2024-2025 Annual Report to Parliament on the Access to Information Act

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Introduction

Access to Information Act

The purpose of the Access to Information Act (ATIA) is to enhance the accountability and transparency of federal institutions in order to promote an open and democratic society and to enable public debate on the conduct of those institutions.

Part 1 of the Access to Information Act extends the present laws of Canada to provide a right of access to information in records under the control of a government institution in accordance with the principles that government information should be available to the public, that necessaroy exceptions to the right of access should be limited and specific and that decisions on the disclosure of government information should be reviewed independently of government.

Part 2 of the Access to Information Act sets out requirements for the proactive publication of information.

Mandate of the Privy Council Office

The Privy Council Office (PCO) reports directly to the Prime Minister and is headed by the Clerk of the Privy Council and Secretary to the Cabinet. PCO is both the Cabinet secretariat and the Prime Minister’s source of public service advice across the entire spectrum of policy questions and operational issues facing the Government. As the hub of non-partisan, public service support to the Prime Minister, Cabinet and its decision-making structures, PCO ensures that the Government and Canadians are served by the highest quality public service.

PCO provides support to the Prime Minister, as well as to the Leader of the Government in the House of Commons, Minister of Transport and Internal Trade, the President of the King’s Privy Council for Canada and Minister responsible for Canada-U.S. Trade, Intergovernmental Affairs, and One Canadian Economy, and the Minister of Canadian Culture and Identity and Minister responsible for Official Languages in his capacity as Quebec Lieutenant.

PCO’s three (3) main roles are to:

1. Provide professional non-partisan advice to the Prime Minister, portfolio ministers, Cabinet and Cabinet committees on matters of national and international importance.
2. Ensure that the Cabinet decision-making process runs smoothly and help implement the Government’s agenda.
3. Foster a high-performing and accountable Public Service.

This is the 42nd Annual Report to Parliamenton the administration of the Access to Information Act (ATIA) by PCO, submitted as required by section 94 of the ATIA. This report covers the reporting period of April 1, 2024 to March 31, 2025. PCO is not reporting on behalf of wholly owned subsidiaries or non-operational institutions.

Additional copies of this report may be obtained by contacting:

• Access to Information and Privacy Division
  Privy Council Office
  11 Metcalfe Street
  Ottawa, Ontario K1A 0A3

Highlights

In the 2024-2025 reporting period, PCO received seven hundred and forty-four (744) requests and closed seven hundred and twelve (712) requests, compared to one thousand seventy-nine (1,079) requests received and seven hundred and seventy-eight (778) requests closed in 2023-2024.

In 2024-2025, 706,796 relevant pages were processed, which represents a 299% increase in the pages reviewed from the previous year. This increase is due to one (1) request totalling 574,971 relevant pages processed. Without this request, 131,825 relevant pages were processed. The page volume does not account for proactive disclosure of briefing note titles, transition material, and committee binders.

Access to Information and Privacy (ATIP) division – organizational structure

The ATIP division within PCO is responsible for managing requests for departmental or personal information, ensuring corporate understanding and compliance with the ATIA and the Privacy Act (PA), and fostering corporate awareness of access and privacy rights and responsibilities. On matters of access and privacy, the ATIP division also acts as a primary liaison with the Office of the Information Commissioner (OIC), the Office of the Privacy Commissioner (OPC), the Access to Information Policy and Performance Division (AIPPD) of Treasury Board of Canada Secretariat (TBS), and partner departments.

PCO did not provide services as defined by section 96 of the ATIA to another government institution during this reporting period. PCO also did not receive these types of services.

While exact staffing and distribution of tasks fluctuate, over the reporting period, the ATIP division had a personnel complement of 28.2 full-time equivalents (FTEs), 0.8 part-time and casual employees and 6.3 students. Staff are organized into two (2) areas of responsibility, as follows:

1. ATIP Operations (25.2 FTEs, 0.8 part-time and casual and 4.3 students)
   • Processes ATIP requests;
   • Oversees the collection and release of personal and/or business information;
   • Provides expertise in ATIP policy;
   • Researches trends and best practices in ATIP;
   • Develops and delivers ATIP training programs; and
   • Proactively discloses and publishes briefing note titles, transition material, and committee binders.
2. Client Services (3 FTEs and 2 students)
   • Coordinates training and prepares promotional products;
   • Processes responses to parliamentary questions and petitions on behalf of PCO; and
   • Provides database administration.

While the exact distribution of tasks fluctuates, of the personnel complement of 28.2 FTEs in 2024-2025, 24.2 FTEs were dedicated to activities related to the administration of the Access to Information Act and one (1) FTE was dedicated to activities related to the administration of the Privacy Act. For a breakdown of the groups and positions responsible for meeting each applicable proactive publication requirement under Part 2 of the Access to Information Act, see subsection “Proactive disclosure” in the section “Other activities”, below.

