Canadian privacy & access decisions

A group of Canada Border Services Agency (CBSA) employees complained that a new policy requiring them to wear name tags displaying their surnames, instead of badge numbers, violated sections 7 and 8 of the Privacy Act. They argued this constituted an unreasonable invasion of privacy and made them vulnerable to violence and intimidation, as their names could be used to find personal information. The CBSA contended that the name tags were part of a service excellence initiative, promoted professionalism and accountability, and that an employee's name on a name tag falls under an exception to the definition of personal information in the Act. The OPC found that while a surname on a name tag is information about an identifiable individual, it falls under paragraph (j) of the definition of personal information, which excludes information relating to the position or functions of a government employee for the purposes of sections 7 and 8. Therefore, the OPC concluded that the policy did not violate the Act.

• Whether the surname of a Border Services Officer (BSO) displayed on a name tag constitutes "personal information" under section 3 of the Privacy Act
• Whether the surname on a name tag falls within the exception to the definition of personal information under paragraph (j) of section 3 of the Privacy Act
• Whether the CBSA's requirement for BSOs to wear name tags displaying their surnames violates sections 7 and 8 of the Privacy Act