Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 154 In this situation, the individual is already participating in the program or receiving the product or service, and the government institution is checking to confirm that the individual was originally qualified, or continues to be qualified, to do so.463 Verification may be done on a regular basis, on a random basis or because of information received by the government institution.464 As with subsection 26(1)(e)(i) of FOIP, it is good practice to inform the individual about whom the information may be collected that verification of continuing eligibility may occur without notice. This is especially the case if the individual could incur any penalty for receiving a benefit for which they have become ineligible.465 Information from other sources may be required to verify eligibility for a number of reasons: the individual may not be able to provide the information, or all the information required; he or she may not be willing to provide the information or may provide inaccurate information; etc. In such circumstances, the individual will usually not be informed that verification of eligibility is taking place.466 IPC Findings In Investigation Report F-2012-002, the Commissioner investigated a complaint concerning the Saskatchewan Workers’ Compensation Board (WCB). The complaint concerned the disclosure of an individual’s personal information to a third party trucking company, specifically, that the individual had a claim with WCB. The Commissioner found that there was an unauthorized disclosure of the individual’s personal information by the WCB to the third party trucking company when it confirmed the individual had an active WCB claim. The Commissioner also found that during the conversation between WCB and the trucking company, WCB collected personal information about the individual indirectly without proper authority to do so under subsections 26(1)(e)(i) or (ii) of FOIP. Included in the Commissioner’s 463 Adapted from Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-80. Available at Chapter (gov.mb.ca). Accessed December 12, 2022. 464 Adapted from Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-80. Available at Chapter (gov.mb.ca). Accessed December 12, 2022. 465 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, pp. 245 to 246. See also SK OIPC Investigation Report F-2012-002 at [83]. 466 Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-80. Available at Chapter (gov.mb.ca). Accessed December 12, 2022.
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