Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 332 must address administrative, technical, and physical safeguards for personal information. See Section 23.1 earlier in this Chapter for more on this requirement. Local authorities should have an email management policy.778 The Commissioner has addressed this issue with local authorities and government institutions in multiple reports which are summarized below: In Investigation Report 350-2017, the Commissioner investigated a complaint involving the Village of Hodgeville (Village). It was alleged that the Mayor of the Village forwarded a copy of the privacy complaint to personal email accounts including those of the councillors. This included “sasktel.net” and “hotmail.com” email addresses. The Commissioner recommended the Village set up email accounts for the councillors to use when conducting business for the village to ensure the security and retention of records. In Review Report 219-2018, the Commissioner discussed how a councillor was using a personal email account to conduct City of Moose Jaw business (City). To respond to an access to information request, the City requested the councillor to conduct a search of their personal email account using specific search terms and to provide the relevant emails. Even though the Commissioner was satisfied that the City verified with the councillor that the personal email account was searched for responsive records, the Commissioner recommended that the City set up email accounts for its councillors to use for conducting City business. In Review Report 361-2021, the Commissioner discussed how the text messages between the Administrator for the Village of Neudorf (Village) and two council members were responsive to an access to information request. The text messages were regarding Village business; however, the texts were sent from personal devices. The Commissioner found that the text messages would be subject to LA FOIP, and he recommended that the Village conduct a search for the responsive text messages on the personal devices. The Village had amended its practices by creating email accounts for its council members and discouraged the use of personal email accounts and personal cellular phones for Village business. In Review Report 184-2016, the Commissioner addressed the issue of Global Transportation Hub (GTH) board members using personal email addresses to conduct 778 The Ministry of Central Services was in the process of developing a government wide email management policy in 2017. See SK OIPC Investigation Report 101-2017 at [37] to [38].
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