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.