Annual Report to Parliament 2024-2025: Access to Information Act

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© His Majesty the King in Right of Canada, represented by the Minister of Justice and Attorney General of Canada, 2025.

ISSN 2369-2618
Cat. No. J1-15E-PDF

Table of Contents

• Introduction
  • A Message from the Director
  • Purpose of the Access to Information Act
  • Mandate of the Department of Justice
  • The Modernization of ATIP in the Department
  • Initiatives and Projects to Improve Access to Information
  • Outreach & Collaboration
• Policies, guidelines, and procedures
  • Updated Procedures and Policies
  • Updated ATIP Standard Operating Procedures
  • Improved Analytics and Technology
  • Retention and Professional Development
  • Commitment to Diversity and Employment Equity
• Organizational structure
• Delegation order
• Performance and statistics
  • Number of Requests
  • Compliance Rate, Completion Times and Extensions
  • Deemed Refusal Rate
  • Outstanding Requests
  • Disposition of Completed Requests
  • Requests, Exemptions and Exclusions
  • Informal Requests
  • Sources and Types of Requests
  • Format of Information Released
  • Consultations
  • Active Complaints
  • Costs
• Training and awareness activities
  • Training Sessions
• Complaints, investigations and federal court cases
  • Complaints Filed
  • Key Issues and Actions Taken on Complaints
  • Completed Investigations
  • Review by the Federal Court of Canada
• Monitoring compliance
  • Proactive Publication
• Annex A – Delegation order
• Annex B – Proactive publications requirements table

Introduction

The Department of Justice is pleased to present to Parliament, in accordance with section 94 of the Access to Information Act (ATIA), its annual report on the management of this Act. The report describes the activities that support compliance with the ATIA for the fiscal year commencing April 1, 2024, and ending March 31, 2025.

A Message from the Director

The year 2024-25 was characterized with purposeful, cautious growth, with Access to Information and Privacy (ATIP) modernization and digital transformation held as a top priority. The Department made notable strides in adopting ATIPXpress, our new advanced request processing and case management software. This software will be hosted on the Government of Canada's Platform as a Service, using a standard cloud architecture that emphasizes efficiency and innovative architectural solutions. The careful adoption of modern tools and skill building act as a foundation for continued innovation in ATIP practices.

To complement these technological advances, we must also acknowledge the human aspect of ATIP. Change cannot be accomplished without an agile, skilled team. The ATIP Division is equipped with the necessary tools to meet and support this moment of ATIP advancement. Together with the ATIP management team, we are focused on building trusting relationships with our internal clients and further developing analyst skills and knowledge.

This past year, there has been a particular focus on the heightened pressures of complaints from the Office of the Information Commissioner (OIC), which must be strategically managed, to ensure sustained progress. We continue to seize on diverse opportunities for ATIP readiness, such as support from the Department’s Paralegal Services Centre, and numerous initiatives involving artificial intelligence (AI) with our colleagues from the Analytics and Systems Division.

This report serves as a comprehensive summary of key milestones and accomplishments from the 2024-25 fiscal year. 2025-26 is brimming with potential for smarter business practices, renewed relationships, and client service excellence for all Canadians.

Purpose of the Access to Information Act

The ATIA was proclaimed into force on July 1, 1983.

The ATIA gives Canadian citizens, permanent residents and any person or corporation present in Canada the right to seek access to federally controlled information and records, subject to specific and limited exceptions. The ATIA complements but does not replace existing procedures for obtaining government information. It is not intended to limit in any way the access to government information that is normally available to the public upon request. Section 94 of the ATIA requires that the head of every government institution prepare for submission to Parliament an annual report on the administration of the ATIA within the institution during each fiscal year.

This 42nd Annual Report on the administration of the ATIA is intended to describe how the Department of Justice Canada (hereinafter referred to as “the Department”) administered its responsibilities during the 2024-2025 fiscal year (hereinafter “during the reporting period”).

Mandate of the Department of Justice

The Department has the mandate to support the dual roles of the Minister of Justice and the Attorney General of Canada.

The Department supports the Minister of Justice in his responsibilities for 49 statutes and areas of federal law by ensuring a bilingual and bijural national legal framework principally within the following domains: criminal justice (including youth criminal justice), family justice, access to justice, Indigenous justice, public law and private international law.

The Department also supports the Attorney General as the chief law officer of the Crown, both in terms of the ongoing operations of government and of the development of new policies, programs, and services for Canadians. The Department provides legal advice to the Government and federal government departments and agencies, represents the Crown in civil litigation and before administrative tribunals, drafts legislation and responds to the legal needs of federal departments and agencies.

The Department did not have any non-operational (“paper”) subsidiaries during this reporting period.

