Order F22-39 – Information & Privacy Commissioner for BC
4
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responded in the aggregate to particular survey questions or survey
topic areas;12
verbatim written comments from survey participants in response to
open-ended invitations for comments;13
the Consultant’s views about the survey results and the areas BCI
should focus on for improvement;14
the Consultant’s background explanations about concepts relating to the
survey and aspects of the survey methodology, including survey
objectives, the level of participation, how to interpret certain charts, why
the Consultant measures certain things, and how certain scores are
calculated;15
benchmark information indicating the average survey results of other
employers, which the Consultant used to compare BCI’s results;16 and
miscellaneous, largely non-substantive, information such as the
Consultant’s company name, statements regarding disclosure of the
records, document cover pages, subject headings, formatting and page
numbers.17
[12] To be clear, as I discuss further below, except for the written comments,
the records do not contain each individual survey participant’s actual responses
to the survey questions. Rather, the records present the survey results in
aggregate and anonymized form and do not identify the individual survey
participants by name or job title. However, some of the survey participants’
written comments refer to individuals by job title.
[13] BCI is withholding all of the records in their entirety under common law
case-by-case privilege and all of the disputed information in its entirety under
s. 13(1) of FIPPA. It is also withholding various parts of the records under
12 Throughout the Records, but examples include pp. 19-40, 165-172, 247 and 292-303.
13 Records at pp. 88, 106-164, 209-212, 214, 216, 218-219, 221-222, 224-225, 227, 229-231,
233-234, 236-237 and 239-241. Also, some information on p. 281 would reveal the substance of
the written comments.
14 Records at pp. 18, 43, 103-105, 249, 253, 258-263, 272-277, 280-281 (mostly in purple
comment boxes).
15 Records at pp. 2-3, 8-9, 12-13, 17, 42, 44, 91-92, 244-245, 253-255, 266-267, 288-289, 291-
296, 334-339, 348-353, 362-364, 372-373, 375-377, 385-386, 388-390, 398-399, 401-403, 411-
412, 414-416, 424-425, 427-429, 437-438, 440-442, 450-451, 453-455, 463-464, 466-468, 476-
477, 479-481, 489-490, 492-494, 502-503, 505-510, 519-524, 533-538, 547-552, 585-590, 599-
604, 613-618, 627-632, 641-642 and 648-653 (many of these pages duplicate information).
I have highlighted the information in a copy of the Records that the OIPC will provide to BCI with
this order.
16 The benchmark information appears throughout the Records in many forms, but examples
(many of which are repeated in the same form on multiple pages) include pp. 4, 10, 12-13, 15, 90,
94-98, 100-102, 165-180, 191, 246-247, 249, 262-263, 268, 272, 292-303 and 305-308.
17 This information appears throughout the Records, but a representative example is most of the
information on the cover pages at pp. 1 and 5. I have highlighted the information in this category
in a copy of the Records that the OIPC will provide to BCI with this order.