Collection of RCMP member's health information unnecessary (RCMP) - November 17, 2014
A former RCMP member complained that the RCMP inappropriately collected her personal medical and financial information from Veterans Affairs Canada (VAC) after she was awarded a disability pension. The complainant alleged that the RCMP's National Compensation Policy Centre had no need for this sensitive information. The OPC found that the 2002 Memorandum of Understanding (MOU) between the RCMP and VAC transferred responsibility for pension administration to VAC, meaning the RCMP's National Compensation Policy Centre did not require the detailed medical diagnosis or financial information. The OPC concluded that the collection of this information by the RCMP was not for a purpose consistent with section 4 of the Privacy Act. The complaint was found to be well-founded, and the OPC recommended updating the MOU and reviewing RCMP's internal policies on access to medical records.
- 1Whether the collection of the complainant's financial information by the RCMP was necessary and related directly to an operating program or activity under section 4 of the Privacy Act
- 2Whether the collection of the complainant's medical diagnosis/pensioned disability by the RCMP was necessary and related directly to an operating program or activity under section 4 of the Privacy Act
- 3Whether the collection of the complainant's disability percentage by the RCMP was necessary and related directly to an operating program or activity under section 4 of the Privacy Act
- 4Whether the collection of personal information by the RCMP's National Compensation Policy Centre was consistent with the RCMP's own internal policies restricting access to sensitive medical information
- 5Whether the MOU between VAC and the RCMP adequately addressed information sharing practices for sensitive personal information
- Collection of personal information: Collection by RCMP was not for a consistent purpose
- Complaint finding: Complaint was well-founded
- MOU update recommendation: OPC recommended updating the MOU
- Policy review recommendation: OPC recommended reviewing internal policies
Complaint well-founded — recommendations made
The OPC found that the RCMP's collection of the complainant's detailed medical and financial information was not necessary for its operating programs or activities, as the responsibility for pension administration had been transferred to VAC via an MOU. The collection was also inconsistent with the RCMP's own internal policies regarding access to sensitive medical information.
The OPC recommended that the RCMP update its Memorandum of Understanding with VAC to provide comprehensive information about the proper flow of sensitive personal information and periodically review it. The OPC also recommended that the RCMP revise Appendix III-11-1 of its Health Service Manual AM II.19 to address concerns about access to employee medical records by Historian/Researchers and the Public Affairs and Information Directorate.
- s.3 Privacy Act
- s.4 Privacy Act
- s.8(2)(a) Privacy Act
- s.35(1)(b) Privacy Act
This summary is informational only and not legal advice.
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