The complainant alleged that Library and Archives Canada (LAC) had improperly withheld information under subsection 15(1) (national security) and subsection 19(1) (personal information) of the Access to Information Act in response to an access request for information relating to “Active Measures ‐ The Soviet Bloc Practice of Deception, Disruption and Defamation”.

The extent to which information pertaining to the subject matter of the request is already within the public domain undermines claims that disclosure of the redacted information could reasonably be expected to result in a harm described in subsection 15(1).

In light of the above, and in the absence of any justification from LAC, the Information Commissioner found that LAC failed to demonstrate that any of the withheld information meets the requirements of the exemption.

The Information Commissioner recommended that LAC disclose all remaining withheld information. LAC gave notice to the Commissioner that it would not implement her recommendation.

The complaint is well founded.