Office of the Saskatchewan Information and Privacy Commissioner. Privacy Protective Survey Guidance. 14 March 2024. 10 enter into an information sharing agreement with the other entity. The requirements for the information sharing agreement are set out in subsection 17.1(2) of the FOIP Regulations. Another Public Body Administers the Survey Your plan may be to ask another public body to use personal information from its own data sources to identify a survey sample, contact participants, and carry out the survey on your behalf. If you select this option, then the public body conducting the survey must have the authority to use the personal information for this purpose. If your public body and the other public body have a direct interest in the subject of the survey and its results, the use may be authorized as a consistent use. Third Party Survey Providers Regardless of who conducts your survey, the same privacy rules apply to any personal information collected. If you retain the services of a third party, such as a survey company, online survey provider or another public body to do the research, a written agreement is needed to ensure that the other party complies with FOIP and LA FOIP. Subsection 2(1)(b.1) of FOIP defines “employee of a government institution” as an individual employed by a government institution and includes an individual retained under a contract to perform services for the government institution. There is a corresponding definition in LA FOIP. You will need to consider if the entity retained to conduct the survey qualifies as an “employee” of your public body. In the privacy world, when personal information is provided to a contractor to facilitate the provision of a service, this constitutes a “use” and not a “disclosure.” Therefore, when a public body transfers information for processing, it can only be used for the purposes for which the information was originally collected. Contracts with online survey providers raise some additional privacy concerns that must be addressed. Ensure that your online survey provider does not allow third parties to track participants. This might arise where an online survey provider permits advertisements and social media analytics to gain access to data. As noted above, information gathered from survey participants could be used with other information to identify individuals.
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