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Document
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P-400
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File #
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P-9100293, P-9100753, P-9101198 and P-9200212
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Institution/HIC
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Ministry of Agriculture and Food
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Summary
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ORDER
In February, 1991, the Ministry of Agriculture and Food (the Ministry) received a request under
the Freedom of Information and Protection of Privacy Act (the Act) for access to the minutes of
the monthly board meetings (the minutes) of the Ontario Pork Producers' Marketing Board (the
OPPMB) for the period April 1990 to "the present time". In June 1991, the same requester made
a request for continuing access to the minutes for "the next two years".
The Ministry responded to the request for continuing access on four separate occasions. Each
time, the Ministry notified the OPPMB pursuant to section 28(1) of the Act, and each time the
OPPMB objected to the release of the minutes. Despite the OPPMB's objections, the Ministry
decided to release the minutes to the requester, subject to certain severances. The OPPMB
appealed the Ministry's four decisions, claiming that sections 17(1)(a), (b) and (c) of the Act
applied to the minutes. This appeal is restricted to the four requests which cover the minutes for
meetings held between April 1990 and December 1991.
During mediation, the requester confirmed that he was not interested in receiving access to those
portions of the minutes which the Ministry had intended to sever and, accordingly, these parts of
the minutes are outside the scope of this appeal. One of the types of information the Ministry
purports to sever from the minutes is personal information of individuals other than the
appellant. Having reviewed the minutes, I note that a few items which refer to individuals
receiving research grants have not been severed. In my view, these items contain personal
information that falls outside the scope of this appeal. Specifically, these minute items are the
names of individuals contained in items 6.1 from August 1990; l8 from January 1991; 21.1 from
May 1991; and 11.1 from August 1991. Attached to this order as Appendix A is a list of the
items that were severed, either in whole or in part, by the Ministry, togetther with the items
which include personal information and are outside the scope of this appeal.
Further mediation was not possible and notice that an inquiry was being conducted to review the
Ministry's decisions was sent to the requester, the Ministry, the OPPMB, and other parties whose
interests might be affected by the disclosure of the information (the affected persons). Written
representations were received from the requester, the OPPMB, the Ministry, and one affected
person.
In its representations, the Ministry indicates that although, it had initially been prepared to
release certain parts of the minutes to the appellant, it now wished to deny access to the minutes
in their entirety, pursuant to section 17(1)(b) of the Act.
It should be noted that the minutes are provided to the Ontario Farm Products Marketing
Commission (the Commission) by the OPPMB pursuant to section 1 of Ontario Regulation
421/90 of the Farm Products Marketing Act. The Commission, which reports to the Ministry, is a
regulatory agency that supervises the activities of various marketing boards in Ontario. The
minutes are one of the tools it uses to carry out its regulatory function.
The sole issue in this appeal is whether the mandatory exemption provided by section 17(1) of
the Act applies to the minutes.
- 2 -
[IPC Order P-400/January 15, 1993]
Sections 17(1)(a), (b) and (c) of the Act read as follows:
A head shall refuse to disclose a record that reveals a trade secret or scientific,
technical, commercial, financial or labour relations information, supplied in
confidence implicitly or explicitly, where the disclosure could reasonable be
expected to,
(a) prejudice significantly the competitive position or
interfere significantly with the contractual or other
negotiations of a person, group of person, or
organization;
(b) result in similar information no longer being
supplied to the institution where it is in the public
interest that similar information continue to be so
supplied;
(c) result in undue loss or gain to any person, group,
committee or financial institution or agency;
In order to qualify for exemption under sections 17(1)(a), (b), and /or (c), the following threepart
test must be satisfied:
1. the record must reveal information that is a trade
secret or scientific, technical, commercial, financial
or labour relations information; and
2. the information must have been supplied to the
Ministry in confidence, either implicitly or
explicitly; and
3. the prospect of disclosure must give rise to a
reasonable expectation that one of the types of
injuries specified in (a), (b) or (c) of section 17(1)
will occur.
Failure to satisfy the requirements of any part of this test will render the section 17(1) claim
invalid [Order 36].
