Message to federal institutions subject to the Access to Information Act regarding the use of digital collaboration tools and the retention of records

February 4, 2026

Strong information management policies and practices that uphold access to information rights must remain central as institutions contend with budget cuts, staff reductions, employee departures, and potential realignment or restructuring in the coming months.

I recognize that information management in the public service is the responsibility of the Treasury Board of Canada Secretariat (TBS). I also acknowledge the responsibility of Library and Archives Canada (LAC) to establish retention and disposition authorities that govern how federal institutions manage, preserve, and ultimately dispose of their records, including transitory records.

However, some aspects of records management by institutions subject to the Access to Information Act become relevant to my office the moment an access request is made. This relevance is heightened by the widespread use of digital collaboration tools such as Microsoft Teams. These tools are designed to modernize and streamline public service workflows, but often operate with limited default retention periods that, if not properly managed, can put access to information rights at risk.

Institutions must ensure that records created using these tools are managed in a manner that upholds the right of access to information.

To that end, I wish to remind you of the following:

• Institutions should only adopt digital tools that ensure they can still fulfill their responsibilities and obligations under the Act.
• Institutions must task program areas in a timely manner once access requests are received to prevent inadvertent deletion of relevant records, especially on platforms with automatic deletion processes.
• Program areas must in turn provide to their Access to Information and Privacy unit all records that are responsive to the access request, regardless of whether they are transitory or constitute information of business value.
• If information of business value held on Microsoft Teams or any other digital collaboration tool that has not been stored elsewhere under existing retention policies is destroyed, the institution may not be able to provide the information sought through an access request.
• While the TBS and LAC information management and retention policies provide a solid framework, their effective implementation is essential. Inadequate application of these policies—particularly regarding retention settings in digital collaboration tools—can compromise an institution’s ability to meet its obligations under the Act.
• Deleting information with the intent to deny a right of access is an offence under section 67.1 of the Act.

I am confident that by implementing policies with these considerations in mind, institutions can properly manage their information, while upholding the right of access to information and ensuring transparency and public accountability.

Caroline Maynard
Information Commissioner of Canada