The complainant alleged that the Canada Revenue Agency (CRA) improperly withheld information under paragraph 16(2)(c) (facilitating the commission of an offence) of the Access to Information Act in response to an access request. The request was for a telephone list for the CRA Headquarters International and Large Business Directorate indicating name, title, group, level, telephone number of each individual and reporting relationship. The allegation falls under paragraph 30(1)(a) of the Act.

The complainant also alleged that the CRA had not conducted a reasonable search for records in response to the same access request. The allegation falls under paragraph 30(1)(a) of the Act.

During the investigation, the complainant decided it was no longer necessary for the Office of the Information Commissioner (OIC) to investigate the reasonable search allegation.

The CRA failed to demonstrate that the requirements of paragraph 16(2)(c) were met because it did not establish that there is a reasonable expectation that harm would occur if the employee phone numbers were disclosed; that is, the representations received did not provide clear and convincing evidence on the likelihood of harm occurring.

The Information Commissioner issued an initial report setting out her intention to order the CRA to disclose the phone numbers withheld under paragraph 16(2)(c). The CRA gave notice to the Commissioner that it had released the phone numbers to the complainant on March 11, 2026. The complaint is well founded.