Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 149 • Establishing cross referencing and verification checks within software of automated systems that identify anomalies in data. Privacy requirements should be integrated into normal information and systems operations for the program.427 Before using personal information to make a decision that affects an individual, the following questions may be helpful in assessing its accuracy and completeness: • Was the personal information collected directly from the individual it is about. • Was the accuracy of the personal information verified at the time it was collected. • Is the proposed use of the personal information consistent with the purpose for which it was collected. • What is the likelihood that the personal information is outdated. How old is the information. Is it likely that circumstances have changed since the information was collected. • Are there systems in place to check the accuracy and completeness of the personal information – for example, periodic audits of files for accuracy, cross- referencing to other related files, systematic procedures for updating personal information, etc.?428 IPC Findings In Investigation Report F-2009-001, the Commissioner investigated a complaint involving the Saskatchewan Workers’ Compensation Board (WCB). An individual had concerns about the way WCB collected, used and disclosed his personal information. During the Commissioner’s investigation, the Commissioner found evidence that raised whether the WCB met its duty to ensure accuracy in the personal information it uses for an administrative purpose and that such information be complete. The Commissioner found that WCB had appropriately developed a policy called Safety and Security Policy which included several checks and balances to ensure that decisions made under the policy would be evidence based and properly substantiated. However, the policy did not appear to have been followed in that case. Specially, the factual basis upon which WCB classified the complainant as a C4 and later a C5 risk was demonstrably incomplete. The Commissioner noted the high prejudice that 427 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, pp. 251 to 252. Also quoted in SK OIPC Review Report F-2006-003 at [52]. 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. 428 Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 6, Protection of Privacy at pp. 6-96 to 6-97. Available at Chapter (gov.mb.ca). Accessed December 13, 2022.
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