Monitoring compliance

In order to meet the legislative deadlines for access to information requests, the timelines of individual requests are strictly monitored. Regular meetings and various reports are used to ensure all requests are on track to meet the deadlines. Given our delegation orders (described in the next section), the ATIP division works very closely with our Offices of Primary Interest (OPIs) to ensure tasking and signoff timelines are respected.

Privy Council Office delegation orders

The Minister heading each government institution is responsible for the implementation of the ATIA within his or her institution. The Prime Minister, as the Minister responsible for the Privy Council Office and pursuant to s. 95(1) of the ATIA, is responsible for the implementation of the ATIA within PCO. Through the PCO delegation order, the Prime Minister has designated the Executive Director, ATIP, as the individual within PCO to perform the powers, duties, functions, or administrative tasks pertaining to the ATIA. PCO Secretariats, or OPIs, holders of the information identified in an access request, approve the release of information to requesters and the application of exemptions or exclusions and supporting rationales. This shared delegation of authority for the disposition of information is exercised diligently within PCO and recorded formally at appropriate stages in the process. PCO delegation orders which were in effect in 2024-2025, can be found at Appendix A.

Activities and accomplishments

While the COVID-19 pandemic resulted in a backlog of access to information files that continues to affect PCO’s percentage of requests closed within legislated timelines, PCO is committed to addressing these challenges and responding to requests on time.

Due to the nature of the records held by PCO, requests received cover a wide variety of subject matters, such as historical intelligence, foreign affairs, and briefing materials to senior officials on issues of the day. As a result, many requests require complex interdepartmental consultations prior to completion. Of the completed requests in 2024-2025, two hundred and sixty-one (261) required consultations with PCO Legal Services Sector for the presence of Cabinet confidences, and one hundred and thirty-nine (139) required consultations for other reasons.

Summary of key issues and actions taken on complaints or audits

PCO collaborates regularly with the OIC with the intended purpose of resolving complaints in a timely manner. Throughout 2024-2025, the ATIP division continued to make progress on complaints by working with its Offices of Primary Interest to respond to requests for representations, while balancing workloads to allow consistent progress on active requests and compliance with legislated due dates. PCO is dedicated to reducing the number of active complaints.

Education and training activities

Within the ATIP division, meetings are held on a weekly basis to ensure requests meet the legislated due dates, as well as to review legislated extensions and discuss any new procedures. PCO provides information on ATIP requirements and best practices through learning products, special events at the branch and/or the departmental level, as well as on the intranet.

In 2024-2025, PCO provided ATIP training or awareness sessions to approximately forty (40) employees through five (5) training events during the reporting period. These sessions consisted of an overview of ATIP to internal secretariats to deliver insight on the ATIP process, related information management considerations, and the application of exemptions.

PCO senior officials were provided with a summary of the access and privacy statistics on performance and compliance to promote understanding of access and privacy responsibilities. The Executive Director of ATIP maintained regular contact with senior staff in the department, and ATIP senior staff met with senior officials in PCO secretariats to clarify their roles and enhance working relationships.

Throughout the 2024-2025 reporting period, ATIP analysts liaised with clients to explain the five-stage request timeline and their role, as well as to provide training on processes such as the search for records.

PCO personnel have access to key information on access and privacy. This information is readily available as instructional ATIP handouts, an email box for questions, takeaway learning tools, as well as comprehensive and educational electronic content on PCO’s intranet.

Information-related to policies, guidelines, procedures and initiatives

Posting of completed access to information requests

As part of the Open Government Initiative, PCO provides monthly summaries of completed access to information requests online. This information includes a summary of the request text, the year and month the request was completed, the disposition, and the number of pages disclosed. Summaries are available with direct links for requesting a copy of records.

The public can also submit informal requests for completed files by mail or the generic email on the PCO website. Records are provided in the form that they were released under the ATIA including format, language(s) and any exemptions or exclusions that were applied.

As reported in the Statistical Report, PCO re-released a total of one thousand nine hundred and fifty-four (1,954) previously released ATI packages informally between April 1, 2024, and March 31, 2025.

Improving access to information through technology

PCO took steps to replace its legacy case management software. Deployment of the new solution is anticipated for fiscal year 2026-2027. This will leverage new technologies to increase efficiencies in our processes, thereby improving service delivery.

Other activities

a) Reading room

In compliance with subsection 12(1) of the ATIA, the ATIP division provides a reading room where the public may examine requested departmental records, manuals, and publications related to access to information. The reading room is located on the first floor of the Hope Building at 63 Sparks Street, Ottawa, Ontario. This secure location allows for an appropriate separation from office activities and provides requesters with a suitable environment to review documents. ATIP analysts can reserve the space in advance to ensure that it is available to requesters. In 2024-2025, no individual made use of this means of access to information.

b) Proactive disclosure

In compliance with mandatory proactive disclosure requirements for government organizations, the PCO website continued to make available information concerning PCO travel and hospitality expenses, reclassification of positions, contracts over $10,000, grant and contribution awards, briefing note titles for the Prime Minister, Ministers, and the Clerk of the Privy Council, transition material for Ministers and the Prime Minister, as well as committee binders.

