Page: 6 the underlying purpose of providing for access to government information. Fortunately, there is considerable information about that in government reports upon which the legislation was based, and there is considerable analysis of the issue in the case law. From these sources, it is clear that the legislative intent is inextricably linked to enhancing the democratic process. [25] Prior to the enactment of freedom of information legislation in Ontario, the government appointed a commission (“the Williams Commission”) to study the issue and it was upon the recommendations of that Commission that the first Ontario legislation was based.10 In its 1980 report, the Williams Commission identified four major rationales for public sector access to information legislation, as follows:11 (i) Accountability: Increased access to information “about the operations of government” would increase the ability of members of the public to hold their elected representatives accountable. Also, the accountability of the executive branch would be enhanced if members of the legislature were granted access to “information about government.” (ii) Public Participation: An informed citizenry is better able to participate in the formulation of public policy. When government policy-making has included the participation of a wide spectrum of citizens and pertinent and accurate information, public perception that the decisions have been fairly made will be enhanced. (iii) Fairness in Decision Making: Access to information about administrative decisions that may affect individuals gives those affected a fair opportunity to present their side on an informed basis and ensures fairness in decision making. (iv) Personal Privacy: A person’s right to access the information government is compiling on him may reduce the intrusiveness of some government record-keeping practices. [26] The fourth of these considerations is not relevant in this case. However, it is clear from the first three purposes listed that enhanced participation in the democratic process is a primary focus of freedom of information legislation. 10 The first legislation came into force in 1988 and applied to the provincial government. The current provincial scheme is under the Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31 (“FIPPA”). MFIPPA was modelled on FIPPA and has virtually identical language, including with respect to “custody or control.” The municipal scheme first came into force in 1991. 11 Ontario, Report of the Commission on Freedom of Information and Individual Privacy/ 1980, vol. 2 (Toronto: Ontario Government Book Store, 1980) at pp. 77-79