Languages Act and Corrections and Conditional Release Act, supra note 130