Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 147 Complete means including every item or element, without omissions or deficiencies; not lacking in any element or particular. Information is complete when all the information necessary for the administrative purpose, and only the information necessary, is used.416 LA FOIP does not define the phrase “reasonably possible”. However, the dictionary meanings of these words are as follows: Reasonably possible: Reasonable means what a reasonable person would consider appropriate in the circumstances.417 This standard acknowledges that reasonable “does not mean perfect”.418 It means fair, proper, moderate under the circumstances.419 Possible means capable of existing, happening or being achieved.420 The extent to which personal information is accurate, complete and up to date will depend upon the use of the information, taking into account the interests of the individual. Information shall be sufficiently accurate, complete, and up to date to minimize the possibility that inappropriate information may be used to make a decision about the individual.421 Generally, if a local authority collects personal information directly from an individual, the risk is lower that the information is inaccurate or incomplete. The risk increases when a local authority collects personal information indirectly. The burden of meeting the “reasonably 416 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p. 251. See also Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-95. Available at Chapter (gov.mb.ca). Accessed December 13, 2022. 417 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. 418 BC IPC Investigation Report F06-01 at [49]. 419 Garner, Bryan A., 2019. Black’s Law Dictionary, 11th Edition. St. Paul, Minn.: West Group at p 1518. See also Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at p. 6-96. Available at Chapter (gov.mb.ca). Accessed December 13, 2022. 420 See SK OIPC Review Report 082-2019, 083-2019 at [72] Originates from Pearsall, Judy, Concise Oxford Dictionary, 10th Ed., (Oxford University Press) at p. 1117. 421 SK OIPC Investigation Reports F-2009-001 at [91] and LA-2013-001 at [35]. Originated from Saskatchewan Justice (now Ministry of Justice) resource, An Overarching Personal Information Privacy Framework for Executive Government, 2003 at p. 17.
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