The Modernization of ATIP in the Department

The Department is committed to strengthening transparency, accountability, and service excellence in Access to Information and Privacy administration. The Department’s ATIP Modernization Plan (2024–2027) provides a strategic framework to enhance request management under the ATIA and the Privacy Act positioning the Department as a leader in innovative ATIP service delivery within the public sector.

A key initiative under this Plan is the implementation of ATIPXpress, a modernized case management system designed to streamline request processing and harness advanced technologies to improve productivity. The adoption of this system also presents an opportunity to review and formalize internal ATIP policies and procedures, reinforcing a culture of continuous improvement in information management. By integrating modernized tools with refined processes, the Department will set new standards for data-driven decision-making, compliance, and service excellence.

Collaboration with departmental stakeholders is central to this modernization effort. Strengthening partnerships will enhance knowledge-sharing, role clarity, and best practices, ensuring ATIP operations remain responsive and effective. The Department will also prioritize the rigorous application of new policies and procedures, reinforcing its commitment to transparent and accountable governance.

The Plan’s objectives will be operationalized through the Access to Information and Privacy Action Plan, which will outline clear actions and measurable outcomes. This structured approach reflects the Department’s dedication to leading ATIP transformation through strategic investments in skilled professionals, advanced technologies, and modernized service delivery.

Through these initiatives, the Department will not only enhance public trust but also establish itself as a model of innovation and efficiency in ATIP administration, setting new benchmarks for transparency and accountability within the Government of Canada.

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Key achievements 2024-2025

April: ATIPXpress Process Maps

May: ATIP Toolkit Updates

June: Wellness & Professional Development Sessions

August: Interdepartmental Group on Privacy, Harassment & Disciplinary Files

September: Right to Know Week 2024

October: TBS Updates to Privacy Suite

November: OPC/OIC Connect Event

December: AI & Privacy Deep Dive Series

January: Data Privacy Week 2025

February: ATIP SOP Updates

March: Policy on Obstruction & Guide on Control at Justice

Initiatives and Projects to Improve Access to Information

During the reporting period, the ATIP Division continued to improve the support and guidance it provided to Offices of Primary Interest (OPIs) at the Department over the reporting period. This included developing additional tools and resources, as well as increasing general ATIP awareness.

We fostered improved communication and collaboration strategies and relationships with all OPIs, liaison officers, and the ATIP Division. The Division is currently also in the process of developing and launching a Teams Channel to communicate effectively with OPIs.

The ATIP Division further increased its visibility and promoted its service offerings through awareness campaigns on ATIP best practices and risks, delivered training sessions, and communicated the latest updates via departmental newsletters and communications channels.

We also continued to proactively monitor new developments and best practices in access to information and privacy, to integrate them into our own processes, as well as contribute to the modernization of ATIP.

External ATIP Digital Workspace and ATIP Toolkit

In May, the ATIP Division launched an external page on its Digital Workspace site, featuring an ATIP Toolkit that houses a variety of helpful resources on access to information and privacy. The Toolkit offered employees quick and easy access to various privacy and access-to-information-related resources and information. It featured various infographics, one-pagers and fact sheets, as well as easily accessible forms and templates.

The Toolkit is regularly updated with new resources, serving as a valuable reference to ensure employees have the necessary information to navigate ATIP requirements and ensure compliance with both Acts across the Department.

ATIP Internal Newsletter

The ATIP Division shared updates, resources and news via the departmental weekly newsletter, as well as its own internal newsletter. The ATIP Internal Newsletter offered a monthly overview to the ATIP Division from the Privacy and Programs Unit, as well as the Complaints and Operations teams. This helped foster communication and cooperation within the Division by providing timely updates and insights from key teams. It ensured that all members remained well informed about ongoing initiatives, challenges, and successes, promoting a more cohesive and efficient work environment.

Outreach and Collaboration

The ATIP Division leveraged the services of various programs at the Department, which provided us with much-needed expertise and support. These partnerships allowed us to access specialized legal guidance and resources, enhancing our ability to navigate complex access to information and privacy matters.

Additionally, the ATIP Division remained committed to supporting our current staff through continuous training and professional development. We provided additional learning and training opportunities to our employees and OPIs, so that they are well equipped to manage our workload effectively, and to continue fostering a positive and collaborative work environment.

ATIPXpress Process Mapping

The ATIP Division worked with the Change Management and Business Transformation team to review workflows at the Department for process mapping, in hopes of compiling research on relevant best practices. The process maps were also developed and shared as part of the interdepartmental ATIPXpress working group with other institutions, to identify any feedback for the vendor or important functional features for the ATIPXpress case management system.

Interdepartmental Collaboration

The ATIP Division engaged in a variety of interdepartmental working groups and sessions related to ATIP through GCCollab. Regular coordination with other departments allowed our team to stay in the loop regarding important updates and relevant best practices in relation to both Acts.

