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. 165 • The title, business address and business telephone number of an officer or employee of the government institution who can answer the individual’s questions about the collection.489 Notification should be given at the time that the personal information is being collected.490 If notification is given orally, either in person or over the telephone, it is a good practice to refer the individual to a written copy of the notice or to provide a printed copy either at the counter or later by mail, and to retain a record that the notice was given.491 If a government institution is authorized to collect personal information indirectly pursuant to subsections 26(1)(a) through (h) of FOIP but chooses to collect from the individual the information is about, notification is still mandatory, even if it would not be required had the government institution collected the information indirectly.492 Government institutions should undertake a regular review of their collection instruments to determine which ones require the inclusion of collection notices. Collection notices should be included on all print and electronic forms used to collect personal information directly.493 IPC Findings In Investigation Report F-2012-001, the Commissioner considered the over collection of a customer’s personal information by Saskatchewan Telecommunications (SaskTel) as part of its identity verification process. The Commissioner found that SaskTel did not have authority to collect the Saskatchewan Health Services Number. Secondly, SaskTel did not provide a satisfactory explanation as to why it needed to collect other unique identifiers over the telephone since it could not verify the accuracy of same. Thirdly, the Commissioner found that SaskTel was collecting third party personal information without authority. Further, the Commissioner found that SaskTel was not meeting the notice requirements of subsection 26(2) of FOIP. It’s notification on its website was too vague to be particularly informative to 489 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p 248. See also Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at pp. 6-91 to 6-92. Available at Chapter (gov.mb.ca). Accessed December 13, 2022. 490 SK OIPC Investigation Report F-2012-001 at [62]. Originated from Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p 249. 491 SK OIPC Investigation Report F-2012-001 at [62]. Originated from Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p 249. 492 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p 249. 493 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p 250

RkJQdWJsaXNoZXIy MTgwMjYzOA==