Office of the Saskatchewan Information and Privacy Commissioner. Best Practices for Managing the Use of Personal Email Accounts, Text Messaging and Other Instant Messaging Tools. Updated 27 July 2023. Remember that it is not enough to develop policies. A public body must ensure that they are implemented. This can be done by developing clear practice guidelines and by providing annual staff training. While it is not possible to account for every potential situation that may result in noncompliance, clear policies, training and awareness go a long way in encouraging staff to responsibly manage their records. Strong policies also help public bodies deal with issues as they arise. In some situations, a public body may be required to demonstrate that it has made its best efforts to appropriately manage its records. Policies, procedures and guidelines addressing the use of text messaging, other instant messaging tools and personal email accounts can help do this. Monitor and Review An implementation plan should address compliance over time and should include longterm monitoring and review. • Assign someone to answer questions or concerns about policies, procedures and practices. • Include spot-checks, surveys of staff practices or implement other review mechanisms in the public body’s plans to ensure that records are being appropriately saved • If staff are not complying with policies, take immediate action to preserve the records and prevent further loss of information. Conclusion Records relating to the public body’s business that are created, sent or received through any communication tool, including text messaging, other instant messaging tools or personal email accounts, are subject to the privacy and access provisions of FOIP or LA FOIP depending on which act applies. The use of these tools creates significant challenges for compliance with the acts and records management requirements. The IPC recommends that all public bodies take appropriate steps to ensure the retention and safeguarding of records sent through text messaging and other instant messaging tools to ensure compliance with FOIP or LA FOIP. If a public body chooses to use these communication tools, it must plan for compliance by implementing appropriate policy and technical mitigation strategies.
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