ATIP & OPQ to PHAC:
Cases Following Vaccination Reporting Methodology Approval

Access to Information and Privacy (ATIP) Online Requests and Order Paper Questions (OPQs) are designed to place precise accountability questions—and their answers—on the public record. 

The following ATIP Request OPQ has been prepared / submitted to  investigate the reasons behind using the data skewing methodology used by PHAC in reporting its "Cases Following Vaccination" statistics.

For background, please see  the following pages : 

• Data Skewing by PHAC

• Fear of Reprisal in Public Service

• Political Interference - Historical Parallels

• Evidence of Foreign and Corporate Influence on Canadian Health Policy Undermining Canadian National Interests and Constitutional Rights 

• Resolution for the PIPSC National AGM: P-24 - Address High Fear of Reprisal Among Professionals Working on Policies Affecting All Canadians (E) 

Order Paper Question 

Status: proposed

With regard to the Public Health Agency of Canada’s “Cases Following Vaccination” reports published from August 2021 to September 2022,

a. What was the rationale for, and through what decision-making process did PHAC decide to calculate and compare numbers of COVID‑19 deaths by vaccination status using case counts beginning on the date of COVID‑19 vaccine approval in Canada (December 2020), rather than (i) from the dates on which each corresponding dose level actually began to be administered, or (ii) using weekly death counts, as is done for Statistics Canada’s Deaths by Age and Deaths by Cause statistics?

b. What internal documentation, analyses, and external scientific or technical references were consulted to inform and justify the methodological choice described in (a)?

c. Within PHAC, which organizational unit(s) and official(s) or governing authority(ies) (i) proposed the methodology described in (a), (ii) reviewed it (including any internal methodological or ethics review), and (iii) formally approved it for use in the “Cases Following Vaccination” reports?

d. In what way does the methodology described in (a) permit the observation and analysis of time‑based (for example, weekly or seasonal) variations in COVID‑19 deaths by vaccination status in relation to contemporaneous factors, including but not limited to seasonal changes and the dates on which additional vaccine doses (e.g. second, third, or booster doses) began to be administered?

e. In developing and approving this methodology, did PHAC rely on, or explicitly reference, any guidance, standards, or methodologies issued by the World Health Organization or any other international public health body; if so, which specific documents or authorities were relied upon?

ATIP to PHAC:  Who Developed Methodology for Reporting  Cases Following Vaccination and Why - Submitted

Status: Submitted. Our file: PHAC-A-2025-000101 / CMD

Below is the log of communications

DG: 16 Oct 2025 (ATIP submitted)

The ATIP request was submitted to PHAC to seek for more transparency related to how PHAC made decisions related to publishing its 'Cases Following Vaccination' data. The update on this action will be provided  on  here and in Action Tracker.

HC: 21 Oct 2025 ( Acknowledgement & Request to narrow the scope)

Subject: Re: Public Heath Agency of Canada Access to Information request A-2025-000101 

On Tue, Oct 21, 2025 at 9:48 AM XXXXXX (HC/SC) <cXXXXXXX@hc-sc.gc.ca> wrote:

Unclassified / Non classifié

Our file: PHAC-A-2025-000101 / CMD

Dmitry Gorodnichy

XXXXXXX

Dear Dmitry Gorodnichy:

This is to acknowledge receipt of your request made under the Access to Information Act (the Act) for the following information:

Timeframe: January 1, 2019 – January 31, 2023 All internal and external communications, briefing notes, meeting minutes, policy documents, reports, and correspondence (including emails, memos, and attachments) held by the Public Health Agency of Canada (PHAC) that relate to the methodology used for reporting COVID-19 cases, hospitalizations, and deaths by vaccination status — specifically within the context of the “Cases Following Vaccination” reports published between 2021 and 2023. This request includes, but is not limited to: 1. Communications and records discussing or approving the decision to report cumulative counts rather than weekly counts of cases, hospitalizations, or deaths. 2. Documents explaining or justifying the inclusion of cases, hospitalizations, or deaths that occurred prior to vaccine administration within “vaccinated” data categories. 3. Any references, directives, or recommendations from the World Health Organization (WHO), or from any other international or domestic advisory body, cited as rationale or “best practices” for the adopted reporting method. 4. Internal analyses, data quality reviews, or risk assessments discussing the impact of the chosen methodology on data interpretation or public communication.

