Administration of the Access to Information Act Annual Report
April 1, 2024 to March 31, 2025

Introduction

The Access to Information Act (the Act) gives Canadian citizens the legislated right to access information in federal government records, subject to certain limitations and specific exemptions. The Act complements other methods for obtaining government information and does not limit in any way the access to federal government information that is normally available to the public upon request.

This report is prepared by the Canadian Institutes of Health Research (CIHR) in accordance with section 94 of the Access to Information Act and section 20 of the Service Fees Act and is tabled in Parliament by the Minister of Health in accordance with the aforementioned sections. It describes how CIHR fulfilled its responsibilities under the Act during the fiscal year, beginning April 1, 2024 and ending March 31, 2025.

CIHR was created in 2000 under the authority of the CIHR Actas the Government of Canada’s health research investment agency. The mandate of CIHR as per its enabling legislation is:

To excel, according to internationally accepted standards of scientific excellence, in the creation of new knowledge and its translation into improved health for Canadians, more effective health services and products and a strengthened Canadian health care system.

CIHR is the largest funder of health research in Canada. Composed of 13 “virtual” institutes and three business portfolios, CIHR provides leadership and support to over 15,000 world-class researchers and trainees from all pillars of health research and from all regions of Canada.

Organizational Structure

CIHR is led by a President and a Governing Council comprised of up to 18 members appointed by Order in Council. The Governing Council sets the overall strategic direction and goals and establishes health research institutes and the mandate of each. As outlined in the legislation, the Governing Council is responsible for developing CIHR’s strategic direction and goals; evaluating its performance, approving its budget; establishing a peer review process for research proposals submitted to CIHR; approving funding for research; approving other expenditures to carry out its objective; establishing policies; and dealing with any other matter that the Governing Council considers related to the affairs of CIHR.

The Access to Information and Privacy (ATIP) Office, part of CIHR’s Strategic Policy Division, administers the provisions of the Access to Information Act and the Privacy Act for the CIHR and is accountable to the President of CIHR. The ATIP Compliance Office is comprised of one ATIP Manager, one Senior ATIP Analyst and one Junior ATIP Officer. The ATIP Office is responsible for the following activities:

In accordance with the Access to Information Act, an area on the premises of this institution has been designated as a public reading room. This can be found at 234 Laurier Street, 18th floor, Ottawa, Ontario.

CIHR was not party to any service agreements under section 96 of the Access to Information Act during the 2024-2025 reporting period.

Delegation Of Authority

The President of CIHR, as designated Head of CIHR under the Access to Information Act, exercises powers entrusted to the position by the Act, such as exemptions and exclusions.

In accordance with his authority under Section 73, the President has designated the Executive Vice-President; the Associate Vice-President, Government and External Relations; the Director General, Strategic Policy; the ATIP Manager; the Senior ATIP Analyst; and the Junior ATIP Officer to exercise his powers, duties or functions under the Act (see Appendix A - Delegation Order).

Performance 2024-2025

During the April 1, 2024 to March 31, 2025 reporting period, CIHR saw an increase in the number of requests received, as well as the number of pages reviewed, when compared against previous reporting years.

a. Formal Requests

During the April 1, 2024 to March 31, 2025 reporting period, CIHR received 37 requests and had four requests carried over from previous reporting periods, for a total of 41 formal requests. CIHR engaged with 27 requesters. Out of these 41 requests, 35 were completed in the 2024-2025 fiscal year and six were carried over to the next fiscal year. One request was carried over from 2018-2019, which was not within legislated timelines (see Appendix B - Statistical Report). Of the 35 requests completed, 91.4% (32 requests) were closed within legislated timelines – up from 60% in the previous year. During the 2024-2025 reporting year, 19 requests were completed within the first 30 days of receipt, 11 requests were completed within 31-120 days, two were completed within 120-180 days, two were completed within 181-365 days, and one request required more than 365 days. One request (2.9%) was disclosed in full, 20 requests (57%) were disclosed in part, and two requests (5.7%) had all records exempted. Nine requests (25.7%) had no records found. Of the 16 requests that were not closed within the first 30 days, workload, and increased response times when consulting with other government institutions were contributing factors.

