Library and Archives Canada Annual Report on the Privacy Act: 2024-2025

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Highlights

The following is a summary of the key achievements of Library and Archives Canada (LAC) regarding the administration of the Privacy Act (the Act) during 2024–2025. The numbers presented below include formal privacy requests only.

Introduction

The Act provides all individuals, whether they are within or outside Canada, the right to access and to correct their personal information held by a government institution. The Act also provides the legal framework for the collection, retention, use, disclosure, disposition and validation of the accuracy of personal information in the administration of programs and activities by government institutions subject to the Act.

The Act defines “personal information” as “information about an identifiable individual that is recorded in any form”. Examples of personal information include data about the national or ethnic origin, colour, religion, age or marital status of an individual; the education or the medical, criminal, financial or employment history of an individual; the address, fingerprints or blood type of an individual; and any identifying number, symbol or other identifier assigned to an individual.

This report is prepared and tabled to Parliament in accordance with section 72 of the Act. It covers the period from April 1, 2024, to March 31, 2025, for LAC.

Mandate of Library and Archives Canada

The mandate of LAC is

Organizational structure

The organizational chart below outlines the reporting structure relating to the ATIP Branch at LAC in 2024–2025. The number of full-time employees (FTEs) in each section has been included with the team’s descriptions.

Figure 1: ATIP Branch reporting structure
Figure 1: ATIP Branch reporting structure - text version

Description: This figure is a line organizational chart that shows the reporting structure of the Access to Information and Privacy Branch in 2024-2025.

  • Librarian and Archivist of Canada
    • Assistant Deputy Minister, Collections
      • Director General, Access to Information and Privacy and ATIP coordinator
        • Chief of Staff
        • Strategic Advisor
        • Senior Advisor
        • Manager, Complaints Management
        • Manager, Planning and Coordination
          • Director, Access to Information, Operational and Historical Requests Division
            • ATIP Managers
            • Archival Research, Operational and Historical Requests
            • Military and Intelligence Requests
            • Declassification
            • Block Review (Proactive Access)
            • LGBT Purge 4SA
          • Director, Privacy, Personnel Records and Indigenous Requests Division
            • ATIP Managers
            • Personnel Records - Gatineau
            • Personnel Records - Winnipeg
            • Indigenous Requests
            • Privacy Management
          • Director, ATIP Operations Support Division
            • ATIP Managers
            • Triage and Registration
            • Systems and Reporting
            • Policies, Procedures & Workflows
            • Recruitment, Training & Development

Office of the Director General, ATIP (14.58 FTEs during the reporting period)

Chief of Staff

Strategic Advisor

Senior Advisor

Complaints Management

Planning and Coordination

Access to Information, Operational and Historical Requests Division (52.47 FTEs during the reporting period)

Archival Research, Operational and Historical Requests

Military and Intelligence Requests

Declassification

Block Review (Proactive Access)

LGBT Purge 4SA

Privacy, Personnel Records and Indigenous Requests Division (65.12 FTEs during the reporting period)

Personnel Records – Gatineau

Personnel Records – Winnipeg

Indigenous Requests

Privacy Management

Operations Support Division (44.13 FTEs during the reporting period)

Triage and Registration

Systems and Reporting

Policies, Procedures and Workflows

Recruitment, Training and Development

Other supporting functions (112.07 FTEs during the reporting period)

Since the majority of the historical records requested are in paper format, LAC ATIP Branch requires the support of additional teams within the organization to be able to fulfill its duties. Supporting functions provided by Research Support (14.934 FTEs), Circulation (9.147 FTEs), Digitization (20.967 FTEs), Regional Services (4.645 FTEs), government archivists (16.992 FTEs) and other staff from the Collections Sector (7.893 FTEs) were essential to the processing of ATIP requests.

During the reporting period, the ATIP Branch continued to require external support to meet the expanded operational needs arising from the temporary funding provided in response to the OIC systemic investigation.

The ATIP Branch also required support from LAC’s corporate functions such as human resources, finance, real properties, policy and strategic support, communications, information technologies, information management and web (37.492 FTEs).

Service agreements

LAC was not party to any service agreements under section 73.1 of the Privacy Act during the reporting period.

Delegation order

For the purposes of the Act, the Minister of Canadian Identity and Culture and Minister responsible for Official Languages (formerly the Minister of Canadian Heritage), delegates their powers, authorities and responsibilities to LAC, who is then accountable for developing, coordinating and implementing effective policies, guidelines, systems and procedures. This delegation order ensures that the Minister's responsibilities under the Act are met and that information is processed and disclosed appropriately.

At LAC, the Minister delegates their powers, authorities and responsibilities to

The delegation order effective during the first part of 2024–2025 was issued by the Minister of Canadian Heritage to LAC in May 2016. During the reporting period, LAC reviewed its delegation order to align with its new ATIP Branch structure and to ensure effective delegation for its functions and requirements. The new simplified instrument, which was signed in August 2024, enables the delegation of actions to appropriate lower levels within the organization using a risk-based approach, promoting greater efficiency and quicker response time. The delegation order is currently being implemented. A copy can be found in the appendix A of this report.

Types of requests processed under the Privacy Act

LAC has a distinct role in making accessible the historical government records of over 300 current and previously existing federal organizations. LAC is therefore the main channel to provide access to billions of pages of archival government records.

LAC’s collections of records are stored at its facilities in the National Capital Region, Renfrew, Winnipeg and Vancouver.

Government records

All government records deemed to have enduring historical (archival) value are transferred to LAC after they are no longer needed for operational purposes in the institution that created them. LAC thus collects, preserves and provides access to historical records created by the various departments and agencies of the federal government. The material in the collection amounts to over 250 linear kilometres of textual, cartographic, photographic, audiovisual and digital records dating back to 1867. The majority of these records are not openly available as they might contain sensitive or personal information that must be reviewed in accordance with ATIP legislation.

Requests to access historical records are typically large in scope and complex, as they often comprise multiple voluminous files. In addition, as LAC is not the creator of these records, it may need to consult with the originating institution prior to releasing information, which can result in longer processing time.

Files of former CAF members and former FPS

LAC holds and preserves 4.85 million personnel files of former CAF members and former FPS. Many of these files are semi-active, meaning they continue to be consulted for ongoing programs and benefits.

