Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter3, Access to Records. Updated 5 May 2023. 10 authority may request the social insurance number as one option among others, but never as a requirement.14 Saskatchewan Health Services Number Again, local authorities should be careful not to collect information beyond what is required to fulfill the purpose to comply with section 24 of LA FOIP and the data minimization principle. Like social insurance numbers above, local authorities should not require an applicant to produce a health services number as a condition of receiving records. Section 11 of The Health Information Protection Act provides that an individual has a right to refuse to produce their health services number to any person, other than to a trustee who is providing a health service, as a condition of receiving a service unless the production is otherwise authorized by an Act or regulation.15 For more on verifying identity, see the Ministry of Justice and Attorney General resource, Verifying the Identity of an Applicant. See also Subsection 49(e) later in this Chapter. IPC Findings In Investigation Report F-2012-001, the Commissioner investigated an alleged breach of privacy involving Saskatchewan Telecommunications (SaskTel). The complaint alleged that SaskTel was over-collecting a customer’s personal information as part of its identity verification process. Along with other findings, the Commissioner found that SaskTel did not have authority to collect the complainant’s Saskatchewan Health Services Number. Furthermore, that SaskTel did not provide a satisfactory explanation as to why it needed to collect other unique identifiers over the phone since it could not verify the accuracy of same. The Commissioner recommended that SaskTel conduct a privacy impact assessment, revise its privacy policy, and prepare a script to ensure that its customers understand what is optional when providing proof of identity. Further, that SaskTel purge its system of all 14 Office of the Privacy Commissioner of Canada, Fact Sheets - Best Practices for the use of Social Insurance Numbers in the private sector. Available at Best Practices for the use of Social Insurance Numbers in the private sector - Office of the Privacy Commissioner of Canada. Also cited in SK OIPC Investigation Report F-2012-001 at [33]. 15 See The Health Information Protection Act, SS 1999, c H-0.021 at section 11.
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