Your request and application fee were received by our office on October 17, 2025, however, we are unable to proceed with your request as stated.  Given the broad scope of your request, we’d like to propose a few ways to narrow the search to make processing more efficient and focused on the most relevant material you are requesting.  Below is a breakdown of your current request with possible options to refine it;

1. - Timeframe:

January 1, 2019 – January 31, 2023

→ You could narrow to January 2021 – December 2022, when the “Cases Following Vaccination” reports were produced.

2. - Records Sought:

All internal and external communications, briefing notes, meeting minutes, policy documents, reports, and correspondence (including emails, memos, and attachments) held by PHAC that relate to the methodology used for reporting COVID-19 cases, hospitalizations, and deaths by vaccination status — specifically within the context of the “Cases Following Vaccination” reports published between 2021 and 2023.

→ You may wish to limit this to final versions only and DG level and above as this is where the decisions making level lies, perhaps also specific document types (e.g., briefing notes and internal analyses only, or emails containing key terms such as “methodology” or “cumulative counts”).

3.  Decision to report cumulative counts rather than weekly counts

→ Could limit to final briefing or approval records only (exclude draft correspondence) DG level or higher

4. - Inclusion of pre-vaccination cases within “vaccinated” categories

→ Could focus on internal analyses or explanatory material prepared for senior management.

5. - References or directives from WHO or other advisory bodies

→ Could limit to final referenced materials or WHO-related documents only.

6. - Internal analyses, data quality reviews, or risk assessments on the chosen methodology

→ Could narrow to finalized reviews or executive summaries (exclude drafts or duplicates).

Additional options to consider:

A - Focus on specific PHAC branches (e.g., Epidemiology and Surveillance Branch, Communications and Public Affairs).

B - Exclude publicly available reports or web content.

The processing of your request will start upon receipt of the required clarification. In the meantime, your request will be put on hold. Should we not hear from you by November 20, 2025, we will consider your request abandoned and the file will be closed.

Please contact the undersigned either by phone at 613-296-4299 or by email at    XXXXX@hc-sc.gc.ca, with reference to our file number cited above. In the event that our program officials require clarification of your request in order to properly identify the relevant records, you will be contacted by us.

The Public Health Agency of Canada is committed to assist you with your request and will ensure that every reasonable effort is made to help you receive a complete, accurate and timely response. More information about the Principles for Assisting Applicants is available at: https://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=18310#appC

Please be advised that you are entitled to complain to the Office of the Information Commissioner of Canada concerning the processing of your request within 60 days of the receipt of this notice. In the event you decide to avail yourself of this right, your notice of complaint can be made online at: https://www.oic-ci.gc.ca/en or by mail to:

Office of the Information Commissioner of Canada

30 Victoria Street

Gatineau, Quebec  K1A 1H3

We are happy to be able to offer you a new and fast way to receive answers to your inquiries at no additional cost to you. Canada Post’s Connect service is a secure messaging service that protects your documents, files and messages (see attached). As a result, your identity and all information sent to our office will be protected, and your privacy rights will be respected at all times under the Privacy Act.

Once you have created your Connect account, we ask that you inform our office by email at: atip-aiprp@phac-aspc.gc.ca

Yours sincerely,

_______________________________________________________________________

XXXXXXXXXX

Team Leader, Access to Information and Privacy Division

Corporate Policy & Planning Services Directorate

Corporate Services Branch

Health Canada and the Public Health Agency of Canada / Government of Canada

XXXXXXXXXX

DG: 23 OCT 2025

---------- Forwarded message ---------

From: Dmitry O. Gorodnichy 

Date: Thu, Oct 23, 2025 

Subject: Re: Public Heath Agency of Canada Access to Information request A-2025-000101

To: XXXXX

Hello XXXX,

Thank you for your email and your suggestions on how to narrow the search.

1. Please narrow the search to  January 2021 – December 2022.

2. Please narrow the search by excluding to the following branches:

   1. Chief Financial Officer and Corporate Management Branch

   2. Health Promotion and Chronic Disease Prevention Branch

   3. National Microbiology Laboratory Branch

3. Please exclude publicly available reports or web content, 

4. Please  exclude duplicates, however please do include all drafts

5. With respect to references or directives from WHO or other advisory bodies, you can limit your search to final referenced materials or WHO-related documents .