The control and supervision of the War Records Division of Veterans Affairs Canada (VAC) and all its records were transferred to LAC in accordance with Order in Council P.C. 1971–1989. Since 1971, LAC has worked with the relevant institutions (DND, VAC and Public Services and Procurement Canada) to provide necessary access to these records. Most of the ATI and privacy requests received each year by LAC are to access the military personnel files of former members of the CAF. These include:

LAC also processes requests for the medical or dental records of CAF regular and reserve members who were released from service more than five years ago or who died in service more than five years ago.

In addition, LAC holds the dormant records of former FPS that were transferred to LAC prior to July 2017. These records are held until a public servant becomes 80 years old, at which time that individual’s records can be destroyed. However, due to a litigation hold currently in place, no records are being destroyed at this time. Since July 2017, LAC no longer accepts the personnel files of former FPS for long-term retention. This is aligned with LAC's mandate to acquire and preserve records deemed to have archival value. Personnel records of former CAF members may be stored at LAC while awaiting the end of the retention period, after which they transfer to permanent or archival status. FPS records are not deemed to have archival value and can be destroyed under certain conditions once the retention period has been met, and barring any active litigation holds. As the personnel files of all CAF members will become archival, LAC will continue to receive them in perpetuity.

LAC operational records

While the overwhelming majority of LAC’s ATIP workload relates to its unique role in providing access to restricted archival records created by other GC institutions, LAC ATIP also has responsibilities relating to LAC’s own operations as an institution of the GC. These responsibilities include processing requests for records created by LAC itself or by its predecessor institutions, the National Library or National Archives, ensuring that LAC is meeting its responsibilities under the Act (including privacy regulations, policies and directives) and providing ATIP subject-matter expertise to support responses to parliamentary questions.

Formal and informal privacy request processes

Formal requests are those officially made under the Privacy Act. A response is required within 30 calendar days of the date the request was received by LAC, unless LAC invokes a one-time 30-day extension (section 15 of the Act). Requesters are entitled to make a formal complaint about the processing time of their request to the Office of the Privacy Commissioner at any time during or after the processing of their request.

Informal requests are not covered under the Act but are reviewed in the spirit of the Act. There are no legislated timelines for informal requests, and there is no recourse or complaint mechanism. The number and dates of requests received and the complexity of each request determine the time frames for completing informal requests.

LAC processes both formal and informal requests. Both processes require a page-by-page review of records by an ATIP analyst.

Table 1: Types of records processed under the Privacy Act in 2024–2025

Type of record

Type of request

Requests outstanding from previous reporting periods

Requests received

Requests completed

Requests carried over to next reporting period within legislated timelines

Requests carried over to next reporting period beyond legislated timelines

Total requests carried over to next reporting period

Personnel files of former CAF members and former FPS

Formal

317

2,376

2,294

330

71

401

Informal

2

2

4

0

0

0

Total

319

2,378

2,298

330

71

401

GC archival records

Formal

28

339

188

163

16

179

Informal

0

0

0

0

0

0

Total

28

339

188

163

16

179

LAC operational records

Formal

0

8

3

5

0

5

Informal

0

0

0

0

0

0

Total

0

8

3

5

0

5

Grand total (all types of records)

Formal

347

2,723

2,485

498

87

585

Informal

2

2

4

0

0

0

Total

349

2,725

2,489

498

87

585

Interpretation of the statistical report on the Privacy Act

All statistics included in these reports are representative of the most current data available to LAC at the time of writing the 2024–2025 Privacy Annual Report.

Informal requests processed under the Privacy Act

During the 2024–2025 fiscal year, LAC received two informal privacy requests —both of which were for the personnel files of former CAF members and former FPS—compared to 304 in 2023–2024.

Throughout the reporting period, LAC responded to four informal privacy requests, compared to 860 in 2023-2024.

At the end of the reporting period, LAC had no outstanding informal privacy requests and, consequently, did not carry over any requests into the 2025–2026 fiscal year.

The decrease in the number of informal privacy requests received and completed in 2024-2025 may be a result of the CAF-DND Sexual Misconduct Class Action Settlement coming to an end during the previous fiscal year, as the last claims were accepted in February 2023.

The following figure provides a three-year overview of informal Privacy requests at LAC.

Figure 2: Informal privacy requests trends
Figure 2: Informal privacy requests trends - text version

Description: This triple bar graph shows the number of Informal Privacy requests received. It provides information for the last three fiscal years.

Outstanding from previous reporting period:

  • 2022-2023: 878
  • 2023-2024: 558
  • 2024-2025: 2

Received:

  • 2022-2023: 2,899
  • 2023-2024: 304
  • 2024-2025: 2

Closed:

  • 2022-2023: 3,236
  • 2023-2024: 860
  • 2024-2025: 4

Carried over to next reporting period:

  • 2022-2023: 541
  • 2023-2024: 2
  • 2024-2025: 0

Formal Requests processed under the Privacy Act

The following figure provides a three-year overview of formal Privacy requests at LAC.

Figure 3: Formal privacy requests trends
Figure 3: Formal privacy requests trends - text version

Description: This triple bar graph shows the number of Formal Privacy requests received. It provides information for the last three fiscal years.

Outstanding from previous reporting period:

  • 2022-2023: 1,025
  • 2023-2024: 219
  • 2024-2025: 347

Received:

  • 2022-2023: 1,719
  • 2023-2024: 2,325
  • 2024-2025: 2,723

Closed:

  • 2022-2023: 2,525
  • 2023-2024: 2,199
  • 2024-2025: 2,485

Carried over to next reporting period:

  • 2022-2023: 219
  • 2023-2024: 345
  • 2024-2025: 585

Formal privacy requests received

During the 2024–2025 fiscal year, LAC received a total of 2,723 formal privacy requests:

Compared to the previous year, LAC saw an increase of 17% in the number of formal privacy requests received (2,723 compared to 2,325 in 2023–2024).

Figure 4: Formal privacy requests received by type of record
Figure 4: Formal privacy requests received by type of record - text version

Description: This figure is a pie graph that shows the number of Privacy requests received in 2024-2025 by type of record.

