Guide to LA FOIP-Chapter 6

Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 154 the provision of a service or other activity.433 The purpose of a collection means the reason(s) the personal information is needed and the use(s) that the local authority will make of the personal information.434 Original purpose is the specific reason for which the personal information was collected or created in the first place.435 Example: a local authority collects certain employment history information about employees to administer benefit programs and that information can subsequently be used to determine the employee’s eligibility for a certain program. Consistent purpose is one that has a direct and reasonable connection to the original purpose and that is necessary for performing the statutory duties of, or for operating a legally authorized program of, the local authority that uses the personal information.436 A purpose is consistent and compatible where an individual might reasonably have expected the use of the personal information at the time of collection.437 Consistent use is a use of personal information that has a reasonable and direct connection to the specific reason for which it was collected or created in the first place. This means that the original use and the proposed use are so closely related that an individual would expect that the information would also be used for the second purpose (consistent purpose), even if the use is not spelled out.438 433 British Columbia Government Services, FOIPPA Policy Definitions at https://www2.gov.bc.ca/gov/content/governments/services-for-government/policiesprocedures/foippa-manual/policy-definitions. Accessed April 23, 2020. 434 SK OIPC Investigation Report F-2012-001 at [62]. Originated from Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p 248. 435 Office of the Privacy Commissioner of Canada, Access to Information and Privacy Process and Compliance Manual for the OPC, available at Access to Information and Privacy Process and Compliance Manual for the OPC - Office of the Privacy Commissioner of Canada. Accessed December 14, 2022. 436 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p. 261. 437 Ministry of Government and Consumer Services, Information, Privacy and Archives, Freedom of Ontario Information and Protection of Privacy Manual at p. 140. Available at https://files.ontario.ca/books/foi_privacy_manual_-_final-v02-2018-03-08-en-accessible.pdf. Accessed July 8, 2020. 438 Office of the Privacy Commissioner of Canada, Access to Information and Privacy Process and Compliance Manual for the OPC, available at Access to Information and Privacy Process and Compliance Manual for the OPC - Office of the Privacy Commissioner of Canada. Accessed December 14, 2022.

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