Variables and values in CIRNAC’s Annual Reports


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Access to information under the control of Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) and its predecessors – Indian and Northern Affairs Canada (INAC) and Aboriginal Affairs and Northern Development Canada (AANDC) – has long been considered problematic and has recently been identified as a concern by the Independent Special Interlocutor for Missing Children and Unmarked Graves and Burial Sites associated with Indian Residential Schools in her Progress Update Report (November 2022) and Interim Report (June 2023).

In response to a 2014 internal audit, AANDC planned to adopt several recommendations to streamline its processing of Access to Information and Privacy (ATIP) requests. We have asked CIRNAC for an update on the implementation and impact of this plan. On May 6, 2024, CIRNAC requested an extension of 90 days beyond the statutory thirty day time limit for processing my request due to the large volume of records involved and/or interference to government operations.

Meanwhile, in a series of posts, we aim to support the efforts of the Special Interlocutor and others to overcome barriers to access to information pertaining to the history and legacy of relations between First Nations and Canada.

Ultimately, we want to quantify the grounds for a common question about CIRNAC’s response to ATIP requests: “Why should I have to wait so long to receive so little information!?!”

We began by describing the context of the CIRNAC’s response to ATIP requests, including relevant legislation, policies and procedures, oversight, and reporting obligations. We also published an open dataset that consolidates all five Annual Reports (2018-19 to 2022-23) on its administration of the Act that CIRNAC has submitted so far to Parliament.

We now index all variables and values used in CIRNAC ‘s Annual Reports to describe its receipt and response to formal ATIP requests.1We disregard data related to informal requests for 2021-22 and 2022-23 (Tabs 2.1.1, 2.1.2, 2.2, 2.3, 2.4, and 2.5) We also define key terms used in these Annual Reports – drawing on the Treasury Board Secretariat’s Access to Information Manual.


List of variables and their associated values

Table 1 lists the variables, their associated values (if any), and the tab(s) within the dataset where they can be found.

Many variables in CIRNAC’s Annual Reports display counts against a list of associated values (e.g. counts for the variable “reporting period” are reported against associated values in the list  “more than one previous“, “previous“, “current“, and “next“). In several of these instances, CIRNAC always reports variable counts against the same set of associated values (e.g. counts for the variable “reporting year” are always reported against the set of associated values “2018-19“, “2019-20“, “2020-21“, “2021-22“, and “2022-23“). Sometimes CIRNAC reports pages processed as numbers of pages (“pages processed_01”) and sometimes as counts within different ranges of pages (“pages processed_02”). The remaining variables (e.g. “requests with legal services” and “pages released”) take no specific values and CIRNAC simply report counts.

Table 1 orders the variables into these groups:

  • time
    • reporting period
    • reporting year
    • legislated timelines
    • negotiated timelines
    • wait-time/latency
  • input
    • requests
    • request source
    • request channel
  • change of status
    • request abandoned
    • request transferred
  • extensions
    • extension required to close case
    • reason for extension
    • reason for not meeting legislated deadlines
  • complexities
    • consultations
    • requests with legal services
    • other complexities
    • recommendations from consultations/requests with legal services
  • pages processed
  •  output
    • no records exist
    • pages released
    • disposition
    • exemptions applied
    • exclusions applied
  • complaints
    • complaints to IC
    • reports from IC
  • investments
    • salaries
    • employees
Table 1. List of variables and associated values in CIRNAC’s Annual Reports (2018-19 to 2022-23).
Variable Values Tab
reporting period 1.1.1*, 1.1.2*, 7.1.1, 7.1.2
more than one previous 1.1.1*
previous 1.1.1*, 7.1.1
current 1.1.1*, 7.1.1, 7.1.2
next 1.1.2*, 7.1.2
reporting year set:
[all tabs]
legislated timelines 1.1.2*, 4.6.1**, 4.7.1, 4.7.2
within 1.1.2*, 4.6.1**
beyond 1.1.2*, 4.7.1, 4.7.2
negotiated timelines set:
wait-time/latency set:
1-15 days
16-30 days
31-60 days
61-120 days
121-180 days
181-365 days
> 365 days
2.3, 4.1, 4.7.2, 5.2, 7.2, 7.3, 8.1
received/outstanding 1.1.1*, 2.1.1, 2.4, 7.1.1
closed 1.1.2*, 2.1.2, 4.6.1**, 4.7.2, 7.1.2
carried over 1.1.2*, 2.1.2, 7.1.2
request source set:
decline to Identify
request channel set:
1.3*, 2.3
request abandoned 4.1, 4.4, 4.51***, 4.5.2, 4.5.7, 5.1
request transferred 4.1
extension required to close set:
closed with extension taken
closed with no extension taken
reason for extension set:
interference with operations / workload
9(1)(b) consultation – section 69
9(1)(b)_1 consultation – other
9(1)(c) third-party notice
reason for not meeting legislated deadlines set:
interference with operations / workload
external consultation
internal consultation
Government of Canada institutions 7.1.1, 7.1.2, 7.2
other organizations 7.1.1, 7.1.2, 7.3
requests with legal services 8.1
recommendations from consultation/legal request set:
disclose entirely
disclose in part
exempt entirely
exclude entirely
consult other institution
7.2, 7.3
other complexities set:
consultation required
assessment of fees
legal advice sought
pages processed_01 4.5.1***, 7.1.1, 7.1.2
pages processed_02 set:
< 100
100 to 500
501 to 1,000
1,001 to 5,000
> 5,000
2.4, 4.5.2, 8.1
no records exist 4.1, 5.1
pages released 2.4, 2.5, 4.5.1***, 8.1
disposition set:
all disclosed
disclosed in part
all exempted
all excluded
4.1, 4.5.1***, 4.5.2, 4.5.7, 5.1
exemptions applied set of 33 categories 4.2
exclusions applied set of 22 categories 4.3
complaints to IC set:
32 IC notice of intention to investigate
30(5) IC ceased to investigate
35 formal representations to IC required
reports from IC set:
37(1) initial reports containing recommendations issued by IC
37(1) initial reports containing orders issued by IC
37(2) final reports containing recommendations issued by IC
37(2) final reports containing orders issued by IC
salaries set:
professional services contracts
employees set:
full-time staff
part-time and casual staff
regional staff
consultants and agency personnel

