Office of the Saskatchewan Information and Privacy Commissioner. Guide to LA FOIP, Chapter 6, Protection of Privacy. Updated 27 February 2023. 56 An identifying number or symbol is, by itself, a piece of personal information because it uniquely identifies an individual. Examples include an individual’s social insurance number, driver’s licence number138, passport number and client numbers assigned by a local authority or bank.139 Employee number when linked with a name was found to be personal information.140 Health services number means a unique number assigned to an individual who is or was registered as a beneficiary to receive insured services within the meaning of The Saskatchewan Medical Care Insurance Act.141 Note: Subsection 23(1)(d) of LA FOIP would capture health services numbers in instances where the local authority is not also a trustee. If the local authority is also a trustee, the health services number would be “personal health information” and would be captured by The Health Information Act as per subsection 23(1.1) of LA FOIP. See Subsection 23(1.1) below in this Chapter for further assistance. 138 History of SK OIPC approach: In Review Reports F-2013-007 at [125], 031-2015 at [44], 129-2015 at [33], 010-2016 at [25], 244-2017 at [17] and Investigation Report F-2012-001 at [6] and footnote [2], the Commissioner found a “driver’s licence number” qualified as personal information pursuant to subsection 24(1)(d) of FOIP. In Review Reports 063-2017, 146-2017 and Investigation Report 096-2018, the Commissioner found that a “driver’s licence number” was not personal information because of subsection 24(2)(e) of FOIP. In the 2018 decision, Shook Legal, Ltd v Saskatchewan (Government Insurance), 2018 SKKB 238 (CanLII), it was found that the “details of a licence” as per subsection 24(2)(e) included name, address, description of the vehicle to be licenced and vehicle registration number (VIN) (see paragraph [34] of the decision). This is supported by the 1993 Saskatchewan Court of Appeal decision, General Motors Acceptance Corp. of Canada v. Saskatchewan Government Insurance, 1993 CanLII 9128 (SK CA) which stated ““Details of a licence or permit” does not contemplate release of a core of personal data that one provides in confidence.” 139 Government of Manitoba, FIPPA for Public Bodies – Resource Manual, Chapter 2, Scope of FIPPA – Who and What Falls under FIPPA at p. 52. Available at https://www.gov.mb.ca/fippa/public_bodies/resource_manual/pdfs/chap_2.pdf. Accessed on April 24, 2020. 140 See SK OIPC F-2005-001 at [22] and LA-2012-002 at [29] to [30] and [106]. 141 Definition originates from The Health Information Protection Act at s. 2(i).
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