FINAL_.pdf Inter-American Development Bank: Note on the Revised Proposal for the Access to Information Policy identified with the 2022 draft remain in the Revised Proposal, particularly in the area of exceptions and proactive disclosure. [...] We also note that the recommendation in our earlier Analysis to include references to the wider benefits of the right to information in these sections is not reflected in the Revised Proposal. [...] One of the recommendations from our earlier analysis which is not reflected in the Revised Proposal relates to the idea that the primary exceptions should be more aligned with the language of the Section 4.2 harm test. [...] 6 Inter-American Development Bank: Note on the Revised Proposal for the Access to Information Policy the time of any request to determine whether the disclosure of the information at that time would cause harm. [...] ▪ The policy should make further improvements to the rules on processing request by: o Amending the language in Section 7.1(b) to refer to reproduction costs instead of “service fees”, removing the reference to response costs in Section 11.1 or changing it to the costs of sending information, and harmonising the two sections.
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