Part 1 of the section 17(1) test
Both the Ministry and the OPPMB submit that the minutes, in their entirety, contain commercial
information. In its representations, the Ministry states:
- 3 -
[IPC Order P-400/January 15, 1993]
The purpose of the OPPMB is commercial; it pertains to the buying and selling of
hogs with profit as the aim. All activities and discussions of the board are related
to this primary purpose and, therefore, all information contained in the minutes of
the board is commercial information.
Similarly, the OPPMB states:
The board minutes contain in their entirety commercial information, ...
...
Because of the nature and character of the OPPMB and the functions in which it
is involved the subject matter of board meetings and hence the content of board
minutes is the presentation of commercial information related to the marketing of
pork on behalf of pork producers.
I do not agree. In my view, the minutes, in their entirety, do not automatically qualify as
commercial information solely because the board is engaged in commercial activities. The Act
provides a right of access to all records in the custody or under the control of an institution, with
the exception of information which legitimately falls within one or more of the exemptions, and
also provides that "necessary exemptions from the right of access should be limited and
specific." Each record must be considered with a view to establishing whether the record, or part
thereof, falls within the exemptions claimed.
In its representations, the Ministry states that the minutes reveal intimate aspects of the OPPMB's
operations and then goes on to list many of the OPPMB's activities. The Ministry's
representations do not, however, describe where such information appears in the minutes, nor do
they provide examples of such information. Similarly, in its representations, the OPPMB submits
that the minutes contain financial, technical, scientific, labour relations information and trade
secrets, but does not describe which parts of the record qualify as which type of information.
The OPPMB does, however, provide specific examples of information that it considers to be
commercial, although I note that several of the examples are from minutes that are not at issue in
these appeals.
I have carefully reviewed all of the minutes and, in my view, only a small proportion of them
contain information which satisfies the first part of the test.
Much of the information is essentially administrative detail, such as attendance lists and
approvals of agendas and minutes. Other information consists of accounts of discussions of such
topics as preparations for attending a baseball game, the possible creation of a slogan for
anniversary celebrations and dress codes for attendance at industry functions. These types of
information do not, in my view, qualify as a trade secret or scientific, technical, commercial,
financial or labour relations information.
Another large part of the record contains information about the pork industry which, in my view,
is only indirectly related to the actual business of marketing pork. For example, there are
updates about meetings of other provincial marketing boards, discussions of lobbying efforts,
grading standards and deadstock, reports about seminars attended by board members, discussions
- 4 -
[IPC Order P-400/January 15, 1993]
of western provinces' grain policies and the national Tripartite program, and discussions about
"countering unfounded criticism". This type of information does not, in my view, relate directly
to the exchange of goods or services (commercial information), nor does it relate to money or the
use, management or distribution of money (financial information), nor is it a trade secret or
technical, scientific, or labour relations information.
In my view, the only information which meets the definition of third party information under
section 17 is information that relates directly to the actual marketing of pork or pork products, or
to discussions of financial matters by the board. Such information includes descriptions of
disbursements such as accounts of yard operations which refer to actual dollar amounts
(financial), accounts of negotiations for the sale of pork (commercial) and updates of pricing and
sales statistics (commercial). In several cases, the Ministry's severance of information, such as
dollar figures, takes a particular item outside the scope of the definition of third party
information. In addition, some of the information about government programs and customs
issues, such as discussions of countervailing duties, qualifies as financial or commercial
information, but only if it includes reference to actual dollar amounts or specific agreements for
the sale of pork; generalized references to government programs or customs issues do not, in my
view, constitute financial or commercial information.
I have attached a list of the minute items which I find contain third party information under
section 17(1) of the Act as Appendix B to this order. My findings do not relate to minute items
that were severed in their entirety by the Ministry because they are outside the scope of this
appeal, but do apply to the unsevered parts of minute items that were partially severed.
Part 2 of the section 17(1) test
In order to satisfy the requirements of part 2 of the section 17(1) exemption test, the information
must have been supplied to the Ministry in confidence, either implicitly or explicitly. The parties
resisting disclosure must establish first, that the information was supplied, and second, that it was
supplied in confidence.
With respect to the supplied requirement, it has been established in previous orders that
information provided to an institution under a statutory reporting requirement is "supplied" for
the purposes of section 17(1) [Orders P-314 and P-345]. Because section 1 of Ontario
Regulation 421/90 requires the OPPMB to file copies of the minutes with the Commission, I am
satisfied that the minutes were supplied to the Ministry.
