Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 228 information could be used to commit a criminal act or harm an individual or property, then it is likely contrary to the public interest to disclose the information.649 The government institution should be able to clearly identify how disclosure is not contrary to the public interest when relying on subsection 29(2)(k) of FOIP. 3. Is the “head” satisfied that the purpose cannot be reasonably accomplished with deidentified information? Information is in individually identifiable form if unique identifiers are attached to the information such that the information can identify a particular individual. The identifiers might be an individual’s name, address, telephone number, date of birth or social insurance number. Small population cells or contextual information may also allow for the identification of an individual.650 De-identification is the general term for the process of removing personal information from a record or data set.651 De-identified information is information that cannot be used to identify an individual, either directly or indirectly. Information is de-identified if it does not identify an individual, and it is not reasonably foreseeable in the circumstances that the information could be used, either alone or with other information, to identify an individual.652 Personal information is de-identified through a process involving the removal or modification of both direct identifiers and indirect or quasi-identifiers.653 As a best practice, de-identified information should be collected, used and/or disclosed if the purpose for the collection, use and/or disclosure can still be achieved using de-identified information. This isn’t always possible. However, government institutions should exercise discretion and consider whether it is possible in each circumstance. Whether something is reasonable is a subjective assessment which means fair, proper, just, moderate, suitable under the circumstances, rational, governed by reason, not immoderate or 649 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 4 at p. 121. 650 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7 at p. 296. 651 ON IPC resource, De-identification Guidelines for Structured Data, June 2016 at pp. 1 and 3. 652 ON IPC resource, De-identification Protocols: Essential for Protecting Privacy, June 25, 2014 at p. 3. 653 ON IPC resource, De-identification Protocols: Essential for Protecting Privacy, June 25, 2014 at p. 3.
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