Subsection 67(1) is a provision that was added to the act in 1999. It created a criminal infraction for concealing, destroying or hiding a document that's subject to the act with the purpose of denying the right of access. From a purely criminal law point of view, it requires evidence of the action, the concealment, and it also requires proof of intent of wanting to avoid or prevent the exercise of the right of access. There has been no case law in that provision. To my knowledge, no one has ever been charged with it. It's a bit difficult to assess exactly how that would play out in the courts, but it would certainly be subject to the whole criminal law rules with respect to obtaining a conviction that includes the proof of what we call in law the mens rea and the actus reus.
On June 5th, 2007. See this statement in context.