Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 151 individual to determine whether the criteria or qualifications are met. Examples include verification of income for social assistance programs; verification of assets for programs requiring asset testing; and verifications of educational prerequisites for a post-secondary program.454 This collection of information can take place only while processing an application from the individual, or from their representative. It is good business practice to inform the individual about whom information is being collected. Government institutions should not take the further step of asking an individual to authorize indirect collection unless they are prepared to modify their procedures for determining eligibility if an individual refuses to authorize the indirect collection. Authorization from the individual is not necessary if the requirements for subsection 26(1)(e) of FOIP are fulfilled.455 Determining eligibility in the context of this provision means determining whether an individual is qualified, fit or entitled to participate in a program of or to receive a service from the Government of Saskatchewan or the government institution collecting the personal information indirectly.456 Determination of eligibility takes place at the point the government institution considers the initial application to participate in the program or receive the service. For this reason, subsection 26(1)(e)(i) of FOIP authorizes collection of personal information from other sources only in the course of processing an application made by the individual the information is about, or by a person authorized to act on his or her behalf.457 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.458 Keeping in mind the “openness” principle (see 10 Fair Information Principles above), if a government institution intends to rely on subsection 26(1)(e)(i) of FOIP in an application 454 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p. 245. See also SK OIPC Investigation Report F-2012-002 at [82]. 455 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p. 245. See also SK OIPC Investigation Report F-2012-002 at [82]. 456 Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-79. Available at Chapter (gov.mb.ca). Accessed December 12, 2022. 457 Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-79. Available at Chapter (gov.mb.ca). Accessed December 12, 2022. 458 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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