Former CAF and FPS Personnel Records: 87%

Government Archival Records: 12%

LAC Operational Records: Less than 1%

Formal privacy requests completed

In 2024–2025, LAC completed 2,485 formal privacy requests:

This represents an increase of 13% in completed formal privacy requests over the previous fiscal year, in which LAC responded to 2,199 formal privacy requests. This increase is the result of LAC’s ongoing efforts to put release packages into clients’ hands sooner and expand its capacity to manage ATIP requests efficiently.

The following table provides information on disclosure for formal privacy requests completed during 2024–2025.

Table 2: Disposition of privacy formal requests

Disposition of requests

Total

All disclosed

432 (17%)

Disclosed in part

1,439 (58%)

All exempted

1 (0%)

All excluded

0 (0%)

No records exist

248 (10%)

Request abandoned

365 (15%)

Neither confirmed nor denied

0 (0%)

Total

2,485

Requests closed within legislated timelines

In 2024–2025, LAC completed 90% (2,226 of 2,485) of formal privacy requests within legislated timelines. This represents an increase of 18% from 2023–2024, when 1,589 of 2,199 requests (72%) were completed within the legislated timelines.

Progress made on requests closed beyond legislated timelines (including any extensions taken)

Of the 259 requests closed beyond legislated timelines, 89% (231) exceeded timelines, including additional extensions taken, and 11% (28) exceeded timelines where no extension was taken.

The following table provides information on the completion time for formal privacy requests completed during 2024–2025.

Table 3: Completion time for formal privacy requests

Number of days

Requests completed within legislated timelines

Requests completed beyond legislated timelines

Total requests completed

0 to 15 days

944

0

944 (38%)

16 to 30 days

477

0

477 (19%)

31 to 60 days

804

17

822 (33%)

61 to 120 days

1

232

233 (9%)

121 to 180 days

0

1

1 (0%)

181 to 365 days

0

4

4 (0%)

More than 365 days

0

5

5 (0%)

Total

2,226

259

2,485

Other complexities

Over the past fiscal year, LAC dedicated significant resources to fulfilling an unexpected access to information request related to the disclosure of the Deschênes Part II Report, from the Commission of Inquiry on War Criminals 1985-1986. The nature and complexity of the request required the work of approximately 50 employees from across the organization. Consequently, during the processing of this request LAC needed to adjust priorities, resulting in delays in addressing the backlog of overdue requests, implementing new policies and procedures and responding to new requests. procedures and responding to new requests.

A unique challenge for LAC lies in the nature of the collection: it is primarily composed of physical, analog records—original source materials that were not born digital and have never been digitized. These billions of pages, originating from over 300 government institutions, exist in a wide variety of formats and are dispersed across multiple storage facilities nationwide. Every time an ATI or privacy request is received, a complex process begins: records must be identified, physically located, transported and digitized before any review or disclosure work can even start.

Adding to this complexity is the fact that many records are poorly described—or not described at all—making them difficult to locate without the specialized knowledge of LAC archivists. The situation is further complicated by preservation requirements: some documents, due to their age and fragility, are stored in climate-controlled environments and must be handled with exceptional care. In certain cases, records require mould remediation before digitization can occur—a necessary but time-consuming step.

After the relevant records have been retrieved and physically prepared (bindings removed, etc.), they are digitized. The speed at which materials are digitized depends on their physical state (fragile or stable), their physical size and the effort required to ensure images are captured clearly to be uploaded and processed in the ATIP redaction software. All these activities must occur before an ATIP analyst begins to review the digitized material for release.

Other sources of complexity for LAC are requests for documents for which it must seek legal advice and documents which contain personal information about more than one individual (e.g., medical or psychological records or records that contain listings of individuals).

Extensions

In 2024–2025, LAC invoked 1,028 extensions of 30 days under paragraph 15(a)(i) (Interference with operations) and two extensions of 30 days under paragraph 15(a)(ii) (Consultation).

Table 4: Length of extensions

Length of extension

15(a)(i) Interference with operations

15(a)(ii) Consultation

15(b) Translation purposes or conversion

Further review required to determine exemptions

Large volume of pages

Large volume of requests

Documents are difficult to obtain

Cabinet Confidences (Section 70)

External

Internal

1 to 15 days

0

0

0

0

0

0

0

0

16 to 30 days

1,028

1

70

1

0

2

0

0

Total

1,028

1

70

1

0

2

0

0

Pages reviewed and released under formal privacy requests

LAC reviewed 417,825 pages pursuant to formal privacy requests in 2024-2025, compared to 371,810 in 2023–2024, an increase of 12%.

The following chart provides the total number of pages reviewed by type of record within LAC’s collections.

Figure 5: Formal privacy requests: pages reviewed by type of record
Figure 5: Formal privacy requests: pages reviewed by type of record - text version

Description: This triple bar graph shows the number of pages reviewed for Formal privacy requests by type of records in the last three fiscal years.

LAC Operational Records:

  • 2022-2023: 7,020
  • 2023-2024: 79
  • 2024-2025: 6,891

Government Archival Records:

  • 2022-2023: 336,863
  • 2023-2024: 47,016
  • 2024-2025: 28,161

Former CAF and FPS Personnel Records:

  • 2022-2023: 154,862
  • 2023-2024: 324,715
  • 2024-2025: 382,773

LAC continues to promote digital delivery, but requesters may request paper copies of the requested records. In addition, LAC continued to offer its clients the ability to consult original records on site at its facilities in the National Capital Region, Winnipeg, and Vancouver.

Figure 6: Format of release packages
Figure 6: Format of release packages - text version

Description: This bar graph shows the number of release packages that were delivered during last fiscal year and in which format.

Digital: 1,297

Hard Copy: 574

Formal privacy requests carried over to next reporting period

At the end of the reporting period, LAC carried over a total of 585 formal privacy requests compared to 345 requests carried over in 2024-2025. LAC has also received 17% more privacy requests compared to the last fiscal year and closed 13% more requests. In addition, a larger number of the requests were completed within statutory timelines (90% compared to 72%). The temporary funding LAC received to increase its capacity to respond to ATI and privacy requests significantly contributed to these results.