With respect to the "confidentiality" element, both the Ministry and the OPPMB submit that the
information was supplied in confidence, implicitly and explicitly. The OPPMB acknowledges
that there is no written policy on keeping the minutes confidential, but states that it is their long
standing corporate practice to treat the minutes confidentially.
The Ministry submits that the information contained in the minutes was supplied with the
expectation that it would remain confidential. In addition, the Ministry states:
- 5 -
[IPC Order P-400/January 15, 1993]
The well-established practices of the Commission have created a long standing
expectation on the part of marketing boards that minutes are supplied to the
Commission in confidence.
...
The [Commission] has never betrayed this confidence, which has contributed to a
cooperative relationship in which marketing boards have been comfortable
supplying full and informative minutes.
Having reviewed the representations, I am satisfied that the minutes were supplied in confidence.
The Commission and the OPPMB both expected that the minutes would be treated
confidentially, the minutes were stamped "confidential", distribution of the minutes was limited
to specific individuals at the OPPMB and the Commission, and both the OPPMB and the
Commission have a long standing practice of treating the minutes in a confidential manner.
Therefore, I find that the second part of the test has been satisfied.
Part 3 of the section 17(1) test
Part 3 of the section 17(1) exemption test requires that the parties resisting disclosure present
evidence that is detailed and convincing, and describe a set of facts and circumstances that could
lead to a reasonable expectation that one or more of the harms described in section 17(1) would
occur if the minutes were released [Order 36].
My discussion of part 3 of the test is restricted to the relatively small number of minutes items,
as set out in Appendix B, which I have found to satisfy parts 1 and 2 of the test. I will consider:
first, the affected persons's representations; second, the OPPMB's and the Ministry's
submissions regarding section 17(1)(b); and finally, the OPPMB's representations regarding
sections 17(1)(a) and (c).
(a) Representations of the affected person
In its representations, the affected person states:
Not knowing exactly what information is in the minutes, but if any of the
following are discussed at board meetings (I would be surprised if they were not)
they would certainly impact on our business negatively if the information was
released.
The affected person goes on to list three examples of the types of information it believes should
not be released. In my view, the affected person's representations were, at best, generalized
- 6 -
[IPC Order P-400/January 15, 1993]
references to possible harm and I find that it has failed to establish the requirements of the third
part of the test.
(b) Representations regarding section 17(1)(b)
Both the Ministry and the OPPMB submit that it is in the public interest that full and detailed
minutes be provided to the Commission and that, if the minutes were to be accessible under the
Act, similar information would no longer be supplied voluntarily.
The Ministry states that it relies on the minutes in carrying out its regulatory responsibilities and
that it will not receive similar information unless it can assure confidentiality. In its
representations, the Ministry states:
Boards, like any profit-oriented business, operate in their own self-interest and
common sense dictates that boards will not supply information that could
potentially be used to harm the industry or its member producers.
...
It is in the public interest that boards be monitored effectively and efficiently.
This role is carried out by the [Commission]. Without access to minutes of the
boards, minutes as detailed as those provided in the past, the Commission's ability
to monitor boards in a timely and effective manner will be impaired and public
interest will suffer.
The Ministry also refers to several letters it received from other marketing boards, which indicate
that they would submit abbreviated minutes if they were subject to release.
The OPPMB concurs, stating in its representations that it would no longer supply detailed
minutes to the Commission if they were accessible under the Act.
In support of their position, both the OPPMB and the Ministry point out that, although section 1
of Ontario Regulation 421/90 requires that the minutes of the OPPMB's board meetings must be
filed with the Commission, it does not prescribe the type of information which must be contained
in the minutes.
In previous orders, I have found that section 17(1)(b) was not intended to protect information
which is provided pursuant to a statutory obligation [Orders P-314 and P-323]. In my view, the
same principle applies to this appeal and, in light of the requirements of section 1 of Ontario
Regulation 421/90, I am not satisfied that the information would no longer be provided.
