Strata’s access fee cut to $225 after unnecessary printing charges removed

British Columbia’s privacy regulator has reduced a strata corporation’s $471 fee for access to a tenant’s personal information to $225, finding that printing the records was unnecessary when the tenant had asked to receive them electronically.

The $225 is the total fee, not an additional charge. It includes the $75 deposit the tenant had already paid, leaving $150 under the order.

In Order P26-19, 2026 BCIPC 110, issued October 6, 2026, adjudicator Alexander Corley removed $96 in per-page printing charges and $150 for two hours of the strata manager’s printing time. He otherwise accepted the evidence about the corporation’s costs and found no basis to reduce the fee further or excuse it entirely.

The ruling concerned Strata Corporation EPS 6040 and a request under B.C.’s Personal Information Protection Act, which permits an organization to charge a minimal fee for providing access to an individual’s own personal information. It did not establish a general right to free access or prohibit printing charges in every case.

Electronic delivery made printing unnecessary

The strata identified 384 pages of responsive documents and one video file. Its $471 estimate consisted of five hours of the manager’s time at $75 an hour, totalling $375, plus 25 cents for each printed page, totalling $96.

The strata said the manager had actually spent 6.5 hours on the request and ordinarily billed $175 an hour. It argued that sensitive material required the manager to retrieve, review, organize and print the records, and that the amount charged reflected substantial reductions from its actual costs. It also said it had not charged for severing information from the documents.

The tenant challenged whether the strata had considered a more economical response, questioned the time claimed and objected particularly to printing when electronic delivery had been requested. The tenant argued that the $75 already paid was a minimal fee in the circumstances.

Corley accepted the strata’s evidence about its actual costs. Although $75 an hour was relatively high, he found it consistent with rates accepted in other orders where an organization showed why a particular professional was needed. Having reviewed the documents, he found sensitive resident information made it reasonable to use the manager rather than an administrative employee to collect, organize and review them.

Printing was different. The tenant had expressly preferred an electronic transfer long before paying the deposit, and the strata had demonstrated it could provide the records electronically by doing so for the inquiry. Corley found no clear evidence or persuasive explanation for providing paper copies instead.

He therefore removed the $96 printing charge and $150 in printing labour. Subtracting those unnecessary costs from $471 produced the $225 fee ordered for the necessary work.

Minimal fees turn on necessary work

The decision applied principles developed in earlier privacy orders: a minimal fee should reflect actual, necessary costs, assessed objectively, and should aim for the lowest overall cost using an appropriately qualified person. It need not recover every cost an organization incurs and must not become a revenue source.

Permissible work can include locating and retrieving records, checking that the requested information has been found, preparing documents for disclosure and providing copies. The principles exclude work unrelated to the request, ordinary professional or legal compliance work, and severing information, which denies rather than provides access. In this case, the reduction turned on unnecessary printing, not a finding that the strata had invented its costs or that the manager’s accepted rate was excessive.

The initial $75 was a deposit

The tenant had initially been asked to pay $75 and told the information would be provided within seven days of payment. After receiving that amount, the strata reassessed the work and sought $471, less the sum already paid, before releasing the documents.

Corley found the strata had not properly estimated the work before requesting the deposit. He noted that permission to require a deposit comes with an obligation to give a written estimate of the total fee. He also acknowledged the tenant’s surprise and the strata’s admitted lack of proper communication.

Nevertheless, he accepted that the original $75 was intended as a deposit, not a settled fee that the strata later changed. That finding did not resolve whether the subsequent estimate was minimal; the printing costs still had to be removed.

The inquiry remained confined to the fee. Corley declined to add the tenant’s allegations about assistance and the adequacy of the records search because they were new issues, permission had not been shown to have been requested, and no exceptional circumstances justified adding them. The order did not decide the merits of the underlying bylaw dispute or establish that the records were subsequently delivered or the remaining fee paid.