Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 264 Customary means in accordance with customs; usual.718 Practice means the actual application or use of a plan or method, as opposed to the theories relating to the customary or expected procedure or way of doing something.719 Customary practices are well-known to the people who use them. This provision would not apply where the disclosure of names, addresses and telephone numbers is irregular or a departure from customary practices. Government institutions should still abide by the data minimization and need-to-know principles when disclosing personal information. Only disclose the least amount of personal information necessary to achieve the purpose. Further, only disclose to those that have a need-to-know the personal information to carry out the purpose. See Need-to-Know and Data Minimization earlier in this Chapter. IPC Findings At the time of issuance of this Chapter, the Commissioner has only briefly considered subsection 29(3) of FOIP in one Report. In Investigation Report F-2012-003, the Commissioner investigated a complaint involving Saskatchewan Workers’ Compensation Board (WCB). The complaint alleged WCB disclosed the complainant’s personal information to external third parties. The Commissioner considered whether there was authority under subsections 29(2), (3) or (4) of FOIP. The Commissioner quickly concluded at paragraph [29] of the Report that subsection 29(3) of FOIP clearly did not apply to WCB. 718 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed., (Oxford University Press) at p. 353. 719 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed., (Oxford University Press) at p. 1123.
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