In reference to the Ministry's assertion that release would harm its regulatory function, I am
prepared to accept that the OPPMB may submit more cursory minutes in order to protect against
the release of certain information; however, neither the OPPMB nor the Ministry have identified
the specific type of information currently included in the minutes which, if excluded, would
hinder the Commission's ability to regulate. In any event, I note that Ontario Regulation 421/90
contains several other mandatory reporting requirements besides the minutes, which are directed
- 7 -
[IPC Order P-400/January 15, 1993]
at the Commission's regulatory mandate. The OPPMB must provide, for example, "all reports of
its operations" and "the annual financial statement and audited reports".
In summary, I find that the Ministry and the OPPMB have failed to establish their claims that
disclosure of the minutes would result in similar information no longer being supplied to the
Commission, and the minutes do not qualify for exemption under section 17(1)(b).
(c) OPPMB's representations regarding sections 17(1)(a) and (c).
The OPPMB submits that release of the information contained in the minutes could be used to
undermine its competitive position, interfere with its contractual negotiations, and cause it undue
loss. In its representations, the OPPMB describes its history and provides a lengthy description
of the pork industry. It states that the industry is very competitive, and that the OPPMB must
compete with other pork producers across Canada and the United States and with producers of
other commodities such as beef and poultry. With respect to the harm that could arise if the
minutes were released, the OPPMB makes several general statements. For example, it states:
It is very much in the best interest of pork's competitors to know what pork
producers are doing and what factors are at work in their marketing. Companies
spend millions of dollars each year to gather market information. Disclosure of
board minutes would make this sensitive information very easily and cheaply
available to competitors.
In my view, the OPPMB's representations, for the most part, amount to generalized references to
possible harm, and are not particularly relevant to the issue of whether release of the relatively
small number of minute items I have found to contain commercial or financial information
would cause harm under section 17(1). I find that these generalized representations are not
sufficient to establish either of the harms enumerated in sections 17(1)(a) or (c).
The OPPMB does make some specific submissions about potential harm to its competitive
position if the minutes are released. In its representations, the OPPMB lists eight categories of
information and, for each category, identifies specific examples from the minutes. A number of
these examples relate to minutes which are not at issue in this appeal; many more consist of
information that I have already found does not qualify under part one of the section 17(1)
exemption test; and others were originally severed by the Ministry and are not at issue in this
appeal. I will not consider these three categories of minute items in my remaining discussion of
part three of the test.
I will, however, consider those minute items for which the OPPMB has made specific
submissions, and which I have found to be commercial or financial information, and which are
contained in the minutes which are at issue in this appeal. These are the following six minute
items: item 26.1 from the November 1991 minutes (information about sales to a foreign
country); items 4.2 and 22 from the September 1991 minutes (information about countervailing
- 8 -
[IPC Order P-400/January 15, 1993]
duties); items 24.1 and 24.3 from the June 1991 minutes (pricing information); and, item 4.4
from the March 1991 minutes (information about expenses related to yard operations).
sales to a foreign country (item 26.1 from the November 1991 minutes)
In 1991, the OPPMB was involved in negotiating a sale of pork to a foreign country. In its
representations, the OPPMB states, "The following information could have been used by the
NPPC as leverage to try and have the U.S. government change their policy and have U.S. Pork
replace Canadian Pork." In my view, the harm requirements contained in sections 17(1)(a) and
(c) relate to possible future harms that could reasonably be expected to arise if information were
released, not harms which could have occurred in the past. I find that release of the information
contained in this minute item, which relates to a possible sale of pork in late 1991 or early 1992,
could not result in harm to the OPPMB's current competitive position. Therefore, the third part
of the test has not been established with respect to this minute item.
I note that the OPPMB also cites item 12.1 from the December 1991 minutes under this category,
which appears to be incorrect. There is a discussion of pork sales to the same foreign country
contained in the December 1991 minutes as item 5. I have given the OPPMB the benefit of the
doubt and have applied its representations regarding item 26.1 to item 5. However, for the same
reasons as outlined for item 26.1, I find that the third part of the test has not been established.
