Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 177 Consistent use is a use of personal information that has a reasonable and direct connection to the specific reason for which it was collected or created in the first place. This means that the original use and the proposed use are so closely related that an individual would expect that the information would also be used for the second purpose (consistent purpose), even if the use is not spelled out.531 Example: information in an employee’s annual Performance Evaluation Report is originally collected to evaluate performance – it is not collected specifically for later use in staffing actions in which the employee may be involved. Still, the use of the information in a staffing context is wholly compatible with the reason for the original collection of the information. A logical link is made between the two uses, because the information collected in an appraisal reflects the strengths and weaknesses of the employee which may indicate whether that person is a good fit for the position to which they have applied. Example of inconsistent or non-consistent use (improper): A community college collects personal information to survey community college students for their views on the college’s course content in an effort to modify courses to meet changing needs of the student population. The college may use the information it collects from the students only to compile statistics or a report on the students’ views. It may not subsequently use the information for a second, totally unrelated purpose (e.g., to lower the marks of those students who gave unfavourable comments on the course professors).532 Obtained means to acquire in any way; to get possession of; to procure; or to get a hold of by effort.533 Compiled means that the information was drawn from several sources or extracted, extrapolated, calculated or in some other way manipulated.534 For example, a government institution creates or assigns an ID number for each client. This information becomes the 531 Office of the Privacy Commissioner of Canada, Access to Information and Privacy Process and Compliance Manual for the OPC, available at Access to Information and Privacy Process and Compliance Manual for the OPC - Office of the Privacy Commissioner of Canada. Accessed December 14, 2022. 532 British Columbia Government Services, FOIPPA Policy Definitions, available at Section 32 - Use of Personal Information - Province of British Columbia (gov.bc.ca). Accessed December 14, 2022. 533 Originated from Campbell Black, Henry, 1990. Black’s Law Dictionary, 6th Edition. St. Paul, Minn.: West Group. Adopted by AB IPC in Order 2000-021 at [26]. Adopted in SK OIPC Review Report F-2006001 at [58] and [59]. Also, found in SK OIPC Review Report F-2006-002 at [39]. 534 British Columbia Government Services, FOIPPA Policy Definitions at https://www2.gov.bc.ca/gov/content/governments/services-for-government/policiesprocedures/foippa-manual/policy-definitions. Accessed April 23, 2020.
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