OIC and OPC Connect Event

In November, the ATIP Director attended a Connect Event for privacy officers and chief information officers hosted by the Office of the Privacy Commissioner (OPC) and the Office of the Information Commissioner (OIC) to discuss emerging trends and issues in ATIP.

Right to Know Week 2024

The ATIP Division marked Right to Know Week 2024 with the release of an updated departmental Info Source, a repository describing programs and activities, as well as personal information holdings. The Division also shared new content on our external Digital Workspace page. This included helpful one-pagers, quick references and resources on topics for the Department, such as the 10 Right to Know Principles, the Responsibilities of the OPI, Access to Information Requests & Records, as well as Information Management.

Policies, guidelines, and procedures

Updated Procedures and Policies

During the reporting period, the ATIP Division updated its policies and procedures to enhance productivity in processing ATIP requests. Our goal was to provide the OPIs and liaison officers with a repository of up-to-date information where they can find several tools and guidance materials to help them with the processing of ATIP requests. Furthermore, we aimed to promote awareness of and inform the Department’s employees of their existing legal obligations and responsibilities under both the Privacy Act and ATIA.

Our internal policies were developed and published on the Departmental intranet, JUSnet, and the ATIP Division’s external Digital Workspace page.

These improvements will further the sharing of knowledge generally and clarify roles and responsibilities for all those involved in the processing of requests.

During the 2024-2025 reporting period, the ATIP Division also completed the development of several new policies, guidelines, and supplementary resources for the Department and OPIs. By establishing clear requirements and guidelines, these new policies aimed to ensure compliance with the ATIA and Privacy Act, as well as protect both records, and the integrity of the ATIP framework within the Department.

Updated ATIP Standard Operating Procedures

The ATIP Division focused on updating various Standard Operating Procedures (SOPs) over the reporting period. The development of detailed and standardized SOPs marked a significant milestone in enhancing our operational efficiency. These procedures defined the steps for receiving, processing, and responding to information requests, ensuring consistency and minimizing the risk of errors or delays. Regularly reviewed and updated, the SOPs reflect the latest legislative requirements, technological advancements, and best practices in information access management. They also served as a valuable training resource for new staff, promoting continuity and maintaining the highest standards of service delivery.

The Privacy Policy and Programs Unit and ATIP Division developed an internal Guide on Determining the Control of Records for the Purpose of the ATIA and Privacy Act, which offered guidelines and requirements regarding the control of records at the Department. It also indicated the responsibilities of employees and management of all levels, as well as the role of relevant teams that must be consulted in matters of control (ATIP Division, Corporate Counsel, and the Centre for Information and Privacy Law).

It also outlined requirements regarding compliance, protection of personal information, proper handling of records and legal records, assessment of control of records, scenarios for authorized disclosure under subsection 8(2) of the Privacy Act as well as reporting and documentation.

The guide was developed in consultation with ATIP Operations, Security, Business Management and Governance, Communications, Information Management, Corporate Counsel, the Legal Practices Policy Division, as well as the Center for Information and Privacy Law (CIPL).

Along with the Guide on Determining Control, the Privacy Policy and Programs Unit also developed a policy on the Obstruction to the Right of Access of Information, in accordance with s. 67.1 of the ATIA.

This policy sets out existing obligations and responsibilities for employees under the ATIA and Privacy Act. It also aligned with those published by other departments to ensure that any suspected obstructions are handled in a consistent manner. The Department regularly receives ATIP requests and, as the obstruction to the right of access to records is a serious offence, it is important that the Department’s employees stay informed and have proper protocols in place to prevent, investigate, and address any suspected obstructions.

The policy was developed in consultation with CIPL, Chief Security Officer (CSO), the National Litigation Sector, the Legal Practices Policy Division, and Corporate Counsel.

Quick reference guides were also developed to supplement the newly established policies on Obstruction to the Right of Access and the Control of Records. These guides were designed to provide employees with a clear and concise overview of their obligations and responsibilities under these policies, helping to ensure greater understanding and compliance. By offering easily accessible information in plain language, the guides aimed to enhance employee awareness, ensure they are informed about privacy risks and responsibilities, and facilitate the effective implementation of the policies across the Department.

Improved Analytics and Technology

One of the main focuses of the ATIP Division’s ongoing modernization plan is the implementation of a new ATIP case management solution, ATIPXpress.  Adoption of this key initiative creates an opportunity to evaluate and formalize internal ATIP policies and procedures. It will also result in sustainable cooperation with key stakeholders through the exchange of knowledge, clarification of roles and improved analytics and reporting, demonstrating the Department’s commitment to continuous process improvement.

The ATIP Division team participated in training with the vendor to better understand how the system works and its various functions.

The ATIP Division continued to engage with the ATIPXpress Community of Practice and also hosts its own ATIPXpress sub-working group. This interdepartmental working group was established to exchange best practices and identify areas for joint efforts to ease the phasing in of the new case management system.