Table 5: Requests carried over to next reporting period, broken down by reporting period received

Reporting period requests carried over were received

Requests carried over that were within legislated timelines as of March 31, 2025

Requests carried over that were beyond legislated timelines as of March 31, 2025

Total

2024-25

497

76

573

2023-24

1

1

2

2022-23

0

5

5

2021-22

0

5

5

2020-21 or earlier

0

0

0

Total

498

87

585

Reasons for not meeting legislated timelines

All 259 requests closed as “deemed refusals”, because they did meet legislated timelines, were due to the large number of requests to be processed, a high volume of records being requested, or other ATIP-related tasks.

Table 6: Reasons for deemed refusals

Reason for deemed refusals

Total

Interference with operations/workload

259

External consultation

0

Internal consultation

0

Other

0

Note: An institution calculates deemed refusals once the request is closed. In some cases, the deemed refusals pertain to requests that were carried over from the previous fiscal year.

Disclosures under subsection 8(2) and 8(5) of the Privacy Act

During 2024–2025, LAC completed 116 requests for disclosures under subsection 8(2) of the Act. Of these requests, 69 were disclosed either fully or in part, and 47 were either abandoned by the applicant or no records existed.

LAC disclosed personal information in 10 cases in accordance with paragraph 8(2)(e), which provides access of personal information to an investigative body specified for the purpose of enforcing any law of Canada or a province or carrying out a lawful investigation, if the request specifies the purpose and describes the personal information to be disclosed.

LAC also released personal information in 36 instances in accordance with paragraph 8(2)(k) of the Act, which stipulates that information could be released to an individual or a body acting on behalf of an Indigenous community for the purpose of researching and validating a land claim or grievance.

What follows is a summary of all of LAC’s disclosures of personal information under subsection 8(2) of the Act.

Table 7: Disclosures of personal information under subsection 8(2) and 8(5) of the Privacy Act

Subsection

Number of disclosures

s.8(2)(a)

2

s.8(2)(b)

0

s.8(2)(c)

2

s.8(2)(d)

20

s.8(2)(e)

10

s.8(2)(f)

0

s.8(2)(g)

0

s.8(2)(j)

0

s.8(2)(k)

36

s.8(2)(m)

2

Total

69

Requests for correction and personal information and notations

During 2024–2025, LAC received no requests to correct personal information.

Consultations from other Government of Canada institutions and other organizations

In 2024–2025, LAC received and completed no requests for consultation from other institutions within the GC, nor from any other organizations, in connection with privacy requests.

Requests for translation

LAC did not translate any documents from English to French or from French to English in 2024–2025.

Investigations

LAC carried over two open complaints with the OPC from the previous reporting period.

In 2024-2025, LAC received two notices of intention to investigate from the OPC, and four complaints were resolved.

At the end of the reporting period, LAC had no active complaints with the OPC.

Non-material privacy breaches

A total of 31 non-material privacy breaches and privacy incidents occurred during the reporting period.

Resources related to the Privacy Act

In addition to the activities undertaken by LAC’s ATIP Branch, it is important to recognize the essential support provided by staff throughout the institution—such as archivists and employees in the front-line public service area of Research Support and the behind-the-scenes areas of Circulation, Preservation, Digitization, Translation, Information Technologies and Web Publishing—who contributed significantly to the ATI and privacy functions and helped ensure LAC’s compliance with the Access to Information Act, the Privacy Act and related policies.

At the end of the reporting period, 190.995 full-time equivalents were performing work associated to the application of the acts across the institution. This is significant given that the institution’s total number of employees in 2024–2025 was 1,201 FTEs, meaning that 16% were involved in ensuring the processing of ATI and privacy requests.

Additional resources from outside the ATIP Branch continued to be necessary to support the expanded operational requirements resulting from the temporary funding received following the OIC systemic investigation. These resources included expenditures on professional services contracts for digital services, such as procuring additional secure workstations and implementing new information technologies.

LAC’s additional temporary funding helped reduce the number of requests carried over to 2024–2025 by 34%. This substantive decrease demonstrates LAC’s efforts to improve its capacity and its ability to meet the annual volume of incoming requests. This multi-year temporary investment of resources will allow LAC to reduce and ultimately eliminate its backlog of overdue requests and to meet the volume of incoming requests annually, including supporting responses to GC class action litigation that arrive through the ATIP channel.

Training and awareness

During the reporting period, LAC’s Privacy Management Team (PMT) provided English and French training sessions to employees. A total of 369 employees attended the official training sessions on the topics of Privacy 101, Privacy Breaches, and Introduction to Privacy Risk Assessment. Three different training modules on the same topics were also provided to employees.

Through the course of the past fiscal year, the PMT also hosted two events, Data Privacy Day and Privacy Awareness Week to help raise awareness regarding the importance of privacy and establish best practices throughout organization. These events included the published Intranet articles, training sessions, and social activities aimed at reinforcing best practices for privacy. 

Coordination of training and recruitment for the ATIP Branch is centralized within the ATIP Recruitment, Training and Development Team. During 2024-2025, the Branch onboarded new employees and students and reached out to an Indigenous community to improve Indigenous workforce representation at LAC. Furthermore, the Branch standardized staffing documents while finalizing supporting documents for the Career Development Program for ATIP analysts at LAC, including performance assessment templates and training and development guides. The Branch also facilitated the enrolment of selected LAC ATIP staff to the ATIP Training Program with the Association of Access to Information and Privacy Professionals.

Moreover, the ATIP Branch collaborated with other areas within LAC to provide basic training materials to new ATIP staff on how to navigate archival records and resources available at LAC. The Branch also created internal training microlearning courses tailored specifically for LAC ATIP staff. These courses cover a broad range of topics, including international requesters, key dates, client codes for personnel records, required documents for ATIP requests and searching in the Military and Government Personnel Information Index. The courses are designed to ensure that staff have access to thorough and up-to-date learning resources and can be used as reference tools as they are easily accessible.

LAC also continued to offer both group and ATIP Branch-specific training sessions to its staff. Nine presentations highlighting the work of various teams within the ATIP Branch were delivered to a broad LAC audience, enhancing staff understanding of the diverse roles and responsibilities within LAC ATIP. These sessions promote collaboration and keep employees informed about the overall operations of the ATIP Branch, including significant changes.

