The Canadian Human Rights Commission (CHRC) refused to disclose information citing subsection 19(1) – Personal information, section 22 – Testing/auditing procedures, and section 23 – Solicitor-client privilege of the Access to Information Act .

During the course of the Office of the Information Commissioner (OIC)’s investigation, the CHRC agreed to disclose all information previously withheld under section 22 of the Act and portions that were previously withheld under solicitor-client privilege. While the CHRC refused to disclose the remainder of the withheld information, it did not convince the OIC  that such information met all the requirements for severance under subsection 19(1) and section 23 of the Act.

The OIC therefore issued a report recommending that the CHRC disclose portions of the information previously withheld as personal information and portions of the information previously withheld under solicitor-client privilege. The CHRC agreed with the recommendations and released additional information.

The complaint is well-founded.