Several departments have collaborated with the Department’s ATIP Division to develop resources such as workflows and process maps, and to discuss the modernization process. The main goal of these meetings and working sessions has been to identify how ATIPXpress fits within the multiorganizational needs of ATIP services and privacy professionals. There has also been a focus on refining existing activities and functions in the Access Pro Case Management system and anticipating upcoming changes to the Privacy Act.

During the reporting period, the Modernization team completed User Acceptance Testing sessions to gather feedback, and the production build for the software began with Shared Services Canada. The ATIP Division anticipates an introductory launch of the ATIPXpress software early into the new fiscal year.

Retention and Professional Development

Employee Wellbeing and Professional Development

In the previous fiscal year, the ATIP Division collaborated with the Change Management and Business Transformation team as part of the ATIP Modernization Strategy. They identified areas to promote employee retention, wellbeing, professional development.

They also led us to identify several topics and areas for training to assist the ATIP staff and OPIs. The ATIP Division held a variety of presentations and training for its internal employees. Some of these topics include:

• The Power of Failure
• Mental Health and Wellness
• Giving and Receiving Feedback
• Communication Styles
• Myers-Briggs Type Indicator Presentation
• Ergonomic Workshop
• Minding Difficult Conversations
• Solicitor-Client Privilege and Section 23
• Public Service Values and Ethics

ATIP training, language training, as well as other training to develop employee competencies and knowledge surrounding professional development, networking, technology and program-specific training were also regularly provided to employees throughout the reporting period.

Finally, ATIP Division employees participated in several internal and interdepartmental training sessions, information sessions and seminars related to access and privacy. These exchanges with other departments allowed our Division to stay up-to-date on new ATIP practices and upcoming trends, while also contributing to the modernization of our team and informing best practices.

Commitment to Diversity and Employment Equity

To be able to serve the public effectively, the Department and its workforce needs to accurately reflect the diversity of the Canadian population. We actively recruit members of Employment Equity designated groups and encourage them to self-identify.

Organizational structure

The Director of the ATIP Division reports to the Senior General Counsel and Director General of the Legal Practices Branch (LPB) under the Management Sector. This structure allows us to focus on modernization initiatives, as well as benefit from additional legal and analytics services within LPB. The Director is accountable for the development, coordination and implementation of effective policies, guidelines, systems, and procedures to efficiently process requests under the ATIA.

During the reporting period, the Department’s ATIP Division had a total of 31.38 full-time equivalent (FTE) positions working on access to information requests and privacy files, and three consultants. To support the administration of the ATIA, the ATIP Division had a total of 19.44 FTE positions, in addition to 0.086 part-time and casual equivalent positions, 2.13 consultants, and 0.58 student positions.

The ATIP Division is organized into three units:

• The Operational Unit works with the Department to process incoming access to information and privacy requests,
• The Privacy, Policy and Programs Unit develop ATIP policies, provides advice on privacy-related matters, updates annual reports and other statutory reports; and
• The Complaints Unit processes complaints and works closely with the OIC and the OPC.

In addition, the ATIP Division is currently working on modernizing its ATIP management system to achieve better performance and is building a team with information technology experts. The team will ensure a smooth transition to the new platform.

Under section 73.1 of the ATIA, institutions reporting to the same minister can partner to share request-processing services. The Department currently has a Memorandum of Understanding with the Law Commission of Canada as of 2023.

The Department’s ATIP Division is comprised of a dedicated workforce committed to access to information and the protection of privacy. This work includes:

• The timely processing of requests under the ATIA and assisting clients in accordance with the principles for assisting requestors.
• Processing consultation requests submitted by other federal institutions on Department documents located in their files and on records that may be subject to solicitor-client privilege.
• Providing advice and guidance to senior management and all employees of the Department on ATIP-related matters, as well as training and awareness sessions.
• Responding to complaints and negotiating with the OIC and OPC.
• Liaising on behalf of the Department with the Treasury Board Secretariat (TBS), the OIC and OPC and other government departments and agencies regarding the application of the ATIA.
• Coordinating, reviewing, approving and publishing statutory reports such as the Annual Reports to Parliament.
• Ensuring obligations for proactive publication are met.
• Developing, coordinating and implementing policies, procedures and guidelines for the orderly implementation of the ATIA by the Department.
• Modernizing the ATIP processes and the ATIP Management technologies by building a small team that evaluates new digital solutions that can reduce business processes, reduce the time needed for requests, increase quality and helps all stakeholders more easily engage in the process.

The work of the ATIP Division is supported by 26 OPIs within the Department. These offices are responsible for locating and providing the records responsive to requests and providing recommendations about the disclosure of records in compliance with the provisions of the ATIA.

