BC Freedom of Information and Privacy Association
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Preliminary Report 2025
FIPA is sharing a preliminary report of our efforts to study freedom of information (FOI) in BC.
Since late 2022, FIPA has been engaged on a research project that uses documents obtained through FOI requests to piece together how FOI requests are processed. We collected data from every public body subject to both the Freedom of Information Act and Protection of Privacy Act and Information Management Act in British Columbia — all 24 ministries in the government of British Columbia, and 32 broader public sector organizations (according to the 2024 legislation).
FOIPPA, passed in 1992, gives everyone a right of access to records in the custody or control of public bodies, subject only to specific exceptions. IMA is a newer statute: passed in 2015 in response to an FOI scandal that involved lapses in recordkeeping; the province passed IMA to replace the 80-year-old Document Disposal Act. For our purposes, the most important part of IMA is the creation of a Chief Records Officer, who has a mandate to “to promote effective information management by government bodies” and may issue directives toward that end.
Today, nearly everyone agrees that FOI — in all public bodies — is not working as well as it could. Following a preliminary review of the information we received we can discuss the following findings that may indicate why:
- The resources to implement FOIPPA and IMA effectively are concentrated in larger public bodies. The smaller the public body gets, the less likely it is to have developed plans or policies for responding to FOI requests specific to itself.
- Records management is decentralized, seemingly unintentionally, creating unintended consequences. The Information Management Act does not set a definite direction in how the government records are organized. That flexibility at the statute level is important, but it has not come with well-developed local plans to ensure consistent, quality recordkeeping strategies are implemented. Inconsistent or unclear recordkeeping can present challenges when public bodies are called upon to retrieve records in response to FOI requests.
- How responsive records are identified and redacted remains largely a black box. When we tried to understand the tasks of an FOI worker through the records released (i.e. interpreting requests, communicating and confirming the final request with applicants, locating the records, analyzing them for harms, etc.), we found it incredibly difficult to do so. Manuals are sparsely distributed across the public sector, and guidance that does exist usually exists to address very specific scenarios.
- Public bodies view FOI through the lens of case management. FOI is usually viewed by applicants and the general public as a key part of our democracy’s information ecosystem. Inside government, it’s framed as a matter of active and inactive files. That’s not entirely inappropriate, but that framing has consequences for what is expected of FOI workers.
Our report unpacks these preliminary findings and discusses some of our work ahead. As we undertake further research over the coming months into 2026, we offer a discussion guide for ministries, for broader public sector organizations, and for applicants that aims to support a constructive dialogue on the administration of FOI. We look forward to presenting our final report on May 1, 2026.
About the research
FIPA is trying to bring a social scientific approach to the study of FOI. For years, civil society and regulatory research on FOI has focused on factors such as timeliness — that is, how quickly public bodies respond to requests and how often requests exceed statutory guidelines for processing. We maintain timeliness is a relevant measure — but is also just that, a measure, a snapshot in time that requires additional context.
We’re interested in how the actual work within public bodies is organized. We want to understand through government documents how FOI is in turn understood by the public service. How does somebody know what “policy advice” (a common justification for redacting or withholding portions of records subject to an FOI request) actually is? Is there a definition? A series of court decisions (or summaries) that are provided? A checklist of properties a document needs to have? Or is it a matter of ‘knowing it when you see it.’? With the design of our study, we are not doing participant observation, meaning we cannot directly observe FOI workers doing their jobs. But we can invest time in careful readings of documents informed by work in anthropology and science and technology studies — which is what we are doing.
This is slow research in novel territory, and we’re committed to getting it right. In recent years, regulators across the country have increasingly stressed the importance of better training and resourcing in FOI units, in addition to law reform where necessary. This research intends to deliver robust, theoretically-informed practical advice to all those charged with administering FOIPPA, which includes adequate appreciation and resources allocation for records management.
Having considered a range of directions in which we could choose to focus, we think can contribute answers to the following pressing issues:
- how documents are retrieved, and in particular how requests are formed and transformed;
- how documents are severed, with specific attention to how ‘harms assessments’ are composed;
- how records management obligations are organized; and
- what the occupational identity of records management and FOI work is.
