The IPC recently considered this issue in Order PO-3146-I. In response to an RFP, the third party provided to the Ontario Power Authority (OPA) an agreement between the third party and another party. The third party provided the OPA with the agreement as evidence of its ability to perform the terms of the RFP. The OPA was not a party to the agreement provided by the third party. The IPC held that the entire agreement was exempt under section 17(1) as it was supplied to the institution and harm would result from its disclosure. In deciding this, however, the IPC noted that it was significant that the RFP did not proceed.