The standard method of exchanging large collections of records in Canada is to provide TIFF images of the documents. Occasionally, some native digital files, such as Excel spreadsheets, are included in productions, but for the most part, TIFF is the way to go.
TIFF images are essentially photos of what the original digital file would look like when printed. They contain some of the information that is visible to the original user. However, the decision to produce TIFF images instead of native digital files results in some parts of the record not being produced. This could include redlining in a Word document or formulas in an Excel spreadsheet. It could also include details on when the record was actually created or last changed. In many cases, this “hidden” information doesn’t even get scrutinized beforehand – it is just ignored and discarded when the TIFF image is created.
When asked why the TIFF standard is still in use, the usual answer is “because that’s the way we’ve always done it”. In some cases, TIFF production is selected on purpose, as a strategic way of avoiding additional review or disclosure without any consideration or push-back from the opposing party. What this boils down to is that information that might be relevant is essentially being ignored.
Counsel should consider the nature of the information they will need at an early stage. The information available may be important in some cases, but not in others. For example, if Excel formulas are germane to a matter, the native Excel files should be produced rather than TIFFs of the spreadsheets.