Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 352 More recently, organizations have been considering the use of “synthetic data” to minimize the privacy impacts of big data but maximize the benefits. Synthetic data is a method of deidentifying data in a way that retains the same structure and level of granularity as the original data set.844 When embarking on big data initiatives, government institutions should make sure they are still meeting their privacy obligations under FOIP, including ensuring they have the authority to collect, use and/or disclose personal information under FOIP, as well as to ensure accuracy and completeness. In the age of big data, it is increasingly important to understand the connection between the upstream collections, uses and disclosures of personal information and the downstream discriminatory impacts thereof. Data analytics – or any other type of profiling or categorization – that results in inferences being made about individuals or groups, with a view to profiling them in ways that could lead to discrimination based on prohibited grounds contrary to humans rights law, would not be considered appropriate.845 This is consistent with the spirit of the International Resolution on Big Data adopted by Data Protection and Privacy Commissioners around the world at their annual Conference in Mauritius in 2014. At this conference, Commissioners committed to calling on all parties to demonstrate that decisions around the use of Big Data were fair, transparent, and accountable. Also, that results from profiling be responsible, fair, and ethical. Finally, that injustice for individuals due to fully automated false positive or false negative results be avoided.846 For more information on this topic, see: 844 Office of the Privacy Commissioner of Canada, Privacy Tech-Know blog: When what is old is new again – The reality of synthetic data. Available at Privacy Tech-Know blog: When what is old is new again – The reality of synthetic data - Office of the Privacy Commissioner of Canada. Accessed December 22, 2022. 845 Office of the Privacy Commissioner of Canada, Guidance on inappropriate data practices: Interpretation and application of subsection 5(3), 2. Profiling or categorization that leads to unfair, unethical, or discriminatory treatment contrary to human rights law. Available at Guidance on inappropriate data practices: Interpretation and application of subsection 5(3) - Office of the Privacy Commissioner of Canada. Accessed December 22, 2022. 846 Office of the Privacy Commissioner of Canada, Guidance on inappropriate data practices: Interpretation and application of subsection 5(3), 2. Profiling or categorization that leads to unfair, unethical, or discriminatory treatment contrary to human rights law. Available at Guidance on inappropriate data practices: Interpretation and application of subsection 5(3) - Office of the Privacy Commissioner of Canada. Accessed December 22, 2022.
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