In 2023-2024, the CIHR made an application to the Office of the Information Commissioner in accordance with section 6 of the Access to Information Act seeking the Commissioner’s approval to decline to act on a request. The Commissioner issued her decision during the reporting period, granting the section 6.2 decline to act.

A total of 28894 pages were processed and 13682 pages were disclosed in 2024-2025. As illustrated in Table 1, the number of requests received in 2024-2025 was a 75% increase from the previous reporting year. The number of requests received is comparable to the number of requests received in 2020-2021 however, the number of pages processed was 8 times higher than in 2020-2021 and 2.8 times higher than in 2023-2024. This change can be attributed to a small number of high-volume requests, 6 of which account for 8253 pages (90.6%) of the total volume of pages processed. Formal requests processed during this reporting period tend to be primarily concerned with the administration of CIHR.

Table 1: Pages Received and Processed

2020-2021 2021-2022 2022-2023 2023-2024 2024-2025
Requests Processed 37 30 23 20 35
Pages Released 1502 1858 1441 2570 13682
Pages Processed 3641 10625 6880 10168 28868
Requests Carried Over 6 6 6 4 6

b. Informal Requests

During the 2024-2025 fiscal year, CIHR received 111 informal requests and three informal requests were carried over from previous reporting periods, for a total of 114 informal requests. All 114 informal requests were processed in the 2024-2025 reporting period.

All but one informal request received in the 2024–2025 reporting period were for copies of records previously processed under the Access to Information Act. The only other request processed informally was a follow up to another formal request completed during this reporting period. These informal requests were received via the Open Government Registry Portal, as well as proactively disclosed directly to a third-party organization to which CIHR provided copies of its completed requests. Of the 114 requests completed, 104 were completed in 1-15 days, one was completed in 16-30 days, three were completed in 31-60 days, four were completed in 61-120 days, and one was completed in more than 365 days. A total of 21,799 pages were released. This is a significant increase from 2023-2024, when 24 informal requests were received and 1,833 pages were released. The majority of informal request were submitted from the Investigative Journalism Foundation for their Open by Default Database.

c. Sources of Requests

Twelve requests were received from the public in 2023-2024, equating to 32% of the requests received. This represents a decline in the trend we had been seeing in requests made from the public, down from 68% in 2023-2024 and 52% in 2022-2023. Conversely, the proportion of requests from academia has increased to 41%, compared to 16% in 2023-2024 and 9% in 2022-2023. There has been a decline in requests from the media. The media accounted for 43% of requests in 2021-2022 and 35% in 2022-2023 however, during 2024-2025, only 19% of requests were received from the media. Three businesses (8%) submitted requests in 2024-2025 and there was no request received from organizations.

d. Consultation Requests

During the 2024-2025 reporting period, the CIHR ATIP Office received 21 consultation requests from federal departments. No consultations were received from organizations external to the federal government. One consultation request was carried over from 2023-2024. Four consultations were recommended for partial disclosure, 15 were recommended for full disclosure and one was referred to another institution for consultation. Of the 22 consultations, twenty were completed in 1-30 days and one in 16-30 days. One consultation was carried over to the next reporting period.

The volume and nature of these consultations tend to be similar to those of requests for information CIHR receives on an annual basis, focusing primarily on CIHR programs and initiatives. In 2024-2025, CIHR was consulted on 731 pages, which is a notable increase from 2023-2024 when a total of 371 pages were received for consultation. This represents an increase in the average number of pages per consultation from 18.9 pages to 34.8 pages.

e. Processing Requests

The CIHR makes every effort to process requests within the 30-day time limit as required by the legislation. However, some delays may be incurred when records contain third-party information, which triggers the requirement for consultations, or when a significant volume of records must be treated for a request.

