Canadian privacy