Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 126 Purpose means the purpose for which personal information was obtained or compiled, the object to be attained or the thing intended to be done, e.g., the administration of a program, the provision of a service or other activity.374 The purpose of a collection means the reason(s) the personal information is needed and the use(s) that the government institution will make of the personal information.375 Relates to should be given a plain but expansive meaning.376 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.377 “Relating to” requires a purpose with some connection to an existing or proposed program or activity of the government institution.378 Existing means that the program or activity must be in place at the time the personal information is collected.379 Proposed means something offered for consideration or acceptance; a suggestion.380 To put forward an idea or plan for consideration.381 In this context, it means the personal information was collected for a purpose relating to a program that is at the stage of being proposed but not yet existing. Program means formally recognized activities or functions designed to deliver specific services that are related to a specific subject matter or topic. Programs do not refer to computer programs.382 374 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. 375 SK OIPC Investigation Report F-2012-001 at [62]. Originated from Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p 248. 376 Gertner v. Lawyers’ Professional Indemnity Company, 2011 ONSC 6121 (CanLII) at [32]. 377 Adapted from Ministry of Attorney General and Toronto Star, 2010 ONSC 991 (CanLII) at [45]. 378 Adapted from Ministry of Attorney General and Toronto Star, 2010 ONSC 991 (CanLII) at [43]. 379 Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-46. Available at https://www.gov.mb.ca/fippa/public_bodies/resource_manual/pdfs/chap_6.pdf. Accessed on June 29, 2020. 380 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1474. 381 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed., (Oxford University Press) at p. 1147. 382 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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