Canadian Privacy Decisions

This investigation examined complaints regarding the National Security and Intelligence Review Agency's (NSIRA) Secretariat's request for access to polygraph records as part of a review of the Communications Security Establishment. The OPC found that the anonymization measures significantly reduced re-identification risks, and the polygraph recordings themselves contained no personal information. However, concerns were raised about the timeliness of the Secretariat's requests to Treasury Board Secretariat for approval of Personal Information Banks (PIBs). The collection issue was found not well-founded, but the timeliness of PIB updates was found well-founded and subsequently resolved.

• Whether the NSIRA Secretariat collected personal information without a direct relationship to its operating programs or activities.
• Whether the NSIRA Secretariat complied with its obligations to include all personal information under its control in Personal Information Banks (PIBs).
• Assessment of privacy mitigation measures implemented by CSE to anonymize polygraph records.
• Timeliness of the NSIRA Secretariat's requests for PIB approvals and publication of its Info Source page.

The complainant alleged that Indigenous Services Canada (ISC) did not conduct a reasonable search for records concerning housing guides and criteria for Indigenous communities from 1960 to 1990. The Office of the Information Commissioner (OIC) found the search was initially unreasonable, as ISC failed to retrieve all relevant records. After further searches prompted by the OIC, 800 pages of responsive records were identified. The OIC ordered ISC to release records promptly, with a final response to follow.

• Reasonableness of the search conducted by the institution.
• Identification and retrieval of all responsive records.
• Timeliness of interim and final responses to the access request.