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. 170 The extent to which personal information is accurate, complete, and up to date will depend upon the use of the information, taking into account the interests of the individual. Information shall be sufficiently accurate, complete, and up to date to minimize the possibility that inappropriate information may be used to make a decision about the individual.514 Generally, if a government institution collects personal information directly from an individual, the risk is lower that the information is inaccurate or incomplete. The risk increases when a government institution collects personal information indirectly. The burden of meeting the “reasonably possible” requirement is greater when the consequences of a decision are greater for the individual.515 When updating personal information, always consider the reason or purpose it was collected. It is not necessary to routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.516 Personal information that is used on an ongoing basis, including information that is disclosed to third parties, should generally be accurate and up to date, unless limits to the requirement for accuracy are clearly set out.517 Government institutions should have adequate procedures in place to properly verify the accuracy and completeness of any personal information crucial to an application, transaction or action at the time the information is provided.518 514 SK OIPC Investigation Reports F-2009-001 at [91] and LA-2013-001 at [35]. Originated from Saskatchewan Justice (now Ministry of Justice) resource, An Overarching Personal Information Privacy Framework for Executive Government, 2003 at p. 17. 515 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p. 251. 516 SK OIPC Investigation Reports F-2009-001 at [91] and LA-2013-001 at [35]. Originated from Saskatchewan Justice (now Ministry of Justice) resource, An Overarching Personal Information Privacy Framework for Executive Government, 2003 at p. 17. 517 SK OIPC Investigation Reports F-2009-001 at [91] and LA-2013-001 at [35]. Originated from Saskatchewan Justice (now Ministry of Justice) resource, An Overarching Personal Information Privacy Framework for Executive Government, 2003 at p. 17. 518 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p. 251. Also quoted in SK OIPC Review Report F-2006-003 at [52].

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