The Department is also organized to effectively manage its responsibilities under Part II of the ATIA on Proactive Publication. The ATIP Division plays a central role, with a dedicated Senior Advisor overseeing proactive publication efforts. Additionally, an intake team and other ATIP analysts support this process as needed.

The ATIP Team also collaborates with and has delegated certain obligations to various internal programs, including Communications, Finance, the Cabinet and Parliamentary Affairs Unit, and the Ministerial Secretariat, to ensure compliance with proactive publication requirements, deadlines, and responsibilities.

The Department was not a party to any new or pre-existing service agreements under section 96 of the ATIA during the reporting period.

Delegation order

The ATIP Director and ATIP Deputy Director have full authority delegated by the Minister for the administration of the ATIA.

For the purpose of increased executive oversight, full authority is also conferred to the Deputy Minister, the Associate Deputy Ministers, the Assistant Deputy Minister and Chief Financial Officer, Management Sector and the Senior General Counsel and Director General, Legal Practices Branch. A copy of the Department’s Delegation Order is at Annex A of this report.

Performance and statistics

The Department is committed to transparency and accountability under the ATIA and continues to work to improve its performance to deliver the highest standards of service for access to information requests.

Number of Requests

Overview of requests received and completed by the Department pursuant to the ATIA:

The Department received 327 requests during the reporting period, which is a slight decrease from the 392 requests received in the previous reporting period. In addition, 548 outstanding requests from previous years were carried over, for a total of 875 requests.

This trend is partially due to various delays in closing more complex requests within legislated timelines. As a result, the number of files specifically carried over beyond legislative timelines also remained high, from 488 in the previous reporting period to 479 in 2024-2025.

During the reporting period, 352 requests were completed, representing an increase compared to the previous reporting period in which 291 requests were closed. In addition, 523 requests were carried forward into the fiscal year 2025-2026.

Responding to formal access to information requests involved the review of 295,060 pages, of which 18,857 pages were partially disclosed. This represents a significant increase compared to the previous reporting period, however, 213,025 (72%) of the 295,060 pages were abandoned by the requester. As a result, 82,035 pages were assessed, which is a decrease from the total pages processed in the previous reporting period.

The number of pages processed in this reporting period only captures pages from closed files. In 2024-2025, a large number of pages were processed on files that are not yet closed. These will be captured in future reports. Finally, no pages were processed and released informally.

Compliance Rate, Completion Times and Extensions

Of the 352 requests closed, 188 were completed within the legislated timelines under the ATIA. The compliance rate for this reporting period decreased to 53%, compared to the 69% in the previous reporting period. This decrease can be attributed to the review of more extensive and complex files, increased focus on consultations with other government departments, as well as pressures imposed by orders from the OIC and other special projects.

During the reporting period, the Department closed a total of 60 requests in 15 days or less (17.04%), 67 requests within 16 to 30 days (19.03%), 33 requests within 31-60 days (9.39%), 39 requests within 61-120 days (11.06%), 23 requests within 121-180 days (6.53%), 34 requests within 181-365 days (9.66%), and 96 requests took over 365 days to complete (27.27%). The chart below represents the number of requests completed (with percentage) per completion time for all completed requests.

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Bar graph displaying completion times of requests as follows:

Completion Time

• 1 to 15 days: 60 requests (17%)
• 16 to 20 days: 67 requests (19%)
• 31 to 60 days: 33 requests (9%)
• 61 to 120 days: 39 requests (11%)
• 121 to 180 days: 23 requests (7%)
• 181 to 365 days: 32 requests (10%)

Over 365 days: 96 requests (28%)

The Department sought extensions for 225 requests. Of these, 128 extensions were taken under section 9(1)(a) for interference with operations. 97 extensions were also invoked under section 9(1)(b) for required consultations. No extensions were taken under section 9(1)(c) for third party consultations.

Deemed Refusal Rate

The Department’s deemed refusal rate in this reporting period (i.e., the percentage of access to information requests that received a response beyond the deadline required under the ATIA) was 46%, which means that 164 requests were closed past legislative timelines. This represents an increase from the previous reporting period, with 90 requests being closed past legislated timelines.

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Line graph displaying deemed refusal rate as follows:

Deemed Refusal Rate

• 2022-2023: 31.0%
• 2023-2024: 30.9%
• 2024-2025: 46%

Outstanding Requests

TBS collects statistical data from specific institutions (of which the Department is one) on the volume of their outstanding access to information requests. The Department carried forward 523 requests over to the next reporting period, due to the varying nature and complexity of new requests received, and previously outstanding requests from past reporting periods.

Disposition of Completed Requests

Of the 352 requests completed this reporting period:

• 75 requests (21.3%) did not have responsive records.
• 138 requests (39.2%) were abandoned by the applicant.

