Office of the Saskatchewan Information and Privacy Commissioner. Guide to FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 44 It does not include work product.124 General information, such as references to the type of employment entered into, certain actions taken, and relevant dates of those options are also not included.125 Employment history does not include: • Discreet pieces of information that might reveal information about a particular episode in a person’s employment (e.g., names of employees interviewed with respect to a complaint). Employment history does not include every action of an individual employee. The fact that a named public servant has performed or undertaken a specific task is not “employment history” in the requisite sense. • Employment history refers only to past employment and not to aspects of current employment such as an employee’s current salary or job position. • It does not include a person’s name, without more. • It does not generically refer to all employment-related incidents.126 The mere fact that an individual is granted an interview for a position does not constitute that person’s employment history.127 Financial transactions are not defined in FOIP. However, the definition can be broken down as follows: Financial means of or pertaining to revenue or money matters.128 Transaction means something performed or carried out; a business agreement or exchange; any activity involving two or more persons.129 Relating to should be given a plain but expansive meaning.130 The phrase should be read in its grammatical and ordinary sense. There is no need to incorporate complex requirements (such as “substantial connection”) for its application, which would be inconsistent with the 124 First cited in SK OIPC Review Report F-2006-001 at [113]. See What is not personal information section above in this Chapter for definition of “work product”. 125 AB IPC Order F2003-005 at [73]. See also ON IPC in Order M-615 at p. 4. 126 ON IPC Reconsideration Order R-980015 at pp. 16 and 17. Also cited in SK OIPC Review Report LA2013-001 at [95]. 127 ON IPC Order P-485 at p. 4. 128 The Shorter Oxford English Dictionary on Historical Principles, Oxford University Press 1973, Volume 1 at p. 964. 129 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1802. 130 Gertner v. Lawyers’ Professional Indemnity Company, 2011 ONSC 6121 (CanLII) at [32].
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