Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 126 Section 23.2 of LA FOIP was a new additional provision in LA FOIP that came into force on January 1, 2018. The accompanying section 8.2 of The Local Authority Freedom of Information and Protection of Privacy Regulations also came into force at the same time. Much of the experience in Saskatchewan surrounding information service providers comes from work surrounding section 18 of The Health Information Protection Act (HIPA). However, the concept of an information management service provider is by no means unique to Saskatchewan. It is a common feature in other privacy legislation across Canada (see for example Manitoba’s The Personal Health Information Act, Alberta’s Health Information Act, Ontario’s Personal Health Information Protection Act, and Newfoundland and Labrador’s Personal Health Information Act). The title may be different, but in each of these statutes there is a specific provision for a health trustee to make arrangements for a third party to store or destroy personal health information.349 Subsection 23.2(1) Information management service provider 23.2(1) A local authority may provide personal information to an information management service provider for the purposes of: (a) having the information management service provider process, store, archive or destroy the personal information for the local authority; (b) enabling the information management service provider to provide the local authority with information management or information technology services; (c) having the information management service provider take possession or control of the personal information; (d) combining records containing personal information; or (e) providing consulting services. Subsection 23.2(1) of LA FOIP provides that a local authority can disclose personal information in its possession or control to an information management service provider (IMSP) provided the purpose for sharing is for one of the services or functions outlined in subsection 23.2(1) of LA FOIP. 349 SK OIPC Investigation Report H-2011-001 at [194].
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