Towards the end of the fiscal year, training was provided to prepare for the implementation of the new case management software, ATIPXpress. A total of fourteen training sessions about various workflows and functionalities were offered and were specifically tailored to the role of each team. Individual and group question and answer sessions were also organized, as needed. The Branch also created a hub in its collaborative portal where all the procedures are readily available for staff to use.

Policies, guidelines and procedures

In fiscal year 2024-2025, LAC has been revising its privacy policy suite. The objectives of this policy suite are to implement the following:

To avoid the excessive and unnecessary collection of personal information, LAC has proactively reviewed its practices related to the collection of personal data during the processing of requests.

During fiscal year 24-25, LAC developed a new Procedure for the Public Interest Disclosure of Personal Information Pursuant to 8(2)(m)(i) of the Privacy Act. The development was informed by consultations with other Government of Canada institutions, including examples of such procedures developed within other institutions. LAC also conducted targeted stakeholder consultations with specific interest groups including ATI and Privacy experts from across Canada, representatives from provincial and territorial archives across Canada, and historians. The new procedure provides guidance to LAC when considering potential disclosures of archival records and includes for consideration the mandatory factors: government transparency and accountability, passage of time, probability and degree of consequence. It also includes additional optional factors: urgency of public interest, expectations of the individual, sensitivity of personal information and extent of disclosure – depth.

Initiatives and projects to improve privacy awareness/management

Activities conducted by the Privacy Management Team

In the 2024-2025 reporting period, the PMT has continued to provide advice, training, and breach management services to LAC. The PMT has continued refining and improving its services by updating its suite of templates, procedures and workflows, as well as overarching policies. It also completed 95 requests for advisory services.

This latter service includes requests related to:

The team also provided advice on multiple projects for the potential opening of archival records in LAC’s collection, in particular a grouping focused on releasing military personnel records outside of the ATIP process. The Korean War Killed in Action (KIA) and Historical Military Personnel Records projects are exploring options to consider opening large segments of military personnel records outside of the formal ATIP request process, just as LAC does with other archival records in its collection through Proactive Access (Block Review) procedures. These records are in extremely high demand for LAC’s clients conducting genealogy research and represent a considerable portion of LAC’s ATIP requests as they contain a wealth of personal information. The PMT advised on best practices in handling this personal information on the basis of analyses of the risks of potential harm to concerned individuals.

During the reporting period, the PMT has completed seven preliminary risk checklists for various initiatives, programs, projects, activities, and services undertaken at LAC to ensure compliance with the Privacy Act, Directives on Privacy Practices, and Privacy Regulations.

Other initiatives

Created in 2023, the Archival Research Team at LAC continued producing research reports to help analysts make informed decisions about the release of information, with the goal of reducing or eliminating the need for consultation with other institutions and to inform LAC on the analysis and disclosure of potentially sensitive information (personal or access related). In 2024–2025, over 300 research reports were created, and consequently LAC saw a decrease of 86% in the number of consultations required on military and intelligence subjects, excluding consultations with the Canadian Security Intelligence Service. Out of 140 requests closed on military and intelligence subjects that would normally have required consultation to obtain subject matter expertise from the originating institution, 121 no longer required external consultation. Through the course of the year, the work of the Archival Research Team has become an integral up-front part of the ATIP analysis process. The quality and effectiveness of the research reports enabled LAC to assert its delegated authority under ATI and privacy in a responsible and informed manner and to provide quicker responses to clients.

LAC continues to play an active role in the reviews of the Access to Information Act and the Privacy Act, working closely with the Treasury Board Secretariat and federal partners. This collaboration ensures LAC’s archival expertise and mandate—to preserve and provide access to government records—are reflected in policy updates that balance transparency with the protection of personal information. As co-lead of an interdepartmental working group on the complaints process, LAC also contributed to broader ATIP system improvements. In parallel, LAC supported discussions on declassification strategies and Indigenous data sovereignty initiatives.

LAC has held regular meetings with the National Centre for Truth and Reconciliation to explore ways to connect data related to Indigenous requests between both of their websites and to promote the sharing of best practices and tools. LAC also continued meetings with the National Claims Research Directors to engage with them and to advise them of new ATIP processes and LAC’s progress in tackling overdue requests and keeping up with ongoing volume.

LGBT Purge Fourth Supplementary Settlement Agreement

During the last reporting period, LAC completed its portion of the ATIP-informed work related to the LGBT Purge Fourth Supplementary Settlement Agreement, marking a key milestone in this significant initiative. Working in collaboration with other government institutions, LAC reviewed approximately 11,000 pages of material. This effort underscored a strong commitment to transparency, accountability and the preservation and sharing of historical records that document the experiences of 2SLGBTQI+ individuals within the federal public service and the Canadian Armed Forces.

Technology-Related initiatives

Through the course of the fiscal year, LAC completed the configuration of its new case management system, ATIPXpress, on the Protected B network. LAC began registering and processing new incoming requests using ATIPXpress as of April 1, 2025.

LAC also expanded its secure network infrastructure, improving its ability to manage digital and digitized sensitive and classified records more efficiently. These upgrades ensured that requests involving Secret and Top Secret information were handled in a more timely manner while ensuring full compliance with Government of Canada security standards. The strengthened secure network capacity also enabled more efficient secure communication and collaboration with other government institutions on matters involving classified records.

Summary of key issues and action taken on complaints

LAC remains committed to actively addressing the complaints it receives while maintaining a collaborative relationship with the OPC. It also remains actively engaged with TBS and other federal institutions to improve the ATIP system, serving as co-lead of an interdepartmental working group focused on enhancing the complaints management process.

At the end of the reporting period, LAC had no open complaints with the OPC compared to two in 2023–2024.

Material privacy breaches

During 2024–2025, LAC did not have any material privacy breaches.

Privacy impact assessments

In 2024–2025, LAC did not complete any new privacy impact assessments. LAC is currently working on revising or completing PIAs for all of LAC’s programs and activities that include the collection, use and/or management of personal information.

Public interest disclosures

During the reporting period, LAC disclosed personal information twice in response to requests in accordance with paragraph 8(2)(m) of the Act, whereby the head of the institution is of the opinion that the disclosure of personal information is considered to be in the public interest. In both instances, the disclosures were to help identify the heirs of deceased individuals. After conducting related reviews, LAC concluded that it should disclose the personal information (name, address and contact information of family members) because the disclosure outweighed any invasion of privacy and the potential heirs would benefit from the release of their personal information. In both cases, the OPC was notified prior to the disclosure of the information.

