Access to Information Policy – March 27, 2026
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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:
March 27, 2026
Primary Contact:
The Access and
Privacy Office
Review
Scheduled:
March 27, 2031
Approver:
Board of Governors
A.
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 Access to Information Act (the "Act") and
other similar legislation.
B.
SCOPE
This Policy applies to all requests for Records under the custody or control of the University.
C.
POLICY STATEMENT
1.
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 delegated by the President may
not further sub-delegate. Delegations by the President are captured in the Access
and Privacy Delegation of Authority Table.
1.3
The Access and Privacy Office is responsible for providing the University community
with planning and guidance on responding to Informal Access to Information
Requests, managing all Formal Access to Information Requests and is responsible
for responding to the Commissioner’s Office.
1.4
Records 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 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 – March 27, 2026
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1.6
Individuals may request access to Records from the University through an Informal
Access to Information Request or a Formal Access to Information Request.
2.
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 contained in the Records in
accordance with the Act.
2.2
Departments 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 Records.
3.
FORMAL ACCESS TO INFORMATION REQUESTS
3.1
Formal Access to Information Requests must be submitted to the Access 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 Access and
Privacy Office is responsible for estimating any fees required to complete a request
for Records.
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 Access 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
be destroyed, deleted, or altered.
Access to Information Policy – March 27, 2026
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4.
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.
4.2
The University will respond to all complaints in accordance with the Procedure for a
Formal Access to Information Request.
D.
DEFINITIONS
(1)
Access and Privacy
Office:
means the Information Management & Privacy Advisor and the
leaders within the Access & Privacy Office.
(2)
Act, the:
means the Access to Information Act of Alberta. Also known as
the “ATIA” or the Act..
(3)
Commissioner:
means the Information and Privacy Commissioner appointed in
accordance with the Act.
(4)
Department:
means a faculty within the Academic Division or a department
outside of the Academic Division.
(5)
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.
(6)
Formal Access to
Information
Request:
means a request for access to Records made to the University
through the Access and Privacy Office under the formal
processes under the Act.
(7)
Informal Access to
Information
Request:
means a request to a University Department for Records that is
made outside of the formal processes under the Act.
(8)
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,, marital status or family status,
d. the individual’s gender identity, sex or sexual
orientation,
e. an identifying number, symbol or other particular
assigned to the individual,
Access to Information Policy – March 27, 2026
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f. the
individual’s
fingerprints,
other
biometric
information, blood type, genetic information or
inheritable characteristics,
g. information about the individual’s health and health
care history, including information about a physical or
mental health,
h. information about the individual’s educational,
financial, employment or criminal history, including
criminal records where a pardon has been given,
i. anyone else’s opinions about the individual, and
j. the individual’s personal views or opinions, except if
they are about someone else.
(9)
Policy:
means the Access to Information Policy.
(10)
Record:
means any electronic record or other record in any form in
which information is contained or stored, including information
in any written, graphic, electronic, digital, photographic, audio
or other medium, but does not include any software or other
mechanism used to store or produce the record.
(11)
University:
means Mount Royal University.
E.
RELATED POLICIES
● Information Security Policy
● Privacy Policy
F.
RELATED LEGISLATION
● Access to Information Act, SA, 2024, C A-1.4
●
Protection of Privacy Act, SA, 2024, c P-28.5
G.
RELATED DOCUMENTS
● Procedure for a Formal Information Request
● Access to Information Request Form
● Access and Privacy Delegation of Authority Table
Access to Information Policy – March 27, 2026
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H.
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
03/27/2026
Major
All
Information
Management &
Privacy Advisor
Board of Governors