Is a police disciplinary record that is not in the control of the police force required to be disclosed by the police officer to the police community?

I am not persuaded by the conclusion in Duff v. Alberta (Attorney General), supra, that this analogy is inapt because not all police disciplinary records require disclosure. This is simply because some disciplinary records are not reasonably relevant. There is a distinction to be drawn between whether specific information must be disclosed, and what regime should be used to govern disclosure. Just as records in the control of the investigating police force that are reasonably relevant to credibility warrant first party disclosure, so too do records in the control of the investigating police force that are reasonably relevant to the reliability of the machine.