countervailing duties (items 22 and 4.2 from the September 1991 minutes)
Earlier in this order, I found that discussions of countervailing duties that do not refer to specific
dollar amounts do not qualify as financial information. Therefore, my discussion of part 3 of the
test is restricted to the two minute items referred to in the OPPMB's representations which deal
with countervail duties and refer to specific monetary sums. In its representations, the OPPMB
states, "[A]lthough the trade disputes on the countervailing duty on live hogs has now gone to a
panel set up under the Canadian - U.S. Free Trade Agreement, the following would provide
useful information to the Americans on how we are attempting to cope with the problem - and
could be used to generate negative publicity in the U.S." However, the OPPMB does not
describe, specifically, how release of the information could harm its competitive position or
result in undue loss or gain and, in my view, the third part of the test has not been established
with respect to minute items 22 and 4.2 from the September 1991 meeting.
pricing (items 24.1 and 24.3 from the June 1991 minutes)
Under pricing, the OPPMB refers to their "unique" selling methods and states, in its
representations that, "[K]nowing ahead of time, Quebec or Ontario Pork, were considering
changing how hogs are sold would be an obvious advantage to the packers". The OPPMB does
not, however, explain how knowledge of this information would be an "obvious advantage" and,
in my view, the third part of the test has not been established for minute items 24.1 and 24.3
from the June 1991 meeting.
expenses related to yard operations (item 4.4 from the March, 1991 minutes)
- 9 -
[IPC Order P-400/January 15, 1993]
This minute items refers to discussions of amounts paid to yard operators. [Yards are the places
to which pork producers deliver their hogs.] In its representations, the OPPMB states,
"[P]ublication of any of the following information would be used by the owners of other yards to
weaken Ontario Pork's negotiating position when it came to negotiating new rents for their
yards". Other than making this general assertion, the OPPMB does not explain how the release
of such information would weaken their negotiating position. In my view, the third part of the
test has not been established with respect to item 4.4 from March 1991.
Finally, I note that the OPPMB refers in its representations to the purchase of a computer in its
representations. The OPPMB incorrectly identifies the relevant minute item as being from the
April 1992 minutes, which are outside the scope of this appeal. The correct minute item is, in
fact, item 4.6 from the April 1991 minutes, which are at issue in this appeal. The OPPMB
submits that "it would not be in the competitive interest of either Ontario Pork or IBM, if
information such as the following were routinely made public". The OPPMB does not explain
what harm would arise or how such harm would arise if this information were released. In any
event, this minute item is not at issue in this appeal because the amount paid for the computer
was originally severed by the Ministry, and I found that the rest of the item does not satisfy the
requirements of part one of the section 17(1) exemption test.
In summary, I have carefully reviewed the minutes and the representations of all parties and, in
my view, the parties resisting disclosure have failed to establish that release of those minute
items which I have found to contain commercial or financial information, and to have been
supplied in confidence, could reasonably be expected to result in any of the types of harms
enumerated in sections 17(1)(a), (b) and/or (c) of the Act. While the descriptions of the pork
industry provided by the Ministry and the OPPMB were helpful in providing a context for my
review of the minutes, the representations provided by these two parties failed to provide clear
and specific evidence linking a reasonable expectation of harm to release of the information in
the specific minute items.
Therefore, I find that the minutes should be released to the appellant, subject to the severances
made by the Ministry in response to the original requests.
ORDER:
1. I order the Ministry to release the minutes to the appellant, subject to the severances
made by the Ministry in response to the original requests, and the severances of personal
information that I have found to be outside the scope of this appeal, within 35 days
following the date of this order, and not earlier than the thirtieth (30th) day following the
date of this order.
2. In order to verify compliance with this order, I order the Ministry to provide me with a
copy of the record which is disclosed to the requester, pursuant to Provision 1, only upon
my request.
- 10 -
[IPC Order P-400/January 15, 1993]
Original signed by: January 15, 1993
Tom Mitchinson
Assistant Commissioner
[IPC Order P-400/January 15, 1993]
A P P E N D I X A
LIST OF ITEMS NOT AT ISSUE
The following items have been severed from the records, either in whole or in part.
Where an item has been partially severed, the unsevered potion of the record is still at
issue.
