Guide to FOIP-Chapter 6

Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 110 Subsection 24.1(b)(i) of FOIP requires government institutions to establish written policies and procedures that protect against any reasonably anticipated threat or hazard to the security or integrity of personal information. Reasonably anticipated “Reasonable” means what a reasonable person would consider appropriate in the circumstances.325 This standard acknowledges that reasonable “does not mean perfect”.326 To “anticipate” means to be aware of (a future event) and take action; regard as probable; look forward to; to act or happen before.327 Threat means the possibility of trouble or danger.328 Hazard means a danger or risk.329 Security means a condition of safety or freedom from fear or danger. In the context of personal information, it refers to the physical, technological, or administrative arrangements that persons or organizations use to prevent individually identifying personal information from being altered, lost, or disclosed without authority.330 Integrity refers to the condition of information being whole or complete; not modified, deleted, or corrupted.331 Common threats are: 325 British Columbia’s Personal Information Protection Act, SBC 2003, c 63 at section 2 and subsection 4(1). See also section 2 of Alberta’s Personal Information Protection Act, SA 2003, c P-6.5 and the joint resource by the Service Alberta and Alberta IPC titled, A Guide for Businesses and Organizations on the Personal Information Protection Act at p. 9. 326 BC IPC Investigation Report F06-01 at [49]. 327 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed. at p. 57, (Oxford University Press). 328 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed. at p. 1492, (Oxford University Press). 329 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed. at p. 654, (Oxford University Press). 330 Adapted from Government of Alberta, Health Information Act, Guidelines and Practices Manual, March 2011 at p. 135. Available at https://open.alberta.ca/dataset/50877846-0fba-4dbb-a99feeb651533bc4/resource/3e16d527-2618-48ae-80b8-93f69973878e/download/hia-guidelinespractices-manual.pdf. Accessed June 18, 2020. 331 Government of Alberta, Health Information Act, Guidelines and Practices Manual, March 2011 at p. 137. Available at https://open.alberta.ca/dataset/50877846-0fba-4dbb-a99feeb651533bc4/resource/3e16d527-2618-48ae-80b8-93f69973878e/download/hia-guidelinespractices-manual.pdf. Accessed June 18, 2020.

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