The following tables reflect the allocation of responsibilities for proactive disclosure within PCO, as well as the on-time compliance rates and locations of proactively disclosed information:

Apply to all Government Institutions as defined in section 3 of the Access to Information Act

Apply to government entities or Departments, agencies, and other bodies subject to the Act and listed in Schedules I, I.1, or II of the Financial Administration Act

Applies to government institutions that are departments named in Schedule I to the Financial Administration Act or portions of the core public administration named in Schedule IV to that Act (i.e. government institutions for which Treasury Board is the employer)

Apply to Ministers’ Offices (therefore apply to any institution that performs proactive publication on behalf of a Minister’s Office)

Interpretation of the Statistical Report

The 2024-2025 Statistical Report on the ATIA can be found at Appendix B.

Part 1 – Requests under the Access to Information Act (ATIA)

1.1 Number of requests

Between April 1, 2024, and March 31, 2025, PCO received seven hundred and forty-four (744) requests for information under the ATIA. The number of requests decreased from one thousand seventy-nine (1,079) received in the previous year, while the number of pages processed increased from the previous fiscal year. As seen in the graph below, ATIP processed 706,796 relevant pages, compared to 176,996 pages processed in 2023-2024 and 162,315 pages processed in 2022-2023. The increase from last year is due to one (1) request totalling 574,971 relevant pages processed. Without this request, 131,825 relevant pages were processed.

A total of seven hundred and ninety (790) requests were carried over to the 2025-2026 reporting period, while seven hundred and fifty-eight (758) requests were carried into 2024-2025 from the previous fiscal year. At the end of 2024-2025, the due date of 67.5% of the seven hundred and ninety (790) active requests had passed, meaning that 32.5% of them were carried over to the next reporting period within legislative timelines. The breakdown of when these requests were received and their status on the last day of the reporting period is as follows:

• Three hundred and fifty-five (355) received in 2024-2025 (64.2% on time, 35.8% late);
• Two hundred and seventy-five (275) received in 2023-2024 (2.9% on time, 97.1% late);
• Sixty-three (63) received in 2022-2023 (27% on time, 73% late);
• Thirty-two (32) received in 2021-2022 (3.1% on time, 96.9% late);
• Thirty-four (34) received in 2020-2021 (0% on time, 100% late);
• Twenty-six (26) received in 2019-2020 (0% on time, 100% late);
• One (1) received in 2018-2019 (0% on time, 100% late);
• Four (4) received in 2017-2018 (75% on time, 25% late); and
• Zero (0) received in 2016-2017 or earlier.

1.2 Sources of requests

The sources of access to information requests, in descending order by volume, were: decline to identify; media; public; academia; organization; and business. The breakdown of the requests received during 2024-2025 is as follows:

• Two hundred and fifty-nine (259) or 34.8% – decline to identify;
• Two hundred and thirty-eight (238) or 32% – media;
• One hundred and fifty-two (152) or 20.4% – public;
• Sixty-nine (69) or 9.3% – academia;
• Nineteen (19) or 2.6% – organization, including from Parliament (members of the House of Commons or Senate); and
• Seven (7) or 0.9% – business (private sector).

For this reporting period, the largest source of requests was from requesters who declined to identify at 34.8%, representing an increase of 3.1% from the previous reporting period. Media accounted for 32%, 3% more than in 2023-2024. Requests from the public decreased by 4% in 2024-2025 to 20.4%. The requests from academia increased by 3.4%, representing 9.3% of all requests. The business sector, which includes law firms, saw a decrease from 1.2% in 2023-2024 to 0.9% in 2024-2025.

1.3 Channels of requests

Of the seven hundred and forty-four (744) requests received in 2024-2025, the majority of requests were submitted through PCO’s electronic portal. PCO received seven hundred and twenty-five (725) online requests, accounting for 97.4% of the total number of requests. Requests received via email amounted to 2.3% of the total number of requests, while mailed requests corresponded to 0.3% of the requests for the reporting period.

Part 2 – Informal requests

Informal requests are not made or processed under the Act and have no deadline for responding. In alignment with Open Government requirements, PCO posts the summaries of completed access requests online on a monthly basis. These summaries allow requesters to access previously processed requests and are intended to eliminate barriers such as lengthy extensions, request fees, and allows for a timelier response.

2.1 Number of informal requests

Between April 1, 2024, and March 31, 2025, PCO received one thousand nine hundred and ninety (1,990) informal requests. The number of informal requests increased by 147.5% from the eight hundred and four (804) requests received in 2023-2024. In addition to the requests received, one (1) request was carried over from the previous reporting period, and zero (0) requests were carried over from more than one reporting period. In 2024-2025, PCO ATIP closed one thousand nine hundred and fifty-four (1,954) informal requests compared to eight hundred and four (804) informal requests closed in 2023-2024. Thirty-seven (37) requests have carried over into 2025-2026.