* 2021-22 and 2022-23 only.

*** 2018-19 and 2019-20 only.

** 2020-21, 2021-22 and 2022-23 only.


Index of variables

Table 2 provides a Tab index for these variables and their associated values (both ordered alphabetically). For brevity’s sake, to designate instances where CIRNAC always reports a variable’s counts against the same set of associated values, we add curly brackets to the variable’s name.

Table 2. Index of variables and values in CIRNAC’s Annual Reports (2018-19 to 2022-23).
Variable Value Tabs
complaints to IC {} 9.1
consultations Government of Canada institutions 7.1.1, 7.1.2, 7.2
other organizations 7.1.1, 7.1.2, 7.3
disposition {} 4.1, 4.5.1***, 4.5.2, 4.5.7, 5.1, 5.2
employees {} 11.2
exclusions applied {} 4.3
exemptions applied {} 4.2
extension required {} 4.7.2, 7.2
legislated timelines beyond 1.1.2*, 4.7.1, 4.7.2, 7.2
within 1.1.2*, 4.6.1**
negotiated timelines {} 7.1.2
no records exist 4.1, 5.1
other complexities {} 4.5.7
pages processed_01 7.1.1, 7.1.2
pages processed_02 {} 4.5.2, 5.2, 8.1
pages released 4.5.1***, 5.1, 8.1
reason for extension {} 5.1
reason for not meeting legislated deadlines {} 4.7.1
recommendations from consultation/legal request {} 7.2, 7.3
reporting period current 1.1.1*, 1.2, 7.1.1, 7.1.2
more than one previous 1.1.1*
next 1.1.2*, 7.1.2
previous 1.1.1*, 7.1.1
reports from IC {} 9.2
request abandoned 4.1, 4.5.1***, 4.5.2, 4.5.7, 5.1, 5.2
request channel {} 1.3*
request source {} 1.2
request transferred 4.1
requests with legal services 8.1
requests carried over 1.1.2*, 7.1.2
closed 1.1.2*, 4.6.1**, 4.7.2, 7.1.2, 7.2
received/outstanding 1.1.1*, 7.1.1
salaries {} 11.1
wait-time/latency {} 4.1, 4.7.2, 5.2, 7.2, 7.3, 8.1

* 2021-22 and 2022-23 only.

** 2018-19 and 2019-20 only.



Statutory deadline and extension of time limit

The Act requires CIRNAC to respond to ATIP requests within 30 days of their receipt, including:

  • giving the requester written notice as to whether access to all or part of the record will be given; and
  • if access is to be given, giving the requester access to all or part of the record.2Treasury Board Secretariat Canada, Access to information manual, p. 100.

CIRNAC may extend this statutory deadline “for a reasonable period of time,” having regard to one of these circumstances:

  • the request is for a large number of records or requires a search through a large number of records and meeting within the statutory deadline would interfere unreasonably with CIRNAC’s operations;
  • consultation is necessary and cannot be completed within the initial 30-day period; or
  • notice is given to a third party.3Ibid., p. 102.

