Notes to file

A note to file is a deliberately created record that is signed, dated and placed on an official file. It captures information that would otherwise go undocumented, such as a verbal exchange, an observation, a discrepancy or the reason a decision was made. Newfoundland and Labrador's Office of the Chief Information Officer describes it as an independent recording of an event, situation or observation.

In Canadian public procurement, notes to file are part of how contracting officers keep a complete and defensible file. The CanadaBuys Supply Manual says a procurement file should tell a story from beginning to end, and that notes to file are an important part of that story. Suppliers rarely write these notes, but their questions, proposals and conduct are often what the notes describe.

What a note to file records and how it is written

The Newfoundland and Labrador guidance explains that a note to file documents information that was observed or passed on verbally and is not recorded in an existing system, form or template. It stresses that the information may not be available anywhere else and may be central to the reasoning behind a decision. A note therefore records why something was done, not only what was done.

The same guidance sets out how a good note is prepared:

• It is written case by case and names the subject where one applies.
• It is signed and dated by the person who writes it, and legible if handwritten.
• It explains clearly and specifically the reason for the error, omission, discrepancy or process it addresses.
• It includes any corrective action or follow-up.
• It is retained and kept accessible within the business process it supports.

Read the full advisory at Government of Newfoundland and Labrador.

How procurement files use notes to file

The CanadaBuys annex on procurement files lists notes to file among the contents of a file. Examples include records of phone calls, summaries of events, actions taken and lessons learned. Notes provide file history, explain problems that came up and remind contracting officers of open items. The annex adds that consistent filing matters most when information is needed quickly for audits, Access to Information requests, Canadian International Trade Tribunal complaints or litigation, or when a new contracting officer takes over a file.

Notes to file also keep records findable. When information is held in more than one place, such as paper and electronic files, the annex requires a cross-reference. A note to file giving the reference and location of the other record is one example. The full guidance is in the CanadaBuys Supply Manual annexes.

Low-dollar justifications under delegated authority

Notes to file also document spending decisions made under delegated authority. The Impact Assessment Agency of Canada publishes notes to its delegation of spending and financial authorities chart. For low dollar value procurement and acquisition cards, the chart states that transactions must be justified by a note to file. That requirement is repeated across the agency's levels of authority, from the President to the Procurement Officer. See the agency's delegation chart notes.

Retention and use beyond procurement

Library and Archives Canada treats acquisition files as case files and recommends keeping all information of business value for a procurement in one repository. Its generic valuation tool lists an approved procurement plan, either a copy or a note to file with the procurement number, as a record to keep. The retention period is six fiscal years after the end of the fiscal year following the end of the asset's life or the termination of the contract. See the Library and Archives Canada acquisition services tool.

The practice extends beyond procurement. Immigration, Refugees and Citizenship Canada uses form CIT 0136B, Note to File - Citizenship Program, whose stated purpose is to archive comments made on file. At National Defence, the designated recipient team lead places a note to file called a Letter of Closure on each harassment and violence file before it is closed. The Ombudsman's report describes this step, and the IRCC forms page lists the citizenship form.

What notes to file mean for a supplier

Notes to file are internal records, so suppliers do not prepare or submit them. They still affect a bid or contract. A contracting officer may record a call, a clarification or a problem in a note, and that note becomes part of the file reviewed in an audit, an access request or a tribunal complaint. Suppliers should therefore put clarifications and commitments in writing through the official channel named in the solicitation, so the file holds the same record the supplier relies on. Low-dollar purchases made under delegated authority also carry a written justification on the buyer's side, which means even small awards leave a documented trail.