What is Personal Information?
Introduction
Under the Freedom of Information and Protection of Privacy Act (FIPPA), Thompson Rivers University (TRU) is regulated in how it may collect, use and disclose personal information (PI).
FIPPA definitions
1. “Personal information” is defined as “recorded information about an identifiable individual other than contact information.”
2. “Contact information” is defined as “information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual.”
The meaning of “identifiable individual”
Information is only considered to be personal information if it is about an “identifiable individual”. Individuals may be identified using their name or another unique number or characteristic, for example by a photograph, SIN number, fingerprint, employee number, or student ID. Any information that has a precise, direct connection with one of these personal identifiers is personal information:
- John Smith is 40 years old.
- Sally Jones is a student.
- Student Number 123456 failed the English exam.
- The Dean of the Faculty of Boxology is sick today.
To determine whether information is about an “identifiable individual”, the Privacy Commissioner of Canada has formulated the following test:
“Information will be about an identifiable individual where there is a serious possibility that an individual could be identified through the use of that information, alone or in combination with other available information”.
Application to staff and students
Based on the two FIPPA definitions above, personal information comprises all recorded information about an identifiable individual, with the exception of the names and business contact information of employees, volunteers and service providers (information that appears on a business card - “contact information”), and most of this business contact information is publicly posted on the TRU website.
On the other hand, students’ names, mailing addresses, email addresses, and phone/fax numbers (their contact information) is not considered to be “contact information” under the FIPPA, as they attend TRU in a personal capacity. This means that all information about students, including their names, is personal information and is protected under the FIPPA.
Caution should be exercised before releasing any data that was derived from underlying personal information, even if you think you have “de-identified” the data. Information technology provides powerful tools for analyzing and linking data. It may be possible for someone to re-identify individuals by combining seemingly innocuous bits of available data. This is sometimes called the “mosaic effect”.
This information is not legal advice. Specific questions about the FIPPA should be directed to privacy@tru.ca.
