Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 135 In general terms, LA FOIP limits the entitlement of local authorities to personal information so that they may only collect such information to the extent that it is necessary or relevant to the various lawful activities of the local authority. Moreover, local authorities may only collect personal information in certain permitted ways which have the effect of giving notice that the information is in fact being collected by a local authority and indicating the general reason for it being collected (see section 25 below for more).377 IPC Findings In Investigation Report F-2012-001, the Commissioner considered the over collection of a customer’s personal information by Saskatchewan Telecommunications (SaskTel) as part of its identity verification process. The Commissioner found that SaskTel did not have authority to collect the Saskatchewan Health Services Number. Secondly, SaskTel did not provide a satisfactory explanation as to why it needed to collect other unique identifiers over the telephone since it could not verify the accuracy of same. Thirdly, the Commissioner found that SaskTel was collecting third party personal information without authority. Further, the Commissioner found that SaskTel was not meeting the notice requirements of subsection 26(2) of The Freedom of Information and Protection of Privacy Act (FOIP) – equivalent to subsection 25(2) of LA FOIP. 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. The Commissioner further recommended that SaskTel purge its systems of all personal information and personal health information of its customers and third parties that it collected without the requisite authority within 60 days. Over collection Over collection is where a local authority collects more personal information than is necessary to accomplish the authorized purpose.378 377 SK OIPC Investigation Report F-2012-001 at [19]. Originated from K. Klein and D. Kratchanov: Government Information: The Right to Information and the Protection of Privacy in Canada, Second Edition (Toronto: Carswell Press, 2009) at pp. 8-15. 378 Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-52. Available at https://www.gov.mb.ca/fippa/public_bodies/resource_manual/pdfs/chap_6.pdf. Accessed on July 15, 2020.
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