PUBLIC RECORDS LAWS IN THE US, CANADA, UK & INDIA

UNITED STATES CANADA UNITED KINGDOM INDIA

Title of Act Freedom of Information Act Access to Information Act Freedom of Information Act Right to Information Act
Date Enacted 1966 1983 2000 2005
Qualified Any person Citizens and permanent residents of Any person Citizens of India, except those from
Requestors Canada Jammu and Kashmir
Response 20 business days 30 days 20 working days 30 days
Time
Records Records created by federal Records created or maintained by Records created by public Records produced by public
Covered government agencies/departments, government institutions. authorities, including central and authorities, including government
regulatory agencies, and publicly local governments, public agencies, bodies and agencies that are entirely
funded institutions. and companies wholly owned by or substantially funded by the
public authorities. government.
Associated All requestors are entitled to 2 hours All requestors are entitled to five All requestors are entitled to 600 Copy fees may apply.
Fees of search time and 100 copies. Fees hours of search and review time. pounds (central government
may apply for larger requests. Copy fees may apply. requests) or 450 pounds (requests to
other public authorities) of search
and review time. Copy and postage
fees may apply.
Grounds for National security, privacy, Confidential government/inter- Absolute exemptions: Security Foreign relations, internal interests,
Denial commercial interests, inter- or intra- government affairs, government service and court records, legal investigations, individual’s
agency correspondence, law operations, national security, law parliamentary privilege, personal safety, records sealed by the court,
enforcement proceedings, enforcement proceedings, legal information, court orders, or competitive information, fiduciary
regulation of financial institutions, investigations, recent/on-going common law. agreement, or unfinished cabinet
or placement of wells. audits of government entities, business.
economic interests, personal Qualified exemptions: National
information, individual’s safety, or security, international relations,
commercial interests. economic interests, court/public
authority investigations, policy
making, individual’s safety, legal
professional privilege, or
commercial interests.

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 UNITED STATES
Appeals Administrative appeals may be filed
Process with the agency that denied the
request. Agencies have 20 business
days to respond.
If the denial is upheld, the requestor
may file a lawsuit in US District
Court.
Government Chief FOIA Officer and FOIA Public
Personnel Liaisons at each agency.
Related Laws All 50 states have individual laws
for state and local records
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CANADA
Complaints must be submitted
within 60 days to the Information
Commission, which will carry out
an investigation.
If the denial is upheld, the requestor
may appeal the matter in court
within 45 days.
Information Commissioner and
Assistant Information
Commissioners at the federal level.
Privacy Act of 1983
UNITED KINGDOM
Requestors may ask the public
authority that denied the request to
internally review its decision.
If the denial is upheld, the requestor
must appeal for an investigation by
the Information Commission
within 2 months.
Information Commissioner at the
federal level.
Data Protection Act of 1998
Environmental Information
Regulation
INDIA
Requestors may appeal decisions
with the public authority that
denied the request within 30 days.
If the denial is upheld, the requestor
must ask the Central or State
Information Commission to
conduct an inquiry.
Chief Information Officers and
Public Information Officers at each
agency.
State Information Commissioners at
the state level and Central
Information Commissions at the
federal level.
Separate state laws in Jammu and
Kashmir