2.2 Channels of informal requests

Of the one thousand nine hundred and ninety (1,990) requests received in 2024-2025, the majority of informal requests submitted were through PCO’s electronic portal. PCO received one thousand nine hundred and eighty-three (1,983) online informal requests, accounting for 99.6% of the total number of requests. Emailed informal requests accounted for 0.4% of the total number of requests submitted for the reporting period.

2.3 Completion time of informal requests

Of the informal requests that were closed in the fiscal year, one thousand two hundred and forty (1,240) requests were completed in 1 to 15 days, representing 63.4% of all requests, while 16.7% of requests were completed between 16 to 30 days, compared to 5.7% of requests in the previous reporting period. Another 12.6% of the requests were completed between 31 to 60 days in 2024-2025, compared to 0.01% of requests in 2023-2024. Of the remaining closed requests, 7.1% were completed between 61 to 120 days, 0.05% between 121 to 180 days, and 0.05% between 181 to 365 days.

2.4 Pages released informally

Pages released informally is defined as the pages released, in response to informal requests, that were not previously released by the institution in response to a formal request pursuant to the ATIA. PCO did not release any pages informally between April 1, 2024, and March 31, 2025.

2.5 Pages re-released informally

In 2024-2025, the ATIP division completed one thousand nine hundred and fifty-four (1,954) informal requests and re-released 538,521 pages. The breakdown for the number of requests processed where pages were re-released is as follows:

• One thousand two hundred and six (1,206) (61.7%) contained less than 100 pages;
• Five hundred and nine (509) (26%) contained between 100-500 pages;
• One hundred and nine (109) (5.6%) contained between 501-1000 pages;
• One hundred and twenty (120) (6.1%) contained between 1001-5000 pages; and
• Ten (10) (0.5%) contained greater than 5000 pages.

Part 3 – Applications to the Information Commissioner on declining to act on requests

During the 2024-2025 reporting period, PCO ATIP did not make any applications to decline to act on an access request under the Access to Information Act, nor did PCO receive a response from the Information Commissioner for an application submitted during a previous reporting period. These applications are submitted when PCO determines that a request is vexatious, made in bad faith or an abuse of the right of access.

Part 4 – Requests closed during the reporting period

4.1 Disposition and completion time

In 2024-2025, the ATIP division completed seven hundred and twelve (712) requests. The breakdown of the disposition of requests is as follows:

• Five hundred and thirteen (513) (72.1%) were disclosed in part;
• One hundred and twenty-four (124) (17.4%) yielded no records;
• Thirty-five (35) (4.9%) were all disclosed;
• Twenty-four (24) (3.4%) were abandoned;
• Seven (7) (1%) were all excluded;
• Six (6) (0.8%) were all exempted;
• Two (2) (0.3%) were transferred;
• One (1) (0.1%) was neither confirmed nor denied; and
• Zero (0) (0%) were declined with the approval of the Information Commissioner.

As these figures demonstrate, five hundred and forty-eight (548) requests, or 77% of all requests, were fully or partially disclosed. The percentage of requests for which no records were disclosed (either exempted or excluded) increased slightly from 2023-2024 by 0.1% to 1.8% of requests completed in 2024-2025. Approximately 17.4% of requests in 2024-2025 did not produce responsive records, which is a small decrease from 18% in 2023-2024. Only two (2) requests were transferred from PCO to another institution in 2024-2025, down from nine (9) in 2023-2024. A smaller proportion of requests were abandoned by the requester in 2024-2025, 3.4% compared to 4.2% of requests in 2023-2024.

Factors such as external consultations with other government departments and third parties, as well as the complex, sensitive and multi-jurisdictional nature of PCO records, impact the time required to complete requests. As such, the breakdown of completion times for requests is as follows:

• One hundred and eighty-nine (189) (26.5%) requests were completed within 30 days;
• Fifty-six (56) (7.9%) requests were completed between 31 to 60 days;
• Ninety-two (92) (12.9%) requests were completed between 61 to 120 days;
• One hundred and nineteen (119) (16.7%) requests were completed between 121 to 180 days;
• One hundred and forty-eight (148) (20.8%) requests were completed between 181 to 365 days; and
• One hundred and eight (108) (15.2%) requests were completed in more than 365 days.

4.2 Exemptions

While PCO endeavours to release as much information as possible, there are instances where information is protected under the ATIA.

Totals for the seven (7) most commonly used exemptions were, in order:

• Three hundred and eighty-nine (389) under subsection 19(1) – personal information;
• Two-hundred and twenty-nine (229) under paragraph 21(1)(a) – information related to advice or recommendations developed by or for a government institution or a minister of the Crown; and
• One hundred and ninety-nine (199) under subsection 15(1) – information related to international affairs and defence of Canada;
• One hundred and seventy-three (173) under paragraph 21(1)(b)– consultations or deliberations related to operations of government;
• One hundred and forty-one (141) under subsection 16(2) – information related to the security of facilities, computer systems, and communications systems;
• One hundred and eighteen (118) under section 23 – solicitor-client privilege;
• Sixty-eight (68) under paragraph 13(1)(a) – information obtained in confidence from the government of a foreign state.

