Routine Access Policy

Routine Access Statement

Halifax Regional Municipality (HRM) is committed to being open and accountable to the residents of HRM, providing the public with access to government information and to providing individuals with an opportunity to obtain certain types of records without having to make a request under Part XX, Freedom of Information and Protection of Privacy, Municipal Government Act [PDF].

Definitions

Routine access: the routine or automatic release, in full or in part, of certain types of administrative or operational records as a matter of course in response to a request without the need for an applicant to make a request for records under Part XX of the MGA.

Active dissemination: the periodic and proactive release of information or records in the absence of a request using the Internet, libraries or other mechanisms.

FOIPOP Access: the release of a record in response to a request under Part XX, Freedom of Information and Protection of Privacy, Municipal Government Act (MGA).

Record, as defined in Part XX of the Municipal Government Act, includes books, documents, maps, drawings, photographs, letters, vouchers, papers and any other thing on which information is recorded or stored by graphic, electronic, mechanical or other means, but does not include a computer program or any other mechanism that produces records.

Routine Disclosure Plan: a document, created by the Business Units, which will identify records that are available either by Routine Access or Active Dissemination.

Policy objectives

The objectives of this policy are:

To make routinely accessible those records which have been identified in the Routine Disclosure Plan.
To provide some certainty of access and ease of access for those requesting information.
To decrease the administrative time required by staff to disclose the records identified in the Routine Disclosure Plan.
To apply the policy in a manner that will protect an individual’s personal privacy.
To ensure records subject to this policy shall be considered for release and any required severing will be done in a manner consistent with the provisions of Part XX of the Municipal Government Act.

Policy directives

The Routine Access Policy applies to all HRM employees and to all records in the custody or control of HRM that are designated as a Routine Disclosure record or an Active Dissemination record.
The Routine Access Policy will be posted on the HRM website.
All HRM employees will be advised of the Routine Access Policy.
The Routine Access Policy will apply to information created after the effective date of the policy and after Routine Disclosure plans have been developed by the Business Unit.
Business units in HRM are required to develop a Routine Disclosure Plan that identifies the type of records within the custody and control of the Business Unit that may be accessed under Routine Disclosure or Active Dissemination. The Access and Privacy Office must review and approve the Routine Disclosure Plans before they can become effective.
Business units are required to keep a record of requests for Routine Access, including the records provided or the response given, in order to enable an audit of Business Unit compliance with the policy.
The application of the Routine Access Policy shall not unreasonably interfere with the day-to-day operations of HRM as determined in the sole discretion of the Director of the Business Unit.
This policy applies to requests for reasonable quantities of records and does not apply to a request for more than 50 pages of records.
This policy does not apply to the records listed under Section 463(2) of the MGA and to the exceptions to the right of access in the MGA and to any other records that the Access and Privacy Officer determines should be exempted.
Personal information will be severed using the same criteria and in the same manner as requests made under Part XX of the MGA.
A request for Routine Access to a particular record, or set of records, can be made in writing, in person or by phone to the Office of the Director of the Appropriate Business Unit.
If this policy applies to the requested records, the records shall be provided to the applicant within a reasonable period of time, but no later than 30 days from receipt of the request.
If the policy does not apply to the requested records, a response to the applicant shall be provided promptly and shall indicate to the applicant other means that may be available to the applicant to obtain the information (for example, by filing a FOIPOP application).
Individuals who apply under FOIPOP for records available under the Routine Access Policy will have their application fee returned and the records provided.

Accountability

Roles and responsibilities

Employees
All HRM employees are required to know and understand their obligations under this policy. Employees are expected to respect the confidentiality of personal information and report any breaches of privacy to their immediate supervisor. Employees will make reasonable efforts to ensure personal information is protected.

Supervisors and managers
Along with the responsibilities noted above, managers, and supervisors are required to ensure that their staff follow this policy and the applicable acts.

Business unit directors
Along with responsibilities noted above, directors are responsible for making reasonable security arrangements for personal information in the custody of their business unit, ensuring that staff receive privacy awareness training, and ensuring that service providers are compliant with this policy.

Access and Privacy Officer
Will provide advice and guidance to elected officials, executive and senior management, business units and employees with respect to the treatment of personal information within HRM and will monitor and report on HRM’s compliance with this policy.

Chief Administrative Officer
Along with the responsibilities noted above, the Chief Administrative Officer is responsible for the proper application of Part XX of the MGA, PIIDPA and other Acts or policies with respect to an individual’s personal information.

Compliance, monitoring, and review

The Access and Privacy Office will be responsible for monitoring compliance with this policy and conducting an annual review of this policy.
Questions with respect to HRM’s compliance with this policy may be directed to the applicable Business Unit or the HRM’s Access and Privacy Office at 902.943.2148 or access@halifax.ca.