The remaining 139 requests were completed as follows:

• 14 requests (10%) were fully disclosed.
• 104 requests (74.8%) were partially disclosed.
• 15 requests (10.7%) were exempted in their entirety.
• 2 requests (1.44%) were neither confirmed nor denied.
• 4 requests (2.88%) were transferred to other government departments.

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Bar graph displaying disposition of completed requests as follows:

Disposition of completed requests

• All disclosed: 14
• Disclosed in part: 104
• All exempted: 15
• No records exist: 75
• Request transferred: 4
• Request abandoned: 138
• Not confirmed/denied: 2

Requests, Exemptions and Exclusions

Exemptions invoked

The Department applied exemptions under the ATIA for 466 requests. The majority of exemptions invoked fell under three sections of the ATIA:

• Section 23, which exempts information relating to solicitor-client privilege, was invoked in 111 files,
• Section 19, which exempts any records that contain personal information, was invoked in 107 files; and
• Section 21, which exempts information relating to the internal decision-making processes of government was invoked in 89 files.

Of note, more than one section of the ATIA (exemption) can be applied to a specific access request.

Exclusions Cited

Exclusions were invoked in 20 requests, pursuant to section 68 of the ATIA, and in 87 requests pursuant to section 69.

Informal Requests

The Department proactively published on the Open Government Portal summaries of completed access to information requests that do not contain personal or third-party information. Members of the public can submit informal requests for a copy of the previously released information without having to pay the application fee.

During the 2024-2025 reporting period, the ATIP Division received 861 informal requests, with 8 requests outstanding from previous reporting periods, for a total of 869 informal requests. The ATIP Division completed 834 requests, which represents a significant increase compared to the 293 informal requests completed during the 2023-2024 reporting period.

The ATIP Division re-released 67,383 pages during the reporting period, which is a significant increase from the last reporting year (38,585 pages). This number does not include emails or telephone calls received from potential applicants that the ATIP Division responded to or redirected to other institutions.

Sources and Types of Requests

During the 2024-2025 reporting period, the Department received its 327 access to information requests from the following sources:

• 56 requesters who declined to identify themselves (17.12%)
• 184 requests by members of the public (56.23%)
• 37 requests by members of the media (11.32%)
• 14 requests from the private sector or businesses (4.28%)
• 28 requests from academia (8.57%)
• 8 requests from organizations (2.45%)

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Bar graph displaying number of requests by source as follows:

Number of Requests by Source

• Decline to identify: 56
• Public: 184
• Organization: 8
• Business (Private Sector): 14
• Academia: 28
• Media: 37

Format of Information Released

Most applicants chose to receive information in an electronic format as the Department continued to use delivery via E-post Connect, a service offered at no charge to the applicant, which is now the office’s primary method of record delivery. It allows for secure delivery of records in an electronic format and circumvents the issue of email size restrictions and the need for the recipient to have a compatible device to access the records.

Consultations

During the 2024–2025 reporting period, the Department received 208 consultations from other government institutions and 14 from other organizations, totalling 222 consultations related to the Department’s activities. With 96 consultations outstanding from previous years, the overall volume for the period was 318.

The number of consultation requests remained relatively stable, increasing slightly from 198 in the previous reporting period to 208 in 2024–2025. Similarly, the number of pages reviewed rose modestly, from 35,596 in the previous reporting period to 36,510 in 2024–2025.

Of the 318 consultations, 246 were completed and closed during the reporting period, an increase compared to 204 in the previous reporting period. The remaining 72 consultations were carried forward to be addressed in fiscal year 2025–2026.

The completion times for the 246 consultations were the following:

• 63 were completed between 1 to 30 days;
• 61 were completed within 31-60 days;
• 53 were completed between 61 to 120 days;
• 69 were completed past 121 days.

Active Complaints

The chart below represents the number of active complaints with the OIC that are outstanding from previous reporting periods, broken down by the fiscal year in which they were received. A total of 21 complaints remain active after the 2024-2025 reporting period. Most complaints that remain active were received in the last two reporting periods, 2022-2023 and 2023-2024.

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Bar graph displaying active complaints as follows:

Active Complaints

• 2024-2025: 15
• 2023-2024: 3
• 2022-2023: 2
• 2021-2022: 0
• 2020-2021: 0
• 2019-2020: 1

Costs

The total cost for administering the ATIA during the 2024-2025 reporting period was $2,254,488. This cost includes $1,937,969 in salaries and overtime, as well as operating costs totalling $316,519, which include $77,141 in professional service contracts.

These costs do not include resources expended by the Department’s other sectors to meet the requirements under the ATIA.

Training and awareness activities

Training Sessions

The Department and ATIP Division continued to provide employee training to enhance understanding of the ATIA and Privacy Act, as well as employee wellbeing and professional development. Training sessions are provided on an ad hoc basis, while others are scheduled routinely throughout the fiscal year.