The use of these exemptions is consistent with the role of PCO and the content of the records it controls, which involves confidential consultations, deliberations and advice provided to the Government on issues of national and international scope.

4.3 Exclusions

The ATIA does not apply to certain information described by section 68 of the ATIA (published material) or to confidences of the King’s Privy Council pursuant to section 69. The application of exclusions under subsection 69(1) reflects the role of PCO in providing advice and information to the Prime Minister as well as to Cabinet and its decision-making structures.

Totals for the six (6) most commonly used exclusions were, in order:

• One hundred and sixty-six (166) under paragraph 69(1)(e) - briefings for Council;
• One hundred and twenty-nine (129) under paragraph 69(1)(g) re (a) – information relating to memoranda to Council;
• One hundred and twenty-one (121) under paragraph 69(1)(g) re (c) – information relating to the agenda or deliberations of Council;
• One hundred and seventeen (117) under paragraph 69(1)(g) re (e) – information relating to briefings for Council;
• Sixty-nine (69) under paragraph 69(1)(g) re (d) – information relating to communications between Ministers; and
• Fifty-seven (57) under paragraph 69(1)(a)– memoranda to Cabinet.

4.4 Format of information released

Of the requests for which records existed and were disclosed in whole or in part, five hundred and forty-eight (548) requests were released in electronic form. No requests were released on paper, down from thirty-five (35) in 2023-2024. While requesters have the option of receiving a paper response by mail or by picking it up in person, the majority of replies were sent to the requester by email in 2024-2025.

4.5 Complexity

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

A total of 706,796 relevant pages were processed in 2024-2025. For requests which were “all disclosed” or “disclosed in part”, 703,752 pages were disclosed. Without the one (1) request totalling 574,971 pages, a total of 131,825 relevant pages were processed. Of those, for requests which were “all disclosed” or “disclosed in part”, 128,781 pages were disclosed.

In compliance with changes made to the ATIA in 2019-2020, PCO now proactively discloses briefing note titles, transition material for the Prime Minister and Ministers, reference numbers of memoranda received by Ministers, Deputy Heads, and committee binders which are not captured in the relevant pages processed but require a significant amount of resources.

4.5.2 Relevant pages processed per request disposition for paper, e-record and dataset formats by size of requests

PCO completed five hundred and eighty-five (585) requests in 2024-2025 that contained responsive records. In addition, PCO refused to confirm or deny the existence of responsive records for one (1) request. This request is not included in the data below to facilitate understanding. The breakdown of the number of requests processed by disposition and by number of pages processed is as follows:

• Four hundred and fifteen (415) (70.9%) contained less than 100 pages:
  • Twenty-seven (27) (4.6%) were all disclosed;
  • Three hundred and fifty-six (356) (60.9%) were partially disclosed;
  • Five (5) (0.9%) were all exempted;
  • Four (4) (0.7%) were all excluded; and
  • Twenty-three (23) (3.9%) were abandoned.
• One hundred and thirty (130) (22.2%) contained between 100-500 pages:
  • Five (5) (0.9%) were all disclosed;
  • One hundred and twenty-one (121) (20.7%) were partially disclosed;
  • One (1) (0.2%) was all exempted;
  • Two (2) (0.3%) were all excluded; and
  • One (1) (0.2%) was abandoned.
• Eighteen (18) (3.1%) contained between 501-1000 pages:
  • Two (2) (0.3%) were all disclosed;
  • Sixteen (16) (2.7%) were partially disclosed; and
  • Zero (0) (0%) were all exempted, all excluded, or abandoned.
• Nineteen (19) (3.2%) contained between 1001 to 5000 pages:
  • Eighteen (18) (3.1%) were partially disclosed;
  • One (1) (0.2%) was all excluded; and
  • Zero (0) (0%) were all disclosed, all exempted, or abandoned.
• Three (3) (0.5%) contained over 5000 pages.
  • One (1) (0.2%) was all disclosed;
  • Two (2) (0.3%) were partially disclosed; and
  • Zero (0) (0%) were all exempted, all excluded, or abandoned.

Note that the number of pages processed is not an accurate gauge of the time required to process an access to information file. A request of many pages may involve basic records that require relatively little time to review, while small requests of a few pages could contain a complex combination of high-level content from several departments, requiring in-depth analysis and consultation.

4.5.3 Relevant minutes processed and disclosed for audio formats

PCO did not process any relevant minutes for audio formats.

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

PCO did not process any relevant minutes for audio formats.

4.5.5 Relevant minutes processed and disclosed for video formats

PCO did not process any relevant minutes for video formats.

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

PCO did not process any relevant minutes for video formats.

4.5.7 Other complexities

Other complexities that impacted PCO’s ability to respond to requests include consultations and seeking legal advice. As an aggregator of information, PCO receives information from numerous sources, including other government departments and third parties.

