Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 179 If the local authority is disclosing personal information but already knows where the individual is located, the provision cannot be relied upon. Locate means to discover the exact place or position.486 In this context, it means the act of locating an individual. “Location” means a particular place or position.487 2. Is locating the individual for the purpose of collecting a debt owed to the local authority or for the local authority to make a payment owed to the individual? A debt is something that is owed, usually money, where the individual has an obligation to pay, and the creditor has the right to receive and enforce payment.488 A debt is a specified amount of money due to the local authority. A payment is a sum of money which a local authority owes to an individual.489 This provision does not permit disclosure of personal information by a local authority for the purpose of determining whether a debt or payment is owed. This determination must already be made.490 Local authorities should still abide by the data minimization and need-to-know principles when disclosing personal information for this purpose. Only disclose the least amount of personal information necessary to achieve the purpose of locating the individual. It is generally not necessary to disclose the reason for the debt or payment (e.g., the penalty or offence leading to the debt owed). Further, only disclose to those that have a need-to-know the personal information to carry out the purpose. See Need-to-Know and Data Minimization earlier in this Chapter. 486 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed., (Oxford University Press) at p. 833. 487 Pearsall, Judy, Concise Oxford Dictionary, 10th Ed., (Oxford University Press) at p. 833. 488 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p. 277. 489 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. 490 Service Alberta, FOIP Guidelines and Practices: 2009 Edition, Chapter 7, p. 278.
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