Departmental ATIP Training for Department Employees

During the reporting period, the ATIP Division regularly provided advice and informal training on the application of ATIP and privacy legislation to the Department’s employees who must review relevant records requested under the ATIA or are completing initiatives with privacy risks.

Formal training is provided to ATIP employees, as well as the Department employees, to ensure they are aware of the policies, procedures, and legal responsibilities under the ATIA.

Formal awareness information sessions were offered to other sectors within the Department to address the specific business and operational needs of the individual groups. Presentations on various ATIP topics were provided via MS Teams or in person to almost 400 employees over the reporting period.

The ATIP Division recently updated its training resources and training decks during the reporting period to reflect changes to the privacy policy suite, as well as to highlight obligations in our newly developed internal policies.

The Centre for Information and Privacy Law, in the Public Law and Legislative Sector of the Department, is responsible for providing legal advice to all departments on the interpretation and application of the ATIA and PA. It also offers training to departmental employees and to employees from other government departments.

ATIP training is part of the recommended courses under the values and ethics component of the Department’s Roadmap for new managers. An e-orientation deck is posted on the Department’s Intranet site for employee consultation.

Departmental training sessions will continue to be provided throughout the 2025-2026 fiscal year.

Internal ATIP Division Training

The ATIP Division worked to ensure employees receive integral training to support their development, success, and wellbeing. Along with internal SOPs and policies, employees also completed mandatory departmental training on issues such as security and cultural sensitivity.

The Department’s ATIP Division employees participated in collective awareness sessions with ATIP legal counsel to review recent jurisprudence and case law related to the ATIA. The ATIP Counsel participated in monthly ATIP Practice Group meetings during which information was exchanged and solutions proposed. The Practice Group is open to all departmental legal counsel, including those from Legal Services Units, and aims to discuss questions such as the right of access to information and privacy issues.

The ATIP Division also invited an external trainer to deliver a session on Exemption and Exclusion Provisions under the ATIA, providing an opportunity for the team to engage in useful discussions and stay up to date on best practices.

Proactive Publication Training

During the reporting period, the ATIP Division maintained up-to-date training materials regarding proactive publication under Part II of the ATIA. These training materials remain available for use as needed.

Proactive disclosure guidance was provided on a case-by-case basis, particularly to the Deputy Minister’s Office and the Ministerial Secretariat. In these instances, the ATIP Division offered support regarding the rationale for releasing or withholding information to promote awareness and compliance with proactive publication requirements.

Complaints, investigations and federal court cases

Complaints Filed

During the reporting period, the dedicated complaints team continued its efforts to reduce the number of active complaints, serving as the primary liaison between the Department and the OIC. Moreover, the Division focused on strengthening the relationship with the OIC through meaningful and open dialogue. A complaints mailbox was also available to streamline complaints.

During the 2024-2025 reporting period, the Department received 37 new Notices of Intention to investigate from the OIC. The reasons for the complaints were as follows:

• 7 related to delays
• 8 related to the time extensions
• 16 related to exemptions
• 1 related to exclusions (section 69)
• 4 related to no records/incomplete search
• 1 related to fees

Key Issues and Actions Taken on Complaints

During the reporting period, key issues raised by access to information complaints received by the Department included:

• Missing records or no records,
• Exemption application,
• Delays on files,
• Administrative issues (i.e., charging of fees),
• Time exemptions; and
• Re-confirmation of Cabinet Confidences.

The ATIP Division took prompt action to resolve access to information complaints received during the reporting period. This included following up with OPIs to confirm the existence, or lack thereof of records, as well as conducting new searches with OPIs to locate additional records. The application of exemptions in certain cases was also re-examined and confirmed with the OPI to assure its accuracy, as it relates to the records.

Delayed files were also prioritized through action plans, with analysts reassigned as necessary to successfully process the file within the designated timeframe. The ATIP Division also evaluated and provided comprehensive background on the reasoning for time extensions taken, as they relate to the complexities of the file. Furthermore, the ATIP Division consulted with legal counsel on the application of the cabinet confidences within files.

Completed Investigations

A total of 40 investigations were completed during the reporting period, some of which had been carried forward from previous years. Of the 40 investigations:

• 10 were not well founded
• 11 were well founded with orders
• 5 were well founded
• 1 was discontinued
• 13 ceased to investigate

No key issues were raised because of these complaints.

Complaint findings are defined as follows:

Well founded with recommendations: If the head of the institution accepted the OIC recommendations and remedial action was taken by the institution to the satisfaction of the OIC, the matter is considered resolved and no further action by the OIC is necessary.

Well founded without recommendations: The institution took remedial action to the satisfaction of the OIC during the course of the investigation. The OIC did not need to provide a recommendation to the head of the institution.

Well founded with order: The OIC has found the complaint well founded and has issued an order to the institution to take certain actions to address the complaint.

