Reford should release corporate names from assessment rolls, commissioner says

Saskatchewan’s information and privacy commissioner has recommended that the Rural Municipality of Reford No. 379 release corporate names and an applicant’s own identifying details from assessment rolls, while continuing to protect other individuals’ information. The mixed outcome appears in Review Report 319-2025, issued October 20, 2026 by Commissioner Grace Hession David.

The report rejected the argument that a right to inspect assessment rolls makes unredacted copies generally available under access-to-information legislation. At the same time, it found that the municipality had applied the personal-information exemption too broadly to corporate names and information belonging to the person requesting access.

Property numbers had already been released

The applicant requested copies of the 2024 and 2025 assessment rolls in October 2025, later narrowing the request to specified areas within the municipality. The dispute concerned two five-page condensed assessment listings. Each contained 25 instances in which owner names and corresponding owner numbers had been withheld.

The municipality initially relied on section 28(1) of The Local Authority Freedom of Information and Protection of Privacy Act, known as LA FOIP. In June 2026 it supplied updated copies disclosing property numbers, but continued to withhold owner names and owner numbers. The applicant asked the commissioner to continue the review.

That distinction mattered. Property numbers identify land; the owner numbers at issue were unique identifiers assigned by the municipality to individual owners for assessment and taxation administration. The commissioner found that those owner numbers qualified as personal information under section 23(1)(d).

Corporate names and the applicant’s information were different

Section 28(1) restricts disclosure of personal information without consent, subject to the Act’s permitted disclosures. The commissioner first asked whether the withheld material was personal information about an identifiable individual. That protection applies to natural persons, rather than corporations.

Corporate names on these rolls did not meet that definition. The commissioner therefore recommended releasing them. But one corporate entry also included an individual contact’s name. That person’s name remained protected even though the corporate name alongside it should be disclosed.

The applicant’s own owner number and name had also been withheld once on each annual roll. The report relied on the applicant’s right to access their own personal information under section 30(1), and recommended releasing those details to the applicant.

For other individual owners, the commissioner accepted the privacy rationale. Their names were linked to property ownership, assessment values, taxable or exempt status and related particulars. The names had been collected for taxation purposes and qualified as personal information under sections 23(1)(i) and (k), rather than merely describing parcels of land.

Inspection did not create an unrestricted right to copies

The applicant argued that legislation required the owner information to be public, pointing to inspection rights and the availability of ownership information elsewhere. The commissioner explained that LA FOIP preserves existing access procedures and permits disclosures authorized by other legislation; those provisions must be read with the particular rights created by The Municipalities Act.

The report noted that assessment rolls are not on the list of documents available for inspection and copying under section 117 of The Municipalities Act. A separate provision, section 213, requires access for inspection during normal business hours from completion of the roll to the last day for lodging an appeal. Council may also authorize inspection of all or part of a roll at additional times.

That inspection process supports the ability to assess taxation equity and challenge an assessment. The commissioner distinguished it from an unrestricted entitlement to obtain copies for personal possession. The report also distinguished publicly accessible land-title ownership information from the tax-assessment details connected to an owner.

The final recommendation was to release the corporate names and the applicant’s own name and owner number within 30 days of the report, while continuing to withhold the remaining redacted information. It was a recommendation for selective disclosure to the applicant, not approval to release the assessment rolls without redactions.