Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 119 Subsection 23.1(b)(ii) Duty of local authority to protect 23.1 Subject to the regulations, a local authority shall establish policies and procedures to maintain administrative, technical and physical safeguards that: … (b) protect against any reasonably anticipated: … (ii) loss of the personal information in its possession or under its control; or Subsection 23.1(b)(ii) of LA FOIP requires local authorities to establish written policies and procedures that protect against any reasonably anticipated loss of personal information. Reasonably anticipated “Reasonable” means what a reasonable person would consider appropriate in the circumstances.325 This standard acknowledges that reasonable “does not mean perfect”.326 To “anticipate” means to be aware of (a future event) and take action; regard as probable; look forward to; to act or happen before.327 Loss means the failure to maintain possession of personal information.328 Loss can include: • Accidental or deliberate loss of data – e.g., physical damage to hardware, willful destruction of recorded information, information destroyed in a flood or fire. • The removal of equipment – e.g., theft of a laptop or file containing personal information, use of information outside the office (e.g., using the information on a home computer), disposal of information at the employee’s home. 325 British Columbia’s Personal Information Protection Act, SBC 2003, c 63 at section 2 and subsection 4(1). See also section 2 of Alberta’s Personal Information Protection Act, SA 2003, c P-6.5 and the joint resource by the Service Alberta and Alberta IPC titled, A Guide for Businesses and Organizations on the Personal Information Protection Act at p. 9. 326 BC IPC Investigation Report F06-01 at [49]. 327 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed. at p. 57, (Oxford University Press). 328 Adapted from Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p. 1132.
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