Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 3, Access to Records. Updated 5 May 2023. 9 In some cases, one of these factors may be used alone to authenticate an individual. For others, combinations may be used. There are multiple ways to confirm the identity of the applicant. The degree of authentication should be appropriate to the sensitivity of the personal information involved. Social Insurance Numbers Government institutions should be careful not to collect information beyond that required to fulfill the purpose to comply with section 25 of FOIP and the data minimization principle. Identification purposes are not in themselves considered a legitimate basis for requiring an individual to provide a social insurance number. If a social insurance number is being requested for identification purposes only, the government institution must not in any way suggest that the social insurance number is required as a condition for providing records or services. Even where it is reasonable to ask an applicant for proof of identity, a request for a social insurance number must be presented and treated as optional. In verifying identity, a government institution may request the social insurance number as one option among others, but never as a requirement.14 Saskatchewan Health Services Number Again, government institutions should be careful not to collect information beyond what is required to fulfill the purpose to comply with section 25 of FOIP and the data minimization principle. Like social insurance numbers above, government institutions should not require an applicant to produce a health services number as a condition of receiving records. Section 11 of The Health Information Protection Act provides that an individual has a right to refuse to produce their health services number to any person, other than to a trustee who is providing a health service, as a condition of receiving a service unless the production is otherwise authorized by an Act or regulation.15 14 Office of the Privacy Commissioner of Canada, Fact Sheets - Best Practices for the use of Social Insurance Numbers in the private sector. Available at Best Practices for the use of Social Insurance Numbers in the private sector - Office of the Privacy Commissioner of Canada. Also cited in SK OIPC Investigation Report F-2012-001 at [33]. 15 See The Health Information Protection Act, SS 1999, c H-0.021 at section 11.
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