Personal Information Directory

Authority

The Freedom of Information and Protection of Privacy Act (FOIPPA) is the privacy legislation applicable to B.C. public bodies. Section 69 of FOIPPA requires public bodies to publish a directory of personal information holdings including personal information banks.

Purpose

The purpose of the Personal Information Directory (PID) is to document the management of personal information holdings of government and to assist the public in identifying the location of personal information about them held by government.

Definitions

Schedule 1 of FOIPPA defines that a personal information bank (PIB) is a collection of personal information that is organized or retrievable by

  • an identifying number
  • symbol
  • or other particular assigned to an individual

Personal Information is recorded information about an identifiable individual including

  • the individual’s name, address or telephone number
  • the individual’s race, national or ethnic origin, colour, or religious or political beliefs or associations
  • the individual’s age, sex, sexual orientation, marital status or family status
  • an identifying number, symbol or other particular assigned to the individual
  • the individual’s fingerprints, blood type or inheritable characteristics
  • information about the individual's health care history, including a physical or mental disability
  • information about the individual's educational, financial, criminal or employment history
  • anyone else’s opinions about the individual
  • the individual’s personal views or opinions, except if they are about someone else

Interpretation

A collection of personal information means paper or electronic files that contain personal information and are collected for the same purpose or to document the same function and relates to an identifiable individual.

A collection of personal information does not include random references to personal information contained in a file.

Organized or retrievable by the name of an individual or by an identifying number, symbol or other particular assigned to an individual means personal information contained in either paper or electronic files that relates to an individual and is organized and retrieved using a personal identifier (for example, an individual’s name, employee number, and social insurance number).

Paper Files

Personal information banks can be in contained in paper files if it contains personal information relating to specific individuals and are retrievable by a personal identifier.

Examples:

  • Personal Information Bank: physician/practitioner case files. These files are arranged by a practitioner billing number that is considered to be a personal identifier.
  • Not a Personal Information Bank: Laboratory/hospital monitoring case files. These files are arranged and retrievable by name of the laboratory or hospital. The files cannot be retrieved by a personal identifier even though sensitive personal information may be contained within a file.

Electronic Files

Files with a defined category that contain personal information that can be electronically searched and retrieved by an individual’s name or other personal identifier.

Examples:

  • Personal Information Bank: Beneficiary (patient) claims information. These files can be searched and personal information retrieved by a Personal Health Number that is considered to be a personal identifier

  • Not a Personal Information Bank:  Inspection and Deficiency Reports (Municipal Affairs). These files contain the names of contractors who inspect elevators. The files are not organized or retrieved by a personal identifier even though personal information is contained within the file

It should be noted that not all collections of personal information are considered PIBs. The key to determining whether a group of files is a PIB is the way it is arranged or retrieved. Collections of personal information that relate to an individual and are organized and retrievable by the person’s last name or personal identifier are PIBs.

Collections of personal information that are organized and retrieved by an identifier that relates to a corporate body or other search field are not listed as PIBs, even if the collections contain personal information.

Personal Information Directory

Personal Information Banks

Section 69 of the Act requires that the following information be listed for PIBs:

  • its title and location
  • a description of the kind of personal information and the categories of individuals whose personal information is included
  • the authority for collecting the personal information
  • the purposes for which the personal information is obtained or compiled
  • the purposes for which the personal information is used or disclosed
  • the categories of persons who use the personal information or to whom it is disclosed

In addition, the PID will contain:

  • the name of an individual who may be contacted regarding the PIB
  • the Branch responsible for the PIB
  • if there an Information Sharing Agreement relevant to the PIB
  • if a PIA has been completed

It is important to note that the PID will also include details of ministry Information Sharing Agreements and Privacy Impact Assessments.

Checklist

  • Does the file contain personal information
  • Does the file contain like or similar personal information
  • Is the information linked to an identifiable individual
  • Is the information organized and capable of being retrieved by a personal identifier