Learn more about our access assessments by visiting these pages.
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FIPA is sharing a preliminary report of our efforts to study freedom of information (FOI) in BC.
Since late 2022, FIPA has been engaged on a research project that uses documents obtained through FOI requests to piece together how FOI requests are processed. We collected data from every public body subject to both the Freedom of Information Act and Protection of Privacy Act and Information Management Act in British Columbia — all 24 ministries in the government of British Columbia, and 32 broader public sector organizations (according to the 2024 legislation).
FOIPPA, passed in 1992, gives everyone a right of access to records in the custody or control of public bodies, subject only to specific exceptions. IMA is a newer statute: passed in 2015 in response to an FOI scandal that involved lapses in recordkeeping; the province passed IMA to replace the 80-year-old Document Disposal Act. For our purposes, the most important part of IMA is the creation of a Chief Records Officer, who has a mandate to “to promote effective information management by government bodies” and may issue directives toward that end.
Today, nearly everyone agrees that FOI — in all public bodies — is not working as well as it could. Following a preliminary review of the information we received we can discuss the following findings that may indicate why:
- The resources to implement FOIPPA and IMA effectively are concentrated in larger public bodies. The smaller the public body gets, the less likely it is to have developed plans or policies for responding to FOI requests specific to itself.
- Records management is decentralized, seemingly unintentionally, creating unintended consequences. The Information Management Act does not set a definite direction in how the government records are organized. That flexibility at the statute level is important, but it has not come with well-developed local plans to ensure consistent, quality recordkeeping strategies are implemented. Inconsistent or unclear recordkeeping can present challenges when public bodies are called upon to retrieve records in response to FOI requests.
- How responsive records are identified and redacted remains largely a black box. When we tried to understand the tasks of an FOI worker through the records released (i.e. interpreting requests, communicating and confirming the final request with applicants, locating the records, analyzing them for harms, etc.), we found it incredibly difficult to do so. Manuals are sparsely distributed across the public sector, and guidance that does exist usually exists to address very specific scenarios.
- Public bodies view FOI through the lens of case management. FOI is usually viewed by applicants and the general public as a key part of our democracy’s information ecosystem. Inside government, it’s framed as a matter of active and inactive files. That’s not entirely inappropriate, but that framing has consequences for what is expected of FOI workers.
Our report unpacks these preliminary findings and discusses some of our work ahead. As we undertake further research over the coming months into 2026, we offer a discussion guide for ministries, for broader public sector organizations, and for applicants that aims to support a constructive dialogue on the administration of FOI. We look forward to presenting our final report on May 1, 2026.
About the research
FIPA is trying to bring a social scientific approach to the study of FOI. For years, civil society and regulatory research on FOI has focused on factors such as timeliness — that is, how quickly public bodies respond to requests and how often requests exceed statutory guidelines for processing. We maintain timeliness is a relevant measure — but is also just that, a measure, a snapshot in time that requires additional context.
We’re interested in how the actual work within public bodies is organized. We want to understand through government documents how FOI is in turn understood by the public service. How does somebody know what “policy advice” (a common justification for redacting or withholding portions of records subject to an FOI request) actually is? Is there a definition? A series of court decisions (or summaries) that are provided? A checklist of properties a document needs to have? Or is it a matter of ‘knowing it when you see it.’? With the design of our study, we are not doing participant observation, meaning we cannot directly observe FOI workers doing their jobs. But we can invest time in careful readings of documents informed by work in anthropology and science and technology studies — which is what we are doing.
This is slow research in novel territory, and we’re committed to getting it right. In recent years, regulators across the country have increasingly stressed the importance of better training and resourcing in FOI units, in addition to law reform where necessary. This research intends to deliver robust, theoretically-informed practical advice to all those charged with administering FOIPPA, which includes adequate appreciation and resources allocation for records management.
Having considered a range of directions in which we could choose to focus, we think can contribute answers to the following pressing issues:
- how documents are retrieved, and in particular how requests are formed and transformed;
- how documents are severed, with specific attention to how ‘harms assessments’ are composed;
- how records management obligations are organized; and
- what the occupational identity of records management and FOI work is.
Learn more about our access assessments by visiting these pages.
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