Monitoring compliance

In fiscal year 2024–2025, LAC continued to monitor the time taken to process privacy requests through its specialized ATIP software AccessPro Case Management (APCM). This software enabled LAC to track all activities related to requests (e.g., time management, correspondence and consultations) and allowed each activity to be reported on with specific timelines.

LAC maintained its efforts to monitor data integrity through comprehensive monthly reviews conducted by a system specialist, which facilitated compliance with applicable regulations, policies and procedures as well as accurate reporting. Managers and team leads used automated dashboards to assess their teams’ workloads and to track the timeliness of the completion of requests. Branch management meetings regularly reviewed and discussed the overall workload to facilitate improvements in completion times. Additional tools such as dashboards, system-designed reports and search builders were available to all users, allowing them to track all active and closed requests for accuracy and completeness.

Appendices

Appendix A: Delegation Order – Privacy Act

As head of Library and Archives Canada (LAC) for the purposes of the Access to Information Act (ATIA) and the Privacy Act (PA), the Minister of Canadian Heritage, pursuant to subsections 95(1) of the ATIA and 73(1) of the PA, delegates the following powers, duties and functions under these Acts to the persons holding the LAC 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.

As of August 16th,2024, a new delegation order was signed by Minister St-Onge, Minister of Canadian Heritage at the time, replacing the previous delegation order.

Original signed by:

The Honourable Pascale St-Onge
Minister of Canadian Heritage
Date: 2024-08-16

Positions Access to Information Act and Regulations Privacy Act and Regulations
  • Librarian and Archivist of Canada
  • Assistant Deputy Minister, Collections
  • Access to Information and Privacy (ATIP) Coordinator
  • Director, ATIP Branch
  • Manager, ATIP
Full authority (including for the Act as it was prior to June 21, 2019) Full authority
  • Team Lead, ATIP
  • Senior Analyst, ATIP
  • Analyst, ATIP
  • Junior Analyst, ATIP
  • Senior Lead Archivist
  • Lead Archivist
  • Senior Archivist
  • Archivist
Full Authority, except for paragraphs 12(2)(b) and 12(3)(b) of the Act (including for the Act as it was prior to June 21, 2019) Authority for sections 18 to 37 of the Act and subsection 72(1) of the Act
Junior Officer, ATIP Authority for subsection 19(1) of the Act (including for the Act as it was prior to June 21, 2019) Authority for section 26 of the Act

Appendix B: Statistical report on the Privacy Act

Name of institution: Library and Archives Canada

Reporting period: 2024-04-01 to 2025-03-31

Section 1: Requests under the Privacy Act

1.1 Number of requests received

Number of requests

Received during reporting period

2,723

Outstanding from previous reporting periods

347

Outstanding from previous reporting period

330

Outstanding from more than one reporting period

17

Total

3,070

Closed during reporting period

2,485

Carried over to next reporting period

585

Carried over within legislated timeline

498

Carried over beyond legislated timeline

87

1.2 Channels of requests

Source

Number of requests

Online

1,198

Email

851

Mail

523

In person

1

Phone

0

Fax

150

Total

2,723

Section 2: Informal requests

2.1 Number of informal requests

Number of requests

Received during reporting period

2

Outstanding from previous reporting periods

2

Outstanding from previous reporting period

0

Outstanding from more than one reporting period

2

Total

4

Closed during reporting period

4

Carried over to next reporting period

0

2.2 Channels of informal requests

Channel

Number of requests

Online

0

Email

2

Mail

0

In person

0

Phone

0

Fax

0

Total

2

2.3 Completion time of informal requests

Completion time

0 day to 15 days

16 to 30 days

31 to 60 days

61 to 120 days

121 to 180 days

181 to 365 days

More than 365 days

Total

2

0

0

0

0

2

0

4

2.4 Pages released informally

Fewer than 100 pages released

101 to 500 pages released

501 to 1,000 pages released

1,001 to 5,000 pages released

More than 5,000 pages released

Number of requests

Pages released

Number of requests

Pages released

Number of requests

Pages released

Number of requests

Pages released

Number of requests

Pages released

3

13

0

0

1

661

0

0

0

0

Section 3: Requests closed during the reporting period

3.1 Disposition and completion time

Disposition of request

Completion time

0 day to 15 days

16 to 30 days

31 to 60 days

61 to 120 days

121 to 180 days

181 to 365 days

More than 365 days

Total

All disclosed

210

183

30

7

0

2

0

432

Disclosed in part

206

247

763

219

0

2

2

1,439

All exempted

0

0

1

0

0

0

0

1

All excluded

0

0

0

0

0

0

0

0

No records exist

182

37

24

3

0

0

2

248

Request abandoned

346

10

3

4

1

0

1

365

Neither confirmed nor denied

0

0

0

0

0

0

0

0

Total

944

477

821

233

1

4

5

2,485

3.2 Exemptions

Section

Number of requests

18(2)

0

19(1)(a)

0

19(1)(b)

0

19(1)(c)

1

19(1)(d)

1

19(1)(e)

0

19(1)(f)

0

20

0

21

1

22(1)(a)(i)

0

22(1)(a)(ii)

0

22(1)(a)(iii)

0

22(1)(b)

1

22(1)(c)

0

22(2)

0

22.1

0

22.2

0

22.3

0

22.4

0

23(a)

1

23(b)

0

24(a)

0

24(b)

0

25

2

26

1,433

27

1

27.1

1

28

2

3.3 Exclusions

Section

Number of requests

69(1)(a)

0

69(1)(b)

0

69.1

0

70(1)

0

70(1)(a)

0

70(1)(b)

0

70(1)(c)

0

70(1)(d)

0

70(1)(e)

0

70(1)(f)

