The Standards Council of Canada was ordered to finish processing records about the development of a national service-dog standard after a second search produced thousands of pages requiring review.
In Standards Council of Canada (Re), 2026 OIC 58, an August 20, 2026 final report, the Information Commissioner of Canada found that the council had not originally conducted a reasonable search. The commissioner nevertheless accepted that its later search used appropriate offices and search parameters. The remaining task was to compare and process the material, then answer the requester.
The distinction matters: the report does not establish that every page gathered in the second search was new, responsive or disclosable. Nor does it decide what a national service-dog standard should contain.
A broader search after missing correspondence was raised
The request sought all records concerning the development of the standard. The requester complained both about the search and about information withheld under several exemptions, but later stopped pursuing the exemption allegations.
The search complaint identified an apparent absence of correspondence involving service-dog organizations, a European standardization body and an individual expected to have participated in the discussions. The publicly issued report does not name that individual.
The council explained that it had tasked six offices, including its chief executive, legal counsel, standards-development branches, accreditation services and access-to-information staff. It described the holdings searched and keywords used, then asked those offices to search again in response to the concerns.
The detailed reasons record approximately 13,000 pages retrieved and another 2,000 expected. The report’s summary describes approximately 15,000 pages. Both accounts emphasize that the material had not been sorted and required manual comparison with the original collection before the council could determine whether new records had been found.
Reasonable effort, not a guarantee of perfection
The commissioner applied a practical search standard. Experienced employees familiar with the subject must make reasonable efforts to locate records connected to the request in places where they are likely to be stored. An institution need not prove with absolute certainty that no other record exists.
On the revised search, the commissioner found that the appropriate offices had been asked to search and that the parameters were suitable. That did not erase the inadequacy of the original search, so the complaint remained well founded.
The council said reviewing and comparing the records would take substantial time but did not provide a date for its supplementary response. The commissioner also noted the broader difficulty caused by duplicate records, multiple versions and emails kept across different platforms.
Processing and access remain separate steps
The order required the council to process all additional pages located, provide a supplementary response forthwith and give access to additional responsive records unless a specific provision of the Access to Information Act permitted refusal. Any refusal had to identify the applicable provision.
Separately, the commissioner recommended employee training and support on information-management responsibilities. Following the initial report of July 8, the chief executive said on August 6 that the council would implement the orders, but did not address the recommendation.
The final report provided a 35-business-day period to seek Federal Court review and said the orders would take effect on the 36th business day if no review application was made. It does not establish whether the supplementary response was subsequently delivered.
The result concerns the adequacy of the search and the obligation to finish responding. It does not resolve the abandoned exemption dispute or require unconditional public release of every document collected.
