Access to Information Policy – June 11, 2021

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ACCESS TO INFORMATION POLICY

Policy Type:

Management

Initially

Approved:

June 11, 2021

Policy Sponsor:

General Counsel

and University

Secretary

Last

Revised:

Primary Contact:

Information

Management &

Privacy Office

Review

Scheduled: June 11, 2026

Approver:

Board of Governors

PURPOSE

This Policy addresses how the University responds to requests for information that the University

holds. The University strives to respond to any such requests in an open transparent manner while

ensuring that it adheres to its obligations under Alberta’s Freedom of Information and Protection of

Privacy Act (the "Act") and other similar legislation.

SCOPE

This Policy applies to all requests for Records or information under the custody or control of the

University.

POLICY STATEMENT

ACCESS TO INFORMATION

1.1

The University complies with all requirements of the Act and all other legislation that

is applicable to the University’s obligation to ensure an individual’s right to access to

information under the custody or control of the University.

1.2

The President is ultimately accountable for processing requests for access to

information and may delegate to an Employee any of the duties or functions of the

President under the Act, in writing. However, those delegates may not further sub-

delegate. Delegations by the President are captured in the FOIP Delegation of

Authority Table.

1.3

The Information Management and Privacy Office is responsible for providing the

University community with planning and guidance on responding to Informal Access

to Information Requests, manages all Formal Access to Information Requests, and

is the official spokesperson for the University with the Commissioner’s Office.

1.4

Records or information may be disclosed internally to Employees acting in their

official capacity, in accordance with the Privacy policy.

1.5

Individuals have a right to make requests to access information and Records under

the control or custody of the University, including to access their own Personal

Information, subject to the exceptions under the Act.

Access to Information Policy – June 11, 2021

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1.6

Individuals may request access to information or Records from the University

through an Informal Access to Information Request or a Formal Access to

Information Request.

INFORMAL ACCESS TO INFORMATION REQUESTS

2.1

Employees who receive an Informal Access to Information Request will make

reasonable efforts to respond and provide Records under the custody or control of

the University, provided that:

a. the Record does not contain Personal Information, except if the Personal

Information is solely about the individual requesting the Record;

b. the Record does not contain the information of a third party;

c. the Record does not contain information that may be harmful to individuals, third

parties or the University;’

d. the Record does not contain information that has been classified as confidential;

and

e. the University can otherwise release the information in accordance with the Act.

2.2

Units who receive frequent or routine Informal Access to Information Requests may

establish their own processes for responding to such requests.

2.3

Employees who are unable to satisfy an Informal Access to Information Request will

advise the requestor that they may file a Formal Access to Information Request for

the requested information.

FORMAL ACCESS TO INFORMATION REQUESTS

3.1

Formal Access to Information Requests must be submitted to the Information

Management and Privacy Office through either the Access to Information Request

Form or otherwise provided in writing.

3.2

Requests may be subject to fees set out in the Act to undertake the process

necessary to process, or fulfill, an Access to Information Request. The IMPA is

responsible for estimating any fees required to complete a request for information,

in consultation with any applicable unit(s).

3.3

The University will respond to all Formal Access to Information Requests in an open

and transparent manner in accordance with the Procedure for a Formal Access to

Information Request.

3.4

Employees are required to cooperate with the University’s Information Management

and Privacy Office in addressing a request for information and must make every

reasonable effort to identify, locate, and retrieve all applicable Records. If an

Employee is notified of a Formal Access to Information Request, any records relating

to the request will not destroyed, deleted, or altered.

Access to Information Policy – June 11, 2021

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COMPLAINTS

4.1

The Office of the Commissioner is authorized under the Act to investigate complaints

by requestors regarding fees, timelines and University decisions relating to a Formal

Access to Information Request. Individuals who are not satisfied with the University’s

response to a request may contact the Commissioner’s Office directly.

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 the Act

(2)

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

(3)

IMPA:

means the University’s Information Management & Privacy

Advisor

(4)

Informal Access to

Information

Request:

means a request to a University unit for information/Records

that is made outside of the formal processes of the Act

(5)

Formal Access to

Information

Request:

means a request for access to information/Records made under

the formal processes of the Act

(6)

Personal

Information:

means recorded information about an identifiable individual,

including:

a. the individual’s name, home or business address or

home or business telephone number,

b. the individual’s race, national or ethnic origin, colour or

religious or political beliefs or associations,

c. the individual’s age, sex, marital status or family status,

d. an identifying number, symbol or other particular

assigned to the individual,

e. the individual’s fingerprints, other biometric

information, blood type, genetic information or

inheritable characteristics,

f. information about the individual’s health and health

care history, including information about a physical or

mental disability,

Access to Information Policy – June 11, 2021

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g. information about the individual’s educational,

financial, employment or criminal history, including

criminal records where a pardon has been given,

h. anyone else’s opinions about the individual, and

i. the individual’s personal views or opinions, except if

they are about someone else.

(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)

University:

means Mount Royal University

RELATED POLICIES

•

Information Security Policy

•

RELATED LEGISLATION

•

Freedom of Information and Protection of Privacy Act, RSA, 2000, c F-25

RELATED DOCUMENTS

•

Procedure for a Formal Information Request

•

Access Request Search Summary

•

Access to Information Request Form

•

FOIP Delegation of Authority Table

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