Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 166 customers as it made no mention of the options to provide alternative information instead of unique identifiers and other sensitive personal information. The Commissioner recommended that SaskTel conduct a privacy impact assessment, revise its privacy policy and prepare a script to ensure that its customers understand what is optional when providing proof of identity. The Commissioner further recommended that SaskTel purge its systems of all personal information and personal health information of its customers and third parties that it collected without the requisite authority within 60 days. Subsection 26(3): Exception to Informing Manner of collection 26(3) Subsections (1) and (2) do not apply where compliance with them might result in the collection of inaccurate information or defeat the purpose or prejudice the use for which the information is collected. Subsection 26(3) of FOIP provides that subsections (1) and (2) do not apply where compliance with them might result in “the collection of inaccurate information or defeat the purpose or prejudice the use for which the information is collected.” This provision recognizes that in certain limited circumstances, collecting personal information directly from the individual, may result in inaccurate information being collected. For example, if a government institution is required to collect personal information directly (s. 26(1)) and notify the individual of the purpose for the collection (s. 26(2)) in advance, an individual may not be forthcoming, may provide partial information or may provide inaccurate information. Surveys seeking opinions and psychological testing are examples where this might be the case. To rely on this provision to collect indirectly and not provide notification to an individual, the threshold that must be met is “might result” in the collection of inaccurate information or defeat the purpose or prejudice the use for which the information is collected. FOIP does not define these terms. Based on dictionary meanings of these terms the IPC establishes the threshold as follows:
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