Archived - Access to Information Guidelines - Accounting for Information Holdings

Subsection 5(1) of the Act requires that the Designated Minister cause to be published annually a description of government organization, program responsibilities and classes of records at a level of clarity and in sufficient detail to enable the public to exercise its rights under the legislation. This provision of the Act is the major device through which the government accounts to the public regarding its organizational structure, the various information holdings under the control of specific institutions and the access points where requests can be made. This requirement is linked directly to the public's ability to exercise the right of access and for that reason such descriptions cannot be conceptual in nature but rather are required to describe actual information holdings as to subject, location and medium. Normally, the descriptions required under the access and privacy legislation are the highest level of aggregation for the departmental inventory of information holdings required under the government policy for the Management of Government Information Holdings.

Treasury Board Secretariat fulfils the requirements of subsection 5(1) of the Act through the annual publication of a volume entitled Info Source (Sources of Federal Government Information). Info Source is distributed to libraries, municipal offices and federal government offices across Canada. The importance Parliament has placed on this general accounting of sources of government information holdings is underlined by the fact that the requirement is subject to complaints before the Information Commissioner. Institutions are accountable for providing clear and comprehensive accounts of their information holdings for inclusion in Info Source.

The publication contains the following elements deriving directly from the Access to Information Act:

1. description of the organization and responsibilities of each government institution including details on the programs and functions of each division or branch;
2. a description of all classes of records under the control of each government institution in sufficient detail to facilitate the exercise of the right of access under the Act;
3. a description of all manuals used by employees of each government institution for the purpose of carrying out any of the programs or activities; and
4. the title and address of the appropriate officer for each government institution to whom requests for access to records under this Act should be sent.

The policy requires that institutions provide this information in accordance with requirements issued annually to institutions by the Treasury Board Secretariat. Government institutions are instructed to describe all information holdings under their control in accordance with the principle that there are no holdings which by their very nature are secret. Institutions are, however, not required to include in such descriptions information which itself would be exempt under the Act.

Subsection 5(2) of the Act requires that the designated Minister cause to be published a bulletin which updates the annual publication and provides information about the Act.