Not well founded: As a result of the investigation, the OIC found that the institution applied the ATIA correctly.

Discontinued: The complaint was withdrawn or abandoned by the complainant before the allegations were fully investigated. In some cases, the complainant did not respond to the OIC’s request for representations within a reasonable time or cannot be located.

Resolved: The complainant is satisfied with the resolution achieved through the OIC's intervention or the matter central to the complaint is no longer at issue before the complaint has been fully investigated.

Review by the Federal Court of Canada

Two applications were filed before the Federal Court pursuant to section 41 of the ATIA during the 2024-2025 reporting period.

Monitoring compliance

The ATIP Division regularly monitored compliance with statutory requirements and timeliness associated with the processing of requests through ongoing communication with senior management and OPIs as necessary. The workload was assessed daily, through the ATIP Case Management System, to ensure it was evenly distributed and effectively managed to meet statutory deadlines.

The ATIP Division regularly advised and engages with OPIs and programs within the Department to ensure the right of public access to information is reflected in contracts, information-sharing agreements and information-sharing arrangements.

The reading rooms at the Department’s headquarters in Ottawa and those located in the regional offices across Canada make available to the public the most recently published version of Info Source, as well as departmental publications and manuals. Many of these publications can be found on the Department’s website and the Treasury Board Secretariat’s websites.

Proactive Publication

During the 2024-2025 reporting period, the Department continued to meet its obligations under Part II - Proactive Publication.

Proactive Publication Procedures and Compliance

The ATIP Division implemented several procedures to meet proactive publication requirements under Part II of the ATIA and to facilitate a 100% compliance rate.

SOPs and business plans outlined the steps, deadlines, and stakeholders involved in the Proactive Publication process. These resources are regularly reviewed and updated to ensure they remain current and effective.

During the reporting period, the ATIP Division used these materials as a framework for publishing content on the Open Government Portal. This included specific guidance on the proactive disclosure of key legislative requirements, such as summaries of access to information requests, question period cards, transition briefing materials, parliamentary committee briefing materials, financial and contractual information, as well as travel and hospitality expenses for the Minister and senior officials.

The ATIP Division regularly monitored the timeliness, accuracy, and completeness of proactively published information under Part II of the ATIA. Analysts within the Division sent scheduled follow-up reminders at the beginning of each month to ensure that the required information was submitted by the 15th of the month, allowing for timely publication. Senior management was advised regularly, and the ATIP Division worked closely with program areas as necessary to ensure compliance with proactive disclosure obligations.

Furthermore, the ATIP Division is currently developing and launching a centralized Digital Workspace site to document the procedures related to proactive disclosure and monitor compliance of each responsible sector.

For a breakdown of the group(s) and/or position(s) responsible for meeting each applicable proactive publication requirement under Part II of the ATIA, see the section “Proactive Publication under Part II of the ATIA” below (Annex B: Proactive Publications Requirements Table).

Annex A – Delegation order

Text version

The Department of Justice’s Delegation Order for the Access to Information Act and Privacy Act

The Minister of Justice of Canada pursuant to subsections 95(1) of the Access to Information Act and 73(1) of the Privacy Act, hereby delegates any powers, duties and functions under the Acts to the persons holding the positions set out in the schedule hereto, as well as to the persons occupying those positions on an acting basis. This delegation order replaces any previous delegation order.

Schedule

Position: The Deputy Minister and Associate Deputy Minister
Privacy Act and Regulations: Full Authority
Access to Information Act and Regulations: Full Authority (including for the Act as it was prior to June 21, 2019)

Position: The Director, Access to Information and Privacy Office
Privacy Act and Regulations: Full Authority
Access to Information Act and Regulations: Full Authority (including for the Act as it was prior to June 21, 2019)

Position: The Chief Financial Officer and Assistant Deputy Management Sector
Privacy Act and Regulations: Full Authority
Access to Information Act and Regulations: Full Authority (including for the Act as it was prior to June 21, 2019)

Position: The Senior General Counsel and Director General, Legal Practices Branch
Privacy Act and Regulations: Full Authority
Access to Information Act and Regulations: Full Authority (including for the Act as it was prior to June 21, 2019)

Position: The Chief of Operations, Chief of Policy and Legal Counsel, Access to Information and Privacy Office
Privacy Act and Regulations: 15, and the mandatory provisions of section 26 for all records
Access to Information Act and Regulations: 8(1), 9, 11, and the mandatory provisions of section 19 for all records

Position: The Senior Access to Information and Privacy Advisors
Privacy Act and Regulations: 15 for all records
Access to Information Act and Regulations: 8(1) and 9 for all records

Dated, at the City of Ottawa, this day of Oct. 2, 2024.

Signed by the Honourable Arif Virani, Minister of Justice.

Annex B – Proactive publications requirements table