More than one extension may be taken, provided each extension is taken within the initial 30-day period. When an extension is taken, the statutory deadline is recalculated from the date of receipt of the request rather than from the original deadline.

Deemed refusal

When CIRNAC fails to respond to a request within the statutory time limit (30 days or length of time taken under an extension), the Department is deemed to have refused the requester access to the record. The requester may then file a complaint with the Information Commissioner about the refusal of access. In addition, the Information Commissioner may initiate a complaint and notify the head of the institution.4Ibid., p. 112.

Request transferred

CIRNAC may transfer an ATIP request to another government institution provided four conditions are met:

  • CIRNAC considers that another institution has a greater interest in the record;
  • the transfer is made within 15 days of receipt of the request;
  • the other government institution agrees to process the request within the remaining allowable time; and
  • the request has not already been transferred from another institution.5Ibid., pp. 96-97.

Request abandoned

CIRNAC may consider a request abandoned by the requester after little processing in a variety of situations.6Ibid., pp. 116-117. Two of these situations are addressed in model letters provided by the Treasury Board Secretariat to assist government institutions in corresponding with requesters:

“Model letter 2 – Acknowledgement of request – missing application fee

“… Please note that your request is temporarily on hold and will be considered abandoned if we do not receive your application fee by [date the response is due].”7pIbid., p. 365-367

“Model letter 3 – Acknowledgement of request – clarification required

“… Your request is on hold until we receive additional information from you. If we have not received your reply by [date the response is due], we will consider the request abandoned and close our file accordingly.”8Ibid., pp. 369-371

With these definitions in hand, let’s consider CIRNAC’s performance in processing ATIP requests.


The AANDC’s 2011-12 Annual Report adopted the government’s newly-enhanced “Statistical Report on the Administration of the Access to Information Act” and now classified ATIP requests by categories and sub-categories of “complexity”:

  1. Relevant pages processed and dislosed
  2. Relevant pages processed and dislosed by size of request
  3. Other complexities
    1. Consultation required
    2. Assessment of fees
    3. Legal advice sought
    4. Other

For a brief period, Annual Reports also classified ATIP requests as “complex” when they were deemed “sensitive” or “high-profile” – though, we have noted, this practice was soon discontinued.

As used here, the “complexity” of ATIP requests is a confusing grab-bag – and we prefer to use four separate terms that more clearly distinguish sensitivity, consultation, effort, and outcome.


We borrow a definition of “senstivity” from AANDC’s 2012-13 Annual Report:  requests were deemed to be of a sensitive nature when they sought records pertaining to high-profile issues in politics and the media, budget and spending information related to First Nations, and
allegations and complaints.

“Consultation” refers to consultations undertaken within a government institution, with other government institutions or other levels of government, or with other third parties when the records do not contain information that might qualify for exemption under the Act (3a above). CIRNAC may also seek legal advice in order to resolve issues related to the processing of an ATIP request (3c above).


Like other government institutions (our cursory survey suggests), CIRNAC includes three types of requests among Requests closed during current reporting period:

  • abandoned requests
  • transferred requests
  • sustained and properly directed requests

We prefer to distinguish these types of requests from one another, based on the effort that’s typically involved in processing them.

First, it’s acknowledged that little processing may be involved when a request is abandoned by the requester9Treasury Board Secretariat of Canada, Access to Information Manual, pp. 116-117.. We assume the same is true when a request is transferred to another government institution. In contrast, when a request is sustained by the requester and is properly directed to CIRNAC, substantial processing may be involved in retrieving, evaluating, and releasing records that respond to the request. We distinguish these “effortful requests” from the first two types.

Number of pages processed (1 and 2 above) is another – and more direct – measure of the effort required to process an ATIP request.

Number of pages released (1 and 2 above) is treated not only a measure of outcome, but also as a measure of effort, given that different work is involved in processing different sets of records for release (e.g. redacting, citing exemptions and exclusions, reproducing, etc.).


Number of pages disclosed (1 and 2 above) is also a direct measure of the outcome of processing an ATIP request. Disposition (all records disclosed vs some records disclosed vs all records exempted vs all records excluded vs no records exist) is another.



We have indexed all variables and values used in CIRNAC ‘s Annual Reports to describe its receipt and response to formal ATIP requests and have defined key terms used in these Annual Reports. We are now positioned to quantify the grounds of a common complaint regarding CIRNAC’s processing of ATIP requests: “Why did I have to wait so long to receive so little information!?!”



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