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ORDER BACKGROUND: The Ministry of Correctional Services (the Ministry) received a request for access to information related to the requester's previous employment at the Grandview Training School for Girls (Grandview) during the summer of 1973. The request included his past employment file; position description; map of Grandview premises; names of residents and housing arrangements at Grandview during the period of his employment; names of residents who had escaped during the period of his employment; procedures at Grandview for dealing with escapes; and information regarding the escape alarm system and key policy in place during the period of his employment. The Ministry determined that any responsive records to the parts of the request dealing with the position specification, map, escape procedures, alarm system and key policy would be held by the Archives of Ontario (the Archives), and transferred these parts of the request to the Archives, pursuant to section 25 of the Freedom of Information and Protection of Privacy Act the ( Act ). In its decision letter, the Archives indicated that no records containing the personal information of the requester were located. The Archives also identified one directly responsive record (the site plan for Grandview), and 4 other records which were not directly responsive, but did deal with the subject matter of the request. The Archives denied access to all five records in their entirety, pursuant to sections 14(1)(a), (b), (f), (g), (i), (j) and/or (k) of the Act . The Archives also cited sections 14(2)(d), 21(1), and 21(2)(f) and (i) of the Act to protect the identity and personal information of a ward referred to in one of the records. The requester appealed the Archives' decision. During mediation, the appellant accepted the Archives' position that no records containing his personal information existed, and clarified that he did not want access to the personal information of any other individuals. Further mediation was not successful, and notice that an inquiry was being conducted to review the Archives' decision was sent to the appellant and the Archives. Written representations were received from both parties to the appeal. In its representations, the Archives submits that all responsive records fall within the discretionary exemptions provided by sections 14(1)(a), (b), (f) and (l), and that Record 2 also qualifies for exemption under sections 14(1)(i), (j) and (k). Because section 14(1)(l) was raised by the Archives for the first time in its representations, the appellant was given an opportunity to make representations on the applicability of that section. The records at issue in this appeal are described as follows: 1. Memorandum dated March 14, 1973, from the Personnel and Staff Training Branch of the Ministry to the Superintendent of Grandview, which describes the number and type of summer jobs available at Grandview during 1973, together with the qualifications required and remuneration paid for those positions. 2. Site Plan dated April, 1970, which shows both the location of the buildings and the topography of Grandview. 3. Memorandum dated June 14, 1973, from the Chief Systems and Procedures Officer of the Ministry to the Assistant Deputy Minister's Office, regarding the use of O.P.C. forms to report training school runaways. 4. Portions of two routine inspection reports, dated June 14, 1974 and November 19, 1975, prepared by the Inspections and Standards Branch of the Ministry, which contain information responsive to the part of the request dealing with the alarm system. 5. Transcript of the minutes of the June 6, 1972 Grandview Employee Relations Committee meeting, which contain information responsive to the part of the request dealing with escape policy. PRELIMINARY ISSUE: Before submitting its representations, the Archives sent a letter to me, requesting that the Waterloo Regional Police and the Ministry of the Solicitor General (the Solicitor General) be added as affected parties to the appeal. The Archives expressed the view that, due to the fact that there is currently a joint investigation of Grandview, involving the Waterloo Regional Police and the Ontario Provincial Police, "[I]t is the police alone who can meaningfully and satisfactorily identify the harms which may result through the disclosure of parts or the whole of these documents." I denied the Archives' request for the following reasons, outlined in my November 6, 1992 letter: The decision that is the subject of Appeal 9200436 is the decision dated May 15, 1992 of the Archives of Ontario. The request for access to the records at issue in this appeal was originally submitted by the requester/appellant to the Ministry of Correctional Services. That Ministry transferred the request to the Archives, presumably because it did not have custody or control of the requested records, and the Archives did. Upon receipt of the request, the Archives, presumably, as it is obliged to do so under section 25(2) of the Freedom of Information and Protection of Privacy Act , considered whether another institution had a "greater interest in the record". The Archives determined that it was in a position to respond to the request, after consulting with the heads of various institutions which the Archives thought might have an interest in the disclosure of the records. The Act expressly contemplates and allows for consultations between governmental institutions before a decision relating to access to a record is made by an institution, where the record affects the interest of more than one institution. In my view, this is to ensure that all viewpoints are considered by the institution in carrying out the provisions of the Act , and that the institution is in a reasonable position to present the government's position as a whole. This approach is necessary in order for the Act to work effectively. Having the "greater interest in the records", and having consulted all the institutions that may have an interest in the records at issue in Appeal 9200436, I am satisfied that the Archives will be in a position to reasonably present the position of the government as a whole, in its representations in the context of my inquiry. Accordingly, I will not be inviting the Ministry of the Solicitor General and the Waterloo Regional Police to make representations. A copy of my letter was sent to the appellant, the Solicitor General and the Waterloo Regional Police, among others. The Archives sub
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