Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 171 It is a good business practice for programs that use large personal information systems for delivery of programs or services to have systematic processes for updating personal information that is used on a regular or continuous basis.519 Other methods of maintaining accuracy include: • Periodically auditing files with accuracy and completeness being one of the criteria tested during the audit. • Implementing procedures to update personal information that is used on a regular or continuous basis. • Ensuring limited access to information for the purposes of making corrections or changes. • Establishing cross referencing and verification checks within software of automated systems that identify anomalies in data. Privacy requirements should be integrated into normal information and systems operations for the program.520 Before using personal information to make a decision that affects an individual, the following questions may be helpful in assessing its accuracy and completeness: • Was the personal information collected directly from the individual it is about. • Was the accuracy of the personal information verified at the time it was collected. • Is the proposed use of the personal information consistent with the purpose for which it was collected. • What is the likelihood that the personal information is outdated. How old is the information. Is it likely that circumstances have changed since the information was collected. • Are there systems in place to check the accuracy and completeness of the personal information – for example, periodic audits of files for accuracy, cross- referencing to other related files, systematic procedures for updating personal information, etc.?521 519 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p. 251. Also quoted in SK OIPC Review Report F-2006-003 at [52]. 520 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, pp. 251 to 252. Also quoted in SK OIPC Review Report F-2006-003 at [52]. See also Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-96. Available at Chapter (gov.mb.ca). Accessed December 13, 2022. 521 Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at pp. 6-96 to 6-97. Available at Chapter (gov.mb.ca). Accessed December 13, 2022.
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