Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 218 (3) Probability and degree of injury • Consider the probability and degree or gravity of injury relative to the benefits of the disclosure to the public. This could include personal or physical injury, or damage to the reputation of an individual or others, which causes adverse consequences (e.g., any harm or embarrassment that negatively affects an individual's career, reputation, financial position, safety, health, or well-being). • Determine the potential of injury if the receiving party wrongfully disclosed the information further.590 Where the local authority intends to rely on this provision to disclose personal information, notification is required to the individual(s) pursuant to the third party notification requirements outlined at subsection 33(1)(b) of LA FOIP. For more on this process, see the Guide to LA FOIP, Chapter 5 – “Third Party Information”. Local authorities should still abide by the data minimization and need-to-know principles when disclosing personal information. Only disclose the least amount of personal information necessary to achieve the purpose. 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. IPC Findings In Investigation Report 092-2015 to 095-2015, the Commissioner investigated an alleged breach of privacy involving the Ministry of Health, the Office of the Premier, Oliver Lodge and Saskatoon Regional Health Authority. The investigation involved the collection and disclosure of a care aide’s personal information. The Commissioner found that there was a public interest in the release of the information and that the public interest outweighed any invasion of privacy. In Review Report 282-2018, the Commissioner investigated an alleged breach of privacy involving the Rural Municipality of Parkdale (RM). The complaint alleged the RM disclosed a former employee’s personal information who was deceased. The disclosure was made by posting the personal information in council meeting minutes which were posted to the RM’s website. Along with other provisions, the RM asserted it had authority to disclose the 590 Privacy Commissioner of Canada, Public Interest Disclosures by federal institutions under the Privacy Act, revised June 2022. Available at Public interest disclosures by federal institutions under the Privacy Act - Office of the Privacy Commissioner of Canada. Accessed December 15, 2022.
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