Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 323 3. Design with access and privacy in mind When government institutions implement or plan to implement new information systems or technologies, it is essential that these tools be capable of functions that support access and privacy obligations under FOIP. When a system is not capable of simple extraction, the costs associated with an access or correction request may ultimately come at the expense of the government institution. Likewise, the lack of extraction capability could prevent the appropriate destruction or archiving of records, leading to potential privacy and access issues. Consult with access and privacy staff, records management, legal and information technology staff before implementing a new system. The following may be taken into consideration when implementing a new system or technology: • Conduct a privacy impact assessment to determine whether the risks outweigh the benefits and if all access and privacy legislation is being met. See Privacy Impact Assessments (PIAs) earlier in this Chapter. • Determine if the system is compliant with your jurisdictional RIM requirements. • Determine goals and objectives of the system or technology. Determine what needs to be collected to reach the desired outcome. • Determine the structure and format of the data. For example, structured or unstructured fields. • Determine if training will need to be done. Will the vendor demonstrate to the staff, or will simple on-site training be done. • Following implementation, test the system. Are all access and privacy expectations being met. • Determine when updates and maintenance should be completed. For more on this best practice see SK OIPC resource, Improving Access and Privacy with Records and Information Management. IPC Findings In Investigation Report 262-2017, the Commissioner was prevented from conducting a full investigation and reviewing relevant records. The Ministry of Social Services (Social Services) advised the Commissioner that it believed the Ministry of Central Services (Central Services) was keeping Social Services’ official records on back up tapes, so it did not appropriately
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