There has been a growing trend in Canada for defense counsel to subpoena police records for the purpose of assisting in the defense of a criminal prosecution. Access has been limited where the requests relate to considerations that are irrelevant to the prosecution and where there is an impact on the privacy interests of police officers. It has generally been held that personnel, discipline, and complaint files are appropriately classified as administrative as opposed to operational records of a police service. An accused that seeks to obtain disclosure of administrative records must obtain them from the record holder that is a stranger to the criminal prosecution. As third-party records, these police documents are not subject to disclosure. In the decision of the Supreme Court of Canada in R v. O’Connor, a two-stage assessment process is needed when serving an application upon the police service. In the first stage, the defense must satisfy the judge that the information is likely relevant – this is the “likely relevance” consideration. The second stage states that, if likely relevance is established, the Court must engage in a balancing between the right of the accused to make a full answer and defense with the privacy rights of the persons whose information is the subject matter of the records. A request for production that appears to invoke questions of credibility at large will not be successful. Police management must ensure that defense counsel are required to adopt the O’Connor application process before the criminal courts prior to any third-party records being disclosed.