With respect @legalfalcon, I think the very point is that IRCC is not fully complying with the statute. The screenshot itself says that IRCC is in deemed refusal of requests for information (i.e., has not responded within 30 days).The 30 days processing time frame is the law.
As per section 7 of the Access to Information Act:
This time can be extended as per section 9, which states:
Whenever an extension is sought, OIC has to be informed.
In March 2020, IRCC has already initiated a systematic inquiry into IRCC handling of ATIP requests.
https://www.oic-ci.gc.ca/en/resources/news-releases/information-commissioner-initiates-systemic-investigation-department
In June July 2020, IRCC sought extensions, and these extensions were invalidated by IRCC, and even the COVID operational difficulties were not found to be an appropriate reason for delaying the release of requested information. In a recent final report this is what OIC stated:
32 days is not too long or unreasonable. Also, how you calculate matters. The 30 days are calculated in accordance with the Interpretation Act:
Do not calculate the day when the processing began, i.e. if you filed your application on November 20, the processing would commence on November 21 if it is a business day, or the following business day. This will depend on the time your request was filed. Further, do not calculate the day when the processing started.
If you have not yet received an extension notice, which has to be sent within 30 days, then your GCMS notes should be released soon.
In documents like this one (https://www.canada.ca/content/dam/oto-boc/migration/rprts/spcl/rprt-ctntp-eng.pdf), the Government notes that deemed refusal rates for some agencies (like the CRA) have tripled in recent years, due to surges in the number of ATIP requests.
The CRA defines the term thus:
Clearly, the statutory requirements have little bearing on operational fact inside IRCC.
But you are right that 32 days (33 now) is not terrible. I suspect I'll hear from them soon.
