Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 123 Service Alberta, Guide for Developing Personal Information Sharing Agreements. IPC Findings In Investigation Report 072-2018, the Commissioner considered section 24.2 of FOIP for the first time. The Commissioner investigated the Ministry of Central Services’ (Central Services) use of backup tape technology and the potential issues posed by this technology. The Commissioner found that Central Services had an agreement in place with Information Management Services (ISM) but had not been reviewed since the new requirements were added to FOIP on January 1, 2018. Further, the Commissioner found that there was no agreement in place between ISM and a subcontractor. The Commissioner recommended that Central Services review the existing contract with ISM to ensure it complies with section 24.2 of FOIP. Additionally, the Commissioner recommended that Central Services require ISM and the subcontractor to have a written agreement in place that was compliant with section 24.2 of FOIP. Subsection 24.2(3) Information management service provider 24.2(3) An information management service provider shall not obtain access to, use, disclose, process, store, archive, modify or destroy personal information received from a government institution except for the purposes set out in subsection (1). Subsection 24.2(3) of FOIP provides that an information management service provider shall not access, use, disclose, process, store, archive, modify or destroy personal information received from a government institution except for the purposes outlined at subsection 24.2(1) of FOIP. The purposes set out in subsection 24.2(1) of FOIP include: • Processing, storing, archiving, or destroying personal information • Information management or information technology services • Combining records (e.g., merging or deleting duplicate records)
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