April 1990
(a) in whole: 17.1
(b) in part: 3.1, 7.1, 30.1
May 1990
(a) in whole: none
(b) in part: 5.1, 6.4
June 1990
(a) in whole: none
(b) in part: 6.1, 19, 34
July 1990
(a) in whole: none
(b) in part: 17.1, 24
August 1990
(a) in whole: none
(b) in part: 6.1, 26
September 1990
(a) in whole: none
(b) in part: 4.2, 4.4, 10.5, 10.6
October 1990
(a) in whole: none
- 2 -
[IPC Order P-400/January 15, 1993]
(b) in part: 3.1, 15.5, 36
November 1990
(a) in whole: none
(b) in part: 8.3
December 1990
none
January 1991
(a) in whole: 4.1
(b) in part: 18
February 1991
(a) in whole: none
(b) in part: 18.3, 31, 35.3
March 1991
(a) in whole: 24
(b) in part: none
April 1991
(a) in whole: 16
(b) in part: 4.6, 4.7, 10.1
May 1991
(a) in whole: 7, 21.1
(b) in part: none
June 1991
(a) in whole: 23
- 3 -
[IPC Order P-400/January 15, 1993]
(b) in part: none
July 1991
(a) in whole: 11.1, 14.1
(b) in part: 13.2, 23 and the attachment
August 1991
(a) in whole: 3.2, 20.1
(b) in part: 11.1
Special meeting of September 12, 1991
(a) in whole: none
(b) in part: 3
September 1991
(a) in whole: 34.2
(b) in part: 9.1, 40
October 1991
The September meeting took place on September 30 and October 1, 1991. There is no
separate October meeting.
November 1991
(a) in whole: 34
(b) in part: none
December 1991
none
[IPC Order P-400/January 15, 1993]
A P P E N D I X B
LIST OF ITEMS WHICH SATISFY THE FIRST PART OF SECTION 17(1) TEST
April 1990
(a) financial: 11.1, 15.2, 18.3, 20, 28.3, 29, 31.1, 31.3, sub-number 39 from item 32
(b) commercial: 9.3, 10, 10.1, 12.2, 17.2, 35
May 1990
(a) financial: 4, 6.2, 10.1, 11, 16.2, 18.1, 19.2, 20, 22.2, 24.1, 25, 29.2, 29.8
(b) commercial: 6.1, 6.4, 8.2, 9, 15, 15.1, 18.3, 18.4
June 1990
(a) financial: 4.2, 8.1, 8.3, 10, 20.2, 29
(b) commercial: 6.1, 6.2, 7, 34
July 1990
(a) financial: 11.1, 17.2, 17.3, 21.1, 22, 26.1, 28.3, 31.1, 33
(b) commercial: 8, 15, 18
August 1990
(a) financial: 3.2, 4.5, 11.2, 32.3
(b) commercial: 4.2, 9, 33
September 1990
(a) financial: 4.4, 9.1, 9.2, 12.1, 12.2, 14.1, 15.1, 25.2, 28
(b) commercial: 6, 7, 22.2
October 1990
(a) financial: 7, 15.3, 15.5, 22,
- 2 -
[IPC Order P-400/January 15, 1993]
(b) commercial: 11, attachment - document regarding "booking"
November 1990
(a) financial: 4.1, 8.2, 10.3, 17.2, 24, 25
(b) commercial: 7
December 1990
(a) financial: 4.1, 10.4, 12
(b) commercial: 7
January 1991
(a) financial: 3.1, 12, 19.2, 19.3, 21.1, 31.1
(b) commercial: 6
February 1991
(a) financial: 4.4, 14.1, 16, 17, 21, 28, 29
(b) commercial: 4.2
March 1991
(a) financial: 4.2, 4.4, 23, 27.1, 27.2, 27.3
(b) commercial: 25
April 1991
(a) financial: 6.2, 10.1, 10.2, 26.1, 31.2, 31.3
(b) commercial: 6.1
May 1991
(a) financial: 11.1, 19, 22.1, 27.1, 27.4
(b) commercial: 11.2, 12
June 1991
(a) financial: 4, 4.1, 4.2, 8.1, 10.5, 12.1, 20.2, 20.3
(b) commercial: 7, 10.2, 22, 24.1, 24.3, 24.4
- 3 -
[IPC Order P-400/January 15, 1993]
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Legislation
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Subject Index
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Signed by
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Tom Mitchinson
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Published
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Jan 15, 1993
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Type
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Order
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Judicial Review
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Affected party's application abandoned October 25, 1994
Ontario (Pork Producers' Marketing Board) v. Ontario (Information and Privacy Commissioner), Toronto Doc. 113/93 (Ont. Div. Ct.)
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