As a result, PCO needs to conduct consultations to obtain advice from subject matter experts in the originating institutions. Of the seven hundred and twelve (712) requests completed in 2024-2025, consultations were required for one hundred and thirty-nine (139) requests. Consultations often require extensions in order to complete requests within legislated timeframes. Of these requests, three (3) were disclosed in full, one hundred and thirty-five (135) were disclosed in part, and one (1) was all exempted.

Furthermore, a large volume of information under the control of PCO contains information subject to Cabinet confidences. Government institutions are required to consult legal services in all instances where information may qualify as a Cabinet confidence. PCO also consults legal services when records contain information that may be subject to solicitor-client privilege. There were twenty-five (25) requests requiring PCO to seek legal advice on the application of s. 23 (solicitor-client privilege). It is essential that PCO seek legal advice on the application of s. 23 in order to prevent any accidental disclosure of privileged information.

TBS requires that requests be counted only once. As a result, requests are divided into the categories that best apply to them. Several files required both consultations and seeking legal advice. Consequently, the total number of requests that fall in these categories may be greater than as presented.

4.6 Closed requests

4.6.1 Requests closed within legislated timelines

In this reporting period, four hundred and six (406) requests were closed within legislated timelines, representing 57% of all requests closed.

4.7 Deemed refusals

4.7.1 Reasons for not meeting legislated timelines

In 2024-2025, three hundred and six (306) access to information requests were completed past the deadline, or in “deemed refusal”: one hundred and seventy-eight (178) requests were completed past the deadline due to an interference with operations/workload; fifty-three (53) were not completed within the legislated timeline due to external consultations; sixty-two (62) were not completed within the legislated timeline due to internal consultations; and the remaining thirteen (13) requests were not completed within the legislated timeline for a variety of other reasons, including workload and operational challenges with processing classified documents.

4.7.2 Requests closed beyond legislated timelines (including any extensions taken)

In 2024-2025, eight (8) requests were closed past legislated timelines where no extension was taken, and two hundred and ninety-eight (298) requests were closed past legislated timelines where an extension was taken.

4.8 Requests for translation

Pursuant to subsection 12(2) of the ATIA, which states that “where access to a record or a part thereof is to be given under this Part and the person to whom access is to be given requests that access be given in a particular official language, a copy of the record or part thereof shall be given to the person in that language, (a) if the record or part thereof already exists under the control of a government institution in that language; or (b) within a reasonable period of time, if the head of the government institution that has the control of the record considers it to be in the public interest to cause a translation to be prepared”.

No translations were requested during the reporting period.

Part 5 – Extensions

5.1 Reasons for extensions and disposition of requests

Subsection 9(1) of the ATIA sets out circumstances under which the initial 30-day time limit for response may be extended. Extensions may be taken for the following reasons:

• if the request is for a large number of records or requires a search through a large number of records, and meeting the original time limit would unreasonably interfere with the operations of the institution;
• if consultations are necessary with other government institutions, other governments or informally with third parties, and it cannot be completed within 30 days; or,
• if notice is to be given to a third party (pursuant to subsection 27(1)) of the pending release of information or trade secrets of that third party.

In 2024-2025, PCO closed seven hundred and twelve (712) requests. While processing those requests, PCO took five hundred and ninety-five (595) extensions. There were one hundred and thirty-nine (139), or 23.4%, extensions under paragraph 9(1)(a) for interference with operations due to the volume of records, versus two hundred and fifteen (215) the previous year. Third-party notifications required thirty-four (34) extensions under paragraph 9(1)(c), two (2) more than the thirty-two (32) extensions for the same reason for the previous fiscal year.

Consultations were another significant driver of extensions during the reporting period. A total of two hundred and fifty-one (251) extensions for consultations on Confidences of the King’s Privy Council, and one hundred and seventy-one (171) extensions to consult other institutions (four hundred and twenty-two (422) extensions combined) were taken under paragraph 9(1)(b). Extensions for consultations increased from the three hundred and sixty-one (361) extensions taken in 2023-2024.

Consultations remain inherent to processing the often complex, interdepartmental records under the control of PCO. When PCO sends a consultation request to another federal institution, it first contacts the department to obtain an estimated response time. These efforts provide requesters with a more accurate estimate of when they will receive a response. Contacting the institution being consulted to mutually determine how long the consultation will take is considered a best practice by the OIC.

5.2 Length of extensions

For the requests closed during the 2024-2025 reporting period, PCO sought a total of five hundred and ninety-five (595) extensions. The breakdown of the number of extensions taken by length are follows:

• One hundred and thirty-one (131) (22%) were for 30 days or less;
• One hundred and twenty-two (122) (20.5%) were for 31 to 60 days;
• Two hundred and twenty-two (222) (37.3%) were for 61 to 120 days;
• Seventy (70) (11.8%) were for 121 to 180 days;
• Forty-six (46) (7.7%) were for 181 to 365 days;
• Four (4) (0.7%) were for 365 days or more.

Reporting requires that separate extensions are recorded under each column. These statistics can be considered representative of PCO's consultative requirements and the department’s heavy workload. PCO remains committed to the responsible use of extensions under the ATIA, consistent with operational demands.