0

70.1

0

3.4 Format of information released

Paper

Electronic record

Electronic data set

Video

Audio

Other

574

1,297

0

0

0

0

3.5 Complexity

3.5.1 Relevant pages processed and disclosed for paper, e-record and dataset formats

Number of pages processed

Number of pages disclosed

Number of requests

417,825

406,309

2,237

3.5.2 Relevant pages processed per request disposition for paper and electronic record formats by size of request

Disposition

Fewer than 100 pages processed

101 to 500 pages processed

501 to 1,000
pages processed

1,001 to 5,000 pages processed

More than 5,000 pages processed

Number of requests

Pages processed

Number of requests

Pages processed

Number of requests

Pages processed

Number of requests

Pages processed

Number of requests

Pages processed

All disclosed

430

2,380

2

275

0

0

0

0

0

0

Disclosed in part

643

17,707

491

130,710

236

166,562

69

93,888

0

0

All exempted

0

0

0

0

0

0

0

0

1

6,059

All excluded

0

0

0

0

0

0

0

0

0

0

Request abandoned

364

22

1

222

0

0

0

0

0

0

Neither confirmed nor denied

0

0

0

0

0

0

0

0

0

0

Total

1,437

20,109

494

131,207

236

166,562

69

93,888

1

6,059

3.5.3 Relevant minutes processed and disclosed for audio formats

Number of minutes processed

Number of minutes disclosed

Number of requests

0

0

0

3.5.4 Relevant minutes processed per request disposition for audio formats by size of requests

Disposition

Less than 60 minutes processed

60 to 120 minutes processed

More than 120 minutes processed

Number of requests

Minutes processed

Number of requests

Minutes processed

Number of requests

Minutes processed

All disclosed

0

0

0

0

0

0

Disclosed in part

0

0

0

0

0

0

All exempted

0

0

0

0

0

0

All excluded

0

0

0

0

0

0

Request abandoned

0

0

0

0

0

0

Neither confirmed nor denied

0

0

0

0

0

0

Total

0

0

0

0

0

0

3.5.5 Relevant minutes processed and disclosed for video formats

Number of minutes processed

Number of minutes disclosed

Number of requests

0

0

0

3.5.6 Relevant minutes processed per request disposition for video formats by size of requests

Disposition

Less than 60 minutes processed

60 to 120 minutes processed

More than 120 minutes processed

Number of requests

Minutes processed

Number of requests

Minutes processed

Number of requests

Minutes processed

All disclosed

0

0

0

0

0

0

Disclosed in part

0

0

0

0

0

0

All exempted

0

0

0

0

0

0

All excluded

0

0

0

0

0

0

Request abandoned

0

0

0

0

0

0

Neither confirmed nor denied

0

0

0

0

0

0

Total

0

0

0

0

0

0

3.5.7 Other complexities

Disposition

Consultation required

Legal advice sought

Interwoven information

Other

Total

All disclosed

0

0

0

0

0

Disclosed in part

1

0

0

0

1

All exempted

0

0

0

0

0

All excluded

0

0

0

0

0

Request abandoned

0

0

0

0

0

Neither confirmed nor denied

0

0

0

0

0

Total

1

0

0

0

1

3.6 Closed requests

3.6.1 Number of requests closed within legislated timelines

Requests closed within legislated timelines

Number of requests closed within legislated timelines

2,226

Percentage of requests closed within legislated timelines

89.57746479

3.7 Deemed refusals

3.7.1 Reasons for not meeting legislated timelines

Number of requests closed past the legislated timelines

Principal reason

Interference with operations or workload

External consultation

Internal consultation

Other

259

259

0

0

0

3.7.2 Request closed beyond legislated timelines (including any extensions taken)

Number of days past legislated timelines

Number of requests past legislated timeline where no extension was taken

Number of requests past legislated timeline where an extension was taken

Total

1 day to 15 days

10

175

185

16 to 30 days

7

46

53

31 to 60 days

3

7

10

61 to 120 days

1

0

1

121 to 180 days

2

2

4

181 to 365 days

1

0

1

More than 365 days

4

1

5

Total

28

231

259

3.8 Requests for translation

Translation requests

Accepted

Refused

Total

English to French

0

0

0

French to English

0

0

0

Total

0

0

0

Section 4: Disclosures under subsections 8(2) and 8(5)

Paragraph 8(2)(e)

Paragraph 8(2)(m)

Paragraph 8(5)

Total

10

2

2

14

Section 5: Requests for correction of personal information and notations

Disposition for correction request received

Number

Notation attached

0

Requests for correction accepted

0

Total

0

Section 6: Extensions

6.1 Reason for extensions

15(a)(i) Interference with operations

15(a)(ii) Consultation

15(b) Translation purposes or conversion

Number of extensions taken

Further review required to determine exemptions

Large volume of pages

Large volume of requests

Documents are difficult to obtain

Cabinet Confidence Section (Section 70)

External

Internal

1,102

1,028

1

70

1

0

2

0

0

6.2 Length of extensions

15(a)(i) Interference with operations

15(a)(ii) Consultation

15(b) Translation purposes or conversion

Length of extensions

Further review required to determine exemptions

Large volume of pages

Large volume of requests

Documents are difficult to obtain

Cabinet Confidence Section (Section 70)

External

Internal

1 to 15 days

0

0

0

0

0

0

0

0

16 to 30 days

1,028

1

70

1

0

2

0

0

31 days or greater

0

Total

1,028

1

70

1

0

2

0

0

Section 7: Consultations received from other institutions and organizations

7.1 Consultations received from other Government of Canada institutions and other organizations

Consultations

Other Government of Canada institutions

Number of pages to review

Other organizations

Number of pages to review

Received during the reporting period

0

0

0

0

Outstanding from the previous reporting period

0

0

0

0

Total

0

0

0

0

Closed during the reporting period

0

0

0

0

Carried over within negotiated timelines

0

0

0

0

Carried over beyond negotiated timelines

0

0

0

0

7.2 Recommendations and completion time for consultations received from other Government of Canada institutions

Recommendations

Number of days required to complete consultation requests

1 day to 15 days

16 to 30 days

31 to 60 days

61 to 120 days

121 to 180 days

181 to 365 days

More than 365 days

Total

Disclose entirely

0

0

0

0

0

0

0

0

Disclose in part

0

0

0

0

0

0

0

0

Exempt entirely

0

0

0

0

0

0

0

0

Exclude entirely

0

0

0

0

0

0

0

0

Consult other institution

0

0

0

0

0

0

0

0

Other

0

0

0

0

0

0

0

0

Total

0

0

0

0

0

0

0

0

7.3 Recommendations and completion time for consultations received from other organizations outside the Government of Canada

