Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 178 IPC Findings In Investigation Report 068-2020, the Commissioner investigated an alleged breach of privacy involving the Town of Qu’Appelle (Town). The complaint alleged that the Town breached the individual’s privacy by disclosing a copy of a “Residential Contract of Purchase and Sale” to the Appeals Assessment Committee. The Town asserted that subsection 28(2)(e) of LA FOIP provided authority to disclose the sales agreement. The Commissioner found that the Town had authority to disclose the complainant’s personal information pursuant to subsection 28(2)(e) of LA FOIP. Subsection 28(2)(f) Disclosure of personal information 28(2) Subject to any other Act or regulation, personal information in the possession or under the control of a local authority may be disclosed: … (f) for the purpose of locating an individual in order to collect a debt owing to the local authority by that individual or make a payment owing to that individual by the local authority; Subsection 28(2)(f) of LA FOIP provides that a local authority can disclose personal information without consent for the purpose of locating an individual to collect a debt owed to the local authority or for the local authority to make a payment owed to the individual. Sometimes, local authorities face the problem of not being able to locate an individual that owes money to the local authority, or the local authority owes the individual money. The following two-part test can be applied: 1. Is the disclosure of personal information for the purpose of locating the individual? To rely on this provision, the local authority must be disclosing the individual’s personal information for the purpose of locating the individual to collect a debt from the individual or make a payment to the individual.
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