Guide to FOIP Chapter-5

Office of the Information and Privacy Commissioner. Guide to FOIP, CHAPTER 5, Third Party Information. Updated 9 March 2023. 74 For more on what constitutes personal information, see Chapter 6: Protection of Privacy for a detailed breakdown of subsections 24(1)(a) through (k) of FOIP. 2. Does the personal information relate to the individual To relate to means connected in some way; having relationship to or with something else.178 Relating to should be given a plain but expansive meaning.179 The phrase should be read in its grammatical and ordinary sense. There is no need to incorporate complex requirements (such as “substantial connection”) for its application, which would be inconsistent with the plain unambiguous meaning of the words of the statute.180 “To whom the information relates” requires some connection between the individual and the personal information in the record.181 Generally, the information at issue would be the personal information of the individual for it to relate to them under Part IV of FOIP. 3. Would disclosure clearly benefit the individual Clear means free from doubt; sure; unambiguous.182 Benefit means a favourable or helpful factor or circumstance; advantage, profit.183 Government institutions should be careful not to disclose more personal information than is necessary for the purpose (i.e., abide by the data minimization principle, see Chapter 6: Protection of Privacy for more information). Where a government institution intends to rely on this provision to release personal information, notification is required to the individual to whom the information relates pursuant to the third party notification requirements outlined at subsection 34(1)(b) of FOIP. 178 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1541. 179 Gertner v. Lawyers’ Professional Indemnity Company, 2011 ONSC 6121 (CanLII) at [32]. 180 Ministry of Attorney General and Toronto Star, 2010 ONSC 991 (CanLII) at [45]. This case dealt specifically with an appeal regarding Ontario’s FOIP legislation. 181 Adapted from Ministry of Attorney General and Toronto Star, 2010 ONSC 991 (CanLII) at [43]. 182 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 317. 183 British Columbia Government Services, FOIPPA Policy Definitions at https://www2.gov.bc.ca/gov/content/governments/services-for-government/policiesprocedures/foippa-manual/policy-definitions. Accessed April 23, 2020.

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