Recommendations

Number of days required to complete consultation requests

1 day to 15 days

16 to 30 days

31 to 60 days

61 to 120 days

121 to 180 days

181 to 365 days

More than 365 days

Total

Disclose entirely

0

0

0

0

0

0

0

0

Disclose in part

0

0

0

0

0

0

0

0

Exempt entirely

0

0

0

0

0

0

0

0

Exclude entirely

0

0

0

0

0

0

0

0

Consult other institution

0

0

0

0

0

0

0

0

Other

0

0

0

0

0

0

0

0

Total

0

0

0

0

0

0

0

0

Section 8: Completion time of consultations on Cabinet confidences

8.1 Requests with Legal Services

Number of days

Fewer than 100 pages processed

101 to 500 pages processed

501 to 1,000 pages processed

1,001 to 5,000 pages processed

More than 5,000 pages processed

Number of requests

Pages disclosed

Number of requests

Pages disclosed

Number of requests

Pages disclosed

Number of requests

Pages disclosed

Number of requests

Pages disclosed

1 to 15

0

0

0

0

0

0

0

0

0

0

16 to 30

0

0

0

0

0

0

0

0

0

0

31 to 60

0

0

0

0

0

0

0

0

0

0

61 to 120

0

0

0

0

0

0

0

0

0

0

121 to 180

0

0

0

0

0

0

0

0

0

0

181 to 365

0

0

0

0

0

0

0

0

0

0

More than 365

0

0

0

0

0

0

0

0

0

0

Total

0

0

0

0

0

0

0

0

0

0

8.2 Requests with the Privy Council Office

Number of days

Fewer than 100 pages processed

101 to 500 pages processed

501 to 1,000 pages processed

1,001 to 5,000 pages processed

More than 5,000 pages processed

Number of requests

Pages disclosed

Number of requests

Pages disclosed

Number of requests

Pages disclosed

Number of requests

Pages disclosed

Number of requests

Pages disclosed

1 to 15

0

0

0

0

0

0

0

0

0

0

16 to 30

0

0

0

0

0

0

0

0

0

0

31 to 60

0

0

0

0

0

0

0

0

0

0

61 to 120

0

0

0

0

0

0

0

0

0

0

121 to 180

0

0

0

0

0

0

0

0

0

0

181 to 365

0

0

0

0

0

0

0

0

0

0

More than 365

0

0

0

0

0

0

0

0

0

0

Total

0

0

0

0

0

0

0

0

0

0

Section 9: Complaints and investigation of notices received

Section 31

Subsection 33

Section 35

Court action

Total

2

0

4

0

6

Section 10: Privacy Impact Assessments (PIAs) and Personal Information Banks (PIBs)

10.1 Privacy impact assessments

Number of PIAs completed

0

Number of PIAs modified

0

10.2 Institution-specific and Central Information Banks

Personal information banks

Active

Created

Terminated

Modified

Institution-specific

24

0

0

0

Central

1

0

0

0

Total

25

0

0

0

Section 11: Privacy breaches

11.1 Material privacy breaches reported

Number of material privacy breaches reported to TBS

Number of material privacy breaches reported to OPC

0

0

11.2 Non-material privacy breaches

Number of non-material privacy breaches

31

Section 12: Resources related to the Privacy Act

12.1 Allocated costs

Expenditures

Amount

Salaries

$4,871,651

Overtime

$14,343

Goods and services

$697,843

  • Professional services contracts

$224,956

  • Other

$472,887

Total

$5,583,837

12.2 Human resources

Resources

Person years dedicated to Privacy Activities

Full-time employees

35.334

Part-time and casual employees

19.972

Regional staff

0.929

Consultants and agency personnel

0.000

Students

1.927

Total

58.162

Appendix C: Supplemental statistical report on the Access to Information Act and the Privacy Act

Name of institution: Library and Archives Canada

Reporting period: 2024-04-01 to 2025-03-31

Section 1: Open requests and complaints under the Access to Information Act

1.1 Enter the number of open requests that are outstanding from previous reporting periods

Fiscal year open request was received

Open request within legislated timeline as of March 31, 2024

Open request beyond legislated timeline as of March 31, 2024

Total

2024–25

1,559

137

1,696

2023–24

45

94

139

2022–23

24

239

263

2021–22

0

370

370

2020–21

0

334

334

2019–20

1

413

414

2018–19

1

89

90

2017–18

1

89

90

2016–17

0

22

22

2015–16 or earlier

0

8

8

Total

1,631

1,795

3,426

1.2 Enter the number of open complaints with the Information Commissioner of Canada that are outstanding from previous reporting periods

Fiscal year open complaints were received by institution

Number of open complaints

2024–25

71

2023–24

29

2022–23

13

2021–22

3

2020–21

1

2019–20

5

2018–19

0

2017–18

0

2016–17

0

2015–16 or earlier

1

Total

123

Section 2: Open requests and complaints under the Privacy Act

2.1 Enter the number of open requests that are outstanding from previous reporting periods

Fiscal year open request were received

Open request within legislated timeline as of March 31, 2024

Open request beyond legislated timeline as of March 31, 2024

Total

2024–25

 497

76

573

2023–24

1

1

2

2022–23

0

5

5

2021–22

0

5

5

2020–21

0

0

0

2019–20

0

0

0

2018–19

0

0

0

2017–18

0

0

0

2016–17

0

0

0

2015–16 or earlier

0

0

0

Total

498

87 

585

2.2 Enter the number of open complaints with the Privacy Commissioner of Canada that are outstanding from previous reporting periods

Fiscal year open complaints were received by institution

Number of open complaints

2024–25

0

2023–24

0

2022–23

0

2021–22

0

2020–21

0

2019–20

0

2018–19

0

2017–18

0

2016–17

0

2015–16 or earlier

0

Total

0

Section 3: Social Insurance Number

Has your institution begun a new collection or a new consistent use of the SIN in 2024-25?

No

Section 4: Universal access under the Privacy Act

Universal access under the Privacy Act

How many requests were received from confirmed foreign nationals outside of Canada in 2024-25?

61

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2025-11-05