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The BC Freedom of Information and Privacy Association requested that ICBC provide records related to the data sharing and privacy aspects of combining the BC driver’s licence with the BC Services Card. ICBC refused to disclose some of the information in the responsive records under s. 13 (policy advice or recommendations), s. 14 (legal advice) and s. 22 (disclosure harmful to personal privacy). The adjudicator found that, with a few exceptions, most of information was properly withheld under ss. 13 and 14. The adjudicator determined that disclosure of the withheld personal information would not be an unreasonable invasion of personal privacy, so ICBC was not authorized to withhold it under s. 22. ICBC also refused to disclose parts of the records on the basis that they were “not responsive” or outside the scope of the applicant’s request. The adjudicator held that ICBC is not authorized to refuse to disclose the information on that basis, and the only part of a responsive record that may be withheld is that which is covered by an exception under Part 2 of FIPPA.