In 2024-2025, 14 requests required an extension and, in some instances, extensions for interference with operations/workload and external consultations were both required. In total, nine extensions were due to interference with operations/workloads and seven extensions required external consultations. Extensions were required for 40% of all requests processed during this reporting year. This figure is consistent with previous years, in which extensions were required for 40% of requests in 2023-2024 and 39% of requests in 2022-2023.

During the 2024-2025 reporting year, nine complaints were received. Two complaints were closed, and the Office of the Information Commissioner ceased to investigate two complaints. CIHR continues to engage with the Office of the Information Commissioner on five open complaints, four from the reporting period and one from 2023-2024.

Training and Awareness

During the 2024-2025 fiscal year, CIHR delivered on the training plan it developed during the previous reporting period. Specifically, over 500 employees attended one of the five “ATIP 101” sessions held during this fiscal year. Additionally, CIHR identified several business units which would benefit from training sessions focusing on their specific activities. Of note, tailored training sessions were delivered to members of Information Management/Information Technology, Secretariat on the Responsible Conduct of Research, Research Programs, and three of CIHR’s Institutes. The delivery of training helped to increase staff’s awareness of, and commitment to, fulfilling its obligations under the Access to Information Act. Agency wide training will continue to be developed and delivered in the 2025-2026 fiscal year.

Policies, Guidelines, Procedures and Initiatives

While there were no significant revisions to current access to information policies, guidelines or procedures, CIHR dedicated time to reviewing efficiencies in the access to information process. The ATIP office provides internal advice, guidance and recommendations on a variety of access to information issues related to CIHR programs and initiatives.  ATIP staff continued to work with business units to develop text about access to information in many memorandums of understanding, especially in relation to joint-funding initiatives.

Initiatives and Projects to Improve Access to Information

Through internal training and engagement activities undertaken this fiscal year, CIHR was able to increase staff awareness of the importance of its obligations under the Access to Information Act. CIHR’s ATIP Office will continue to monitor the effectiveness of formal, routine and proactive disclosure methods to identify new ways in which it can uphold the informational rights of Canadians.

Summary of Key Issues and Actions Taken on Complaints

A small number of complaints were received during the 2024-2025 reporting period. Of note, two complaints relating to requests processed in 2019 were found to be unsubstantiated and another complaint was discontinued. CIHR also chose to voluntarily disclose additional records in an effort to resolve complaints. A disproportionate number of complaints were received from a small number of individuals this year. For the first time, CIHR was required to seek the Information Commissioner’s approval to decline to act on a request under subsection 6.1(1) of the Act. CIHR was successful in its application.

Proactive Publication Under Part 2 of the ATIA

CIHR is a government institution listed in Schedule II (section 2) of the Financial Administration Act for the purposes of Part 2 of the ATIA. As set out in sections 82 to 88 of the Access to Information Act, CIHR is subject to the following proactive publication requirements:

Apply to all Government Institutions as defined in section 3 of the Access to Information Act

Legislative Requirement Section of ATIA Publication Timeline Does requirement apply to your institution? (Yes/No) Internal group(s) or positions(s) responsible for fulfilling requirement % of proactive publication requirements published within legislated timelines Link to web page where published
Travel Expenses 82 Within 30 days after the end of the month of reimbursement Yes Finance Branch 100% Proactive disclosure | Open Government - Government of Canada
Hospitality Expenses 83 Within 30 days after the end of the month of reimbursement Yes Finance Branch 100% Proactive disclosure | Open Government - Government of Canada
Reports tabled in Parliament 84 Within 30 days after tabling Yes Strategic Policy Branch 100% Corporate plans and reports - CIHR

Apply to government entities or Departments, agencies, and other bodies subject to the Act and listed in Schedules I, I.1, or II of the Financial Administration Act