I hope this will allow to considerably  reduce the workload in searching for  the requested  information.

Critically: 

It is requested that all internal and external communications that mention, discuss, or compare "cases following vaccination" statistics—especially those used to compare the number of "covid cases deceased" among unvaccinated and vaccinated populations—be provided, including all drafts.

Please note that "covid cases deceased" may also be referred to as "Covid deaths," "Deaths with Covid," or "Deaths from Covid," where the term "Covid" may appear in uppercase and/or include the "-19" suffix (as in "COVID-19 deaths").

Please let me know if you have any other questions.

Thank you

Dmitry

HC: On Fri, Nov 14, 2025 at 1:48 PM (Clarifications, further narrowing of scope)

Unclassified / Non classifié

Good afternoon Dmitry Gorodnichy,

This is further to your request made under the Access to Information Act (the Act) for the following information:

All internal and external communications created between January 2021 and December 2022  (excluding records from the Chief Financial Officer and Corporate Management Branch, the Health Promotion and Chronic Disease Prevention Branch, and the National Microbiology Laboratory Branch) that mention, discuss, or compare “cases following vaccination” statistics-particularly those used to compare the number of “COVID cases deceased” among unvaccinated and vaccinated populations-be provided, including all drafts.

Please note that “COVID cases deceased” may also be referred to as “COVID deaths,” “Deaths with COVID,” or “Deaths from COVID,” where the term “COVID” may appear in uppercase and/or include the “-19” suffix (as in “COVID-19 deaths”). Please also exclude publicly available reports or web content and duplicate records, while still including all drafts of responsive materials. With respect to references or directives from the World Health Organization (WHO) or other advisory bodies, the search may be limited to final referenced materials or WHO-related documents only.

The office of primary interest (OPI) has advised that processing the request text as its currently written will significantly impact their regular operations as it will require all their resources and require a halt on surveillance operations. During the requested period, about 180 staff were producing reports and analyses on “cases following vaccination,” leading to 78 online reports, thousands of draft versions and supporting datasets. They advised that the request is too broad and would involve approximately 1.2 million pages of records.

To ensure that the request can be operationalized and in turn processed in a timely manner, we are seeking further information on the following points of contention for our OPI in your request text:

1. Could you please clarify the meaning of the word “communication”. The OPI has interpreted as “ any types of records where the purpose was to provide information from point A to point B”, which includes all the types of communications that were listed in your original request text (emails, letters, correspondence, memorandums, meeting minutes, PowerPoint presentations, reports, etc).

1. 1. To reduce the scope, would you agree to limit the search to one specific type of communication?

   2. Are you interested in information received from a specific source, Province or Territory?

2. Could the time frame of the request be modified to a shorter period?

3. As it relates to the main subject of your request, we understand that there is interest related to deaths.

3. 1. Are you exclusively interested in reporting of COVID deaths in people that received a COVID-19 vaccine and those that did not, and any statistical comparison that could have been produced using that data?

   2. Or alternatively, are you interested in deaths following COVID-19 immunizations? Those would be considered adverse events following vaccination.

Please note that your file is ON HOLD pending your reply.

Please be advised that you are entitled to complain to the Office of the Information Commissioner of Canada concerning the processing of your request within 60 days of the receipt of this notice. In the event you decide to avail yourself of this right, your notice of complaint can be made online at: https://www.oic-ci.gc.ca/en or by mail to:

Office of the Information Commissioner of Canada

30 Victoria Street

Gatineau, Quebec  K1A 1H3

Please do not hesitate to contact me if you require any more information.

 Sincerely,

(she | elle)

Junior ATIP Analyst

Access to Information and Privacy Services Directorate

Corporate Services Branch
Health Canada and the Public Health Agency of Canada

DG: 2025-11-17 10:58 PM

To:@hc-sc.gc.ca>
Subject: Re: Public Health Agency of Canada Access to Information Request PHAC-A-2025-000101

Warning: This message is from an EXTERNAL SENDER – be CAUTIOUS, particularly with links and attachments.
Attention : Ce message provient d'un EXPÉDITEUR EXTERNE – soyez PRUDENT, en particulier avec les liens et les pièces jointes.