Part 6 – Fees

In accordance with the Interim Directive on the Administration of the ATIA, issued on May 5, 2016, and the changes to the ATIA that came into force on June 21, 2019, PCO waives all fees prescribed by the Act and Regulations, other than the $5 application fee set out in paragraph 7(1)(a) of the Regulations.

The fees collected during the reporting period totaled at $3,590.00 on seven hundred and eighteen (718) requests, down from $5,215.00 in 2023-2024 and up from $3,240.00 in 2022-2023. In 2024-2025, PCO waived or refunded the fees associated with seventeen (17) requests with an amount totaling $85.00. The fees for the remaining nine (9) requests received by PCO were collected by other institutions due to request transfers, or were waived by PCO outside the reporting period. 

Part 7 – Consultations received from other institutions and organizations

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

PCO received three hundred and sixty-four (364) consultations during the reporting period, including three hundred and fifty-six (356) consultations from Government of Canada institutions and eight (8) consultations from other organizations.

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

Consultations continue to account for a significant portion of the workload and make demands on both ATIP resources and on the PCO records authorities who provide consultative guidance.

In 2024-2025, PCO received three hundred and sixty-four (364) consultations, and ninety-four (94) consultations were carried over from the previous fiscal year.

PCO responded to three hundred and fifty-one (351) consultations from other Government of Canada institutions. The breakdown is as follows:

• One hundred and sixty-seven (167) (47.6%) were completed within 30 days or less;
• Seventy-seven (77) (21.9%) were completed between 31 to 60 days;
• Seventy-four (74) (21.1%) were completed between 61 to 120 days;
• Fourteen (14) (4%) were completed between 121 to 180;
• Fourteen (14) (4%) completed between 181 to 365 days;
• Five (5) (1.4%) in greater than 365 days.

PCO received forty (40) requests from other Government of Canada institutions that were carried over within negotiated timelines, while fifty-nine (59) were carried over beyond the negotiated timeline, that is, after the due date.

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

A total of eight (8) consultation requests from third-party organizations were received by PCO during 2024-2025. Four (4) were completed in 30 days or less, two (2) were completed in 31 to 60 days, and one (1) was completed in 61 to 120 days. PCO received one (1) request from an organization outside the Government of Canada that was carried over within negotiated timelines.

Part 8 – Completion time of consultations on Cabinet confidences

8.1 Requests with legal services

Note that in regard to ATIP, PCO consults only with the Privy Council Office Legal Services Sector (PCO LSS). Therefore, no data appears in the table entitled “Completion Time of Consultations on Cabinet Confidences - Requests with Legal Services”.

8.2 Requests with Privy Council Office

ATIP consulted PCO LSS on two hundred and sixty-one (261) of the requests that were closed in the reporting period, up from two hundred and fourteen (214) in 2023-2024.

This figure represents consultations where the request was completed in the reporting period and excludes both active consultations and completed consultations in ongoing requests, which will be carried forward into the next reporting period.

Part 9 – Investigations and reports of finding

9.1 Investigations

In the 2024-2025 reporting period, two hundred and sixteen (216) complaints were submitted to the OIC. These complaints were made on requests received in the 2024-2025 fiscal year, as well as previous fiscal years. This is an increase from the two hundred and twelve (212) complaints that were received in the 2023-2024 reporting period. Of the complaints received in 2024-2025, 60% came from three (3) individuals.

In the 2024-2025 reporting period, complaints related to a range of issues, including the exemptions invoked or exclusions cited on records, and extensions taken to complete consultations and meet PCO operational requirements.

At the end of the 2024-2025 fiscal year, there were two hundred and twenty-three (223) active complaints with the OIC for access to information requests processed by PCO. The breakdown of when those complaints were received is as follows:

• One hundred and twenty-four (124) received in 2024-2025;
• Forty-four (44) received in 2023-2024;
• Twenty-four (24) received in 2022-2023;
• Eight (8) received in 2021-2022;
• Eleven (11) received in 2020-2021;
• Five (5) received in 2019-2020;
• Two (2) received in 2018-2019;
• One (1) received in 2017-2018;
• Two (2) received in 2016-2017; and
• Two (2) received in 2015-2016 or earlier.

9.2 Investigations and reports of finding

In the 2024-2025 reporting period, PCO received sixty (60) section 37(1) initial reports of finding from the OIC. Initial reports include the results of their investigation and set out recommendations or orders that the Commissioner intends to make. Receipt of an initial report requires PCO to give notice whether our institution will implement their forthcoming order or recommendation.

PCO also received one hundred and forty-eight (148) section 37(2) final reports that includes the results of their investigation and any orders or recommendations from the Information Commissioner. Last fiscal year, PCO received twelve (12) recommendations and forty-two (42) orders.

This marks an increase from the previous fiscal years, as illustrated below, requiring greater resources to be re-oriented towards the processing of the files with recommendations and orders, as they are time sensitive. Additional administrative products also need to be drafted to confirm if PCO will meet the due dates set by the Information Commissioner. Many complex, interlinked factors contribute to this increase, notably PCO’s backlog and the workload of subject-matter experts who provide guidance.