Legislative Requirement Section of ATIA Publication Timeline Does requirement apply to your institution? (Yes/No) Internal group(s) or positions(s) responsible for fulfilling requirement % of proactive publication requirements published within legislated timelines Link to web page where published
Contracts over $10,000 86 Q1-3: Within 30 days after the quarter
Q4: Within 60 days after the quarter
Yes Procurement Branch 100% Proactive disclosure | Open Government - Government of Canada
Grants & Contributions over $25,000 87 Within 30 days after the quarter Yes Finance Branch 100% Proactive disclosure | Open Government - Government of Canada
Packages of briefing materials prepared for new or incoming deputy heads or equivalent 88(a) Within 120 days after appointment Yes Strategic Policy Branch 100% Proactive disclosure | Open Government - Government of Canada
Titles and reference numbers of memoranda prepared for a deputy head or equivalent, that is received by their office 88(b) Within 30 days after the end of the month received Yes President’s Office 83% Proactive disclosure | Open Government - Government of Canada
Packages of briefing materials prepared for a deputy head or equivalent’s appearance before a committee of Parliament 88(c) Within 120 days after appearance Yes Strategic Policy Branch 100% Proactive disclosure | Open Government - Government of Canada

Applies to government institutions that are departments named in Schedule I to the Financial Administration Act or portions of the core public administration named in Schedule IV to that Act (i.e. government institutions for which Treasury Board is the employer)

Legislative Requirement Section of ATIA Publication Timeline Does requirement apply to your institution? (Yes/No) Internal group(s) or positions(s) responsible for fulfilling requirement % of proactive publication requirements published within legislated timelines Link to web page where published
Reclassification of positions 85 Within 30 days after the quarter Yes Human Resources Branch 100% Proactive disclosure | Open Government - Government of Canada

Apply to Ministers’ Offices (therefore apply to any institution that performs proactive publication on behalf of a Minister’s Office)

Legislative Requirement Section of ATIA Publication Timeline Does requirement apply to your institution? (Yes/No) Internal group(s) or positions(s) responsible for fulfilling requirement % of proactive publication requirements published within legislated timelines Link to web page where published
Packages of briefing materials prepared by a government institution for new or incoming ministers 74(a) Within 120 days after appointment Yes Strategic Policy Branch 100% Proactive disclosure | Open Government - Government of Canada
Titles and reference numbers of memoranda prepared by a government institution for the minister, that is received by their office 74(b) Within 30 days after the end of the month received No      
Package of question period notes prepared by a government institution for the minister and in use on the last sitting day of the House of Commons in June and December 74(c) Within 30 days after last sitting day of the House of Common in June and December No      
Packages of briefing materials prepared by a government institution for a minister’s appearance before a committee of Parliament 74(d) Within 120 days after appearance No      
Travel Expenses 75 Within 30 days after the end of the month of reimbursement No      
Hospitality Expenses 76 Within 30 days after the end of the month of reimbursement No      
Contracts over $10,000 77 Q1-3: Within 30 days after the quarter
Q4: Within 60 days after the quarter
No      
Ministers’ Offices Expenses
Note: This consolidated report is currently published by TBS on behalf of all institutions.
78 Within 120 days after the fiscal year No      

In 2024-2025, CIHR’s commitment was evident with 98% of CIHR’s proactive publication requirements due during the reporting period published within the legislated timelines. This is a notable increase from the 48% compliance reported in 2022-2023. CIHR’s proactive publications can be found on the Open Government portal.

Monitoring Process

The ATIP Office monitors the trends and time to process requests and administer the Privacy Act. This includes providing performance reports on the status of files in progress in the ATIP office on a regular basis. Issues of significant interest are discussed with the Director General of Strategic Policy and the Associate Vice-President of Government and External Relations, and briefing is provided to the President and Communications department on an as needed basis.

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