Co-location means looking beyond one institution to find records

Complaint: The Department of National Defence (DND) said it had no records that responded to a request for information about the process to submit an application to the Spectrum Management Office.

Investigation: The OIC learned that this office was part of Innovation, Science and Economic Development Canada (ISED), but that DND had co-located employees there. DND access officials had made no effort to reach out to ISED when searching for records, despite that institution’s having been named in the request.

Outcome: A co-located DND employee found 54 responsive pages, which were released in their entirety.

Information Commissioner’s position

  • To qualify as thorough, a search must extend to all individuals and offices belonging to the institution that may have records responsive to a request.
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