Thank you for your email.

I'm sorry if my request appeared to take so much effort to provide the information I'm requesting. It was not meant to be that way.

My request is related to the “cases following vaccination” statistics that were published by PHAC in their
COVID-19 Daily Epidemiology Updates from  July 30, 2021 to September 30, 2022:
https://health-infobase.canada.ca/covid-19/archive/ (June 10, 2022 -September 23, 2022)
For data prior to June 10, 2022, see web.archive.org for https://health-infobase.canada.ca/covid-19/epidemiological-summary-covid-19-cases.html
(July 30, 2021 - May 31, 2022)

Please provide information related to who signed on and on who prepared  “cases following vaccination” statistics that have been published in those reports.
I request written communications in the chain of command leading to the publication of “cases following vaccination” statistics the way  it has been published in those reports. 

Please let me know if this is simple enough.
If not, I may find even easier ways for you to find the information I'm looking for  (e.g. just to find who approved the very first such report that included  “cases following vaccination” statistics published in July 30, 2021)

Thank you
Dmitry

HC On Tue., Nov. 18, 2025, 09:23 (Sent to OPI)

Unclassified / Non classifié

Good morning Dmitry Gorodnichy,

Thank you for providing the clarifications. I have sent the information you shared to the OPI for their feedback. The request will remain on hold until I receive their response, and we finalize an updated version of the request text.

Please do not hesitate to contact me if you require any more information.

 Sincerely,

....

(she | elle)

Junior ATIP Analyst

Access to Information and Privacy Services Directorate

Corporate Services Branch
Health Canada and the Public Health Agency of Canada

DG: Sent: 2025-11-18 

To: @hc-sc.gc.ca>
Subject: Re: Public Health Agency of Canada Access to Information Request PHAC-A-2025-000101

I appreciate that. Will look forward to hear from you. Thanks

Dmitry

HC: On Thu., Nov. 20, 2025, 13:41  (Further narrowing of scope)

Unclassified / Non classifié

Good afternoon Dmitry Gorodnichy,

The OPI has reviewed the information you provided and shared their feedback. They have suggested two possible revisions to the request text :

Option 1 : The request is related to the “cases following vaccination” statistics that were published by PHAC in their COVID-19 Daily Epidemiology Updates from  July 30, 2021 to September 30, 2022: https://health-infobase.canada.ca/covid-19/archive/ (June 10, 2022 -September 23, 2022). For data prior to June 10, 2022, see web.archive.org for https://health-infobase.canada.ca/covid-19/epidemiological-summary-covid-19-cases.html (July 30, 2021 - May 31, 2022).

 Please provide all communications related to the development and approval of the methods used to generate the “cases following vaccination” statistics that were included in the reports that were published online.

Option 2 : The request is related to the “cases following vaccination” statistics that were published by PHAC in their COVID-19 Daily Epidemiology Updates from  July 30, 2021 to September 30, 2022: https://health-infobase.canada.ca/covid-19/archive/ (June 10, 2022 -September 23, 2022). For data prior to June 10, 2022, see web.archive.org for https://health-infobase.canada.ca/covid-19/epidemiological-summary-covid-19-cases.html (July 30, 2021 - May 31, 2022).

Please provide all communications related to the production and approval of each routine report that included “cases following vaccination” statistics that were published online.

Please confirm whether you approve any of the proposed revised request text or make edits if you wish to suggest further changes.

Please note that your file is currently on hold pending your response. Once I receive the approved request text, we will proceed with processing your request.  

Please do not hesitate to contact me if you require any more information.

Kind regards,

(she | elle)

Junior ATIP Analyst

Access to Information and Privacy Services Directorate

Corporate Services Branch
Health Canada and the Public Health Agency of Canada

---------- Forwarded message ---------

From: Dmitry O. Gorodnichy <dmitry.gorodnichy@gmail.com>

DG: Date: Fri, Nov 21, 2025 

Subject: Re: Public Health Agency of Canada Access to Information Request PHAC-A-2025-000101

To: de Montigny-Saumure, Véronique (HC/SC) <Veronique.deMontigny-Saumure@hc-sc.gc.ca>

Option 1 is perfect. Thank you 

Look forward to receiving the requested information