Part 10 – Court action

In 2024-2025, no court actions involving PCO were initiated by the OIC or were ongoing concerning the ATIA. Five (5) court actions were initiated by complainants.

Part 11 – Resources related to the Access to Information Act

11.1 Allocated costs

Salary costs associated with administration of the ATIA were $3,178,928 for 2024-2025, an increase from $3,056,708 in 2023-2024. Overtime costs totaled $38,297 for 2024-2025, which is a decrease from $70,619 in 2023-2024. Goods and services amounted to $58,095. This amount is up from $45,671 in 2023-2024. Total costs were $3,275,320, up from $3,172,998 in 2023-2024.

11.2 Human resources

It remains a challenge to attract and retain ATIP personnel, given the shortage of qualified analysts across the federal government. Currently, PCO uses various staffing methods to fill vacancies, including working with other departments to staff from pools of qualified candidates as well as running our own staffing processes.

PCO offers a supportive work environment and growth opportunities for staff in an effort to retain qualified ATIP personnel. Moreover, the Professional Developmental Program launched in 2017-2018 boosts the retention of employees by encouraging them to learn and grow within the team, progressing from the PM-01 level to the PM-04 level. Coupled with the successful hiring of students, the program will contribute to the recruitment and professional development of qualified analysts within the ATIP team for years to come.

Organizationally, the ATIP division is located within the Data and Information Services Directorate of the Corporate Services Branch. The co-location of ATIP with other information and data services fosters partnership, collaboration, and cohesive support to the department. It also enables a data first approach in ATIP to find efficiencies, make decisions on where to dedicate resources to create the biggest impact, and help collaborators better understand their current and upcoming workloads for better planning.

In 2024-2025, ATIP had a personnel complement of 28.2 FTEs. Of those, 24.2 FTEs were dedicated to activities related to the administration of the Access to Information Act.

Appendices

Appendix A: Delegation orders

Access to Information Act

The Prime Minister, as head of the Privy Council Office and pursuant to section 95(1) of the Access to Information Act^a, hereby designates the officers or employees holding the positions set out in the schedule hereto, and any persons acting in those positions, to exercise or perform the powers, duties and functions of the Prime Minister as the head of a government institution under the sections of the Act and the regulations opposite each position in the schedule.

This delegation order supercedes all previous delegation orders.

Prime Minister
Justin Trudeau

October 2, 2020

^a R.S. 1985, c. A-1

Schedule

Appendix B: 2024-2025 Statistical Report on the Access to Information Act

Name of institution: Privy Council Office

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

Section 1 - Requests under the Access to Information Act

1.1 Number of requests

1.2 Sources of requests

1.3 Channels of requests

Section 2 - Informal requests

2.1 Number of informal requests

2.2 Channels of informal requests

2.3 Completion time of informal requests

2.4 Pages released informally

2.5 Pages re-released informally

Section 3 - Applications to the Information Commissioner on declining to act on requests

Section 4 - Requests closed during the reporting period

4.1 Disposition and completion time

4.2 Exemptions

4.3 Exclusions

4.4 Format of information released

4.5 Complexity

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

4.5.2 Relevant pages processed per request disposition for paper, e-record and dataset formats by size of requests

4.5.3 Relevant minutes processed and disclosed for audio formats

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

4.5.5 Relevant minutes processed and disclosed for video formats

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

4.5.7 Other complexities

4.6 Closed requests

4.6.1 Number of requests closed within legislated timelines

4.7 Deemed refusals

4.7.1 Reasons for not meeting legislated deadline

4.7.2 Requests closed beyond legislated timelines (including any extension taken)

4.8 Requests for translation

Section 5 - Extensions

5.1 Reasons for extensions and disposition of requests

5.2 Length of extensions

Section 6 - Fees

Section 7 - Consultations received from other institutions and organizations

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

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

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

Section 8 - Completion time of consultations on Cabinet Confidences

8.1 Requests with Legal Services

8.2 Requests with Privy Council Office

Section 9 - Investigations and reports of findings

9.1 Investigations

9.2 Investigations and reports of findings

Section 10 - Court action

10.1 Court actions on complaints

10.2 Court actions on third party notifications under paragraph 28(1)(b)

Section 11 - Resources related to the Access to Information Act

11.1 Allocated costs

11.2 Human resources

Appendix C: Supplemental Statistical Report on the Access to Information Act and Privacy Act

Name of institution: Privy Council Office

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

Section 1: Requests carried over and active complaints under the Access to Information Act

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

1.2 Active complaints with the Information Commissioner of Canada, broken down by reporting period received

Section 2: Requests carried over and active complaints under the Privacy Act

2.1 Requests carried over to next reporting period, broken down by reporting period received

2.2 Active complaints with the Privacy Commissioner of Canada, broken down by reporting period received

Section 3: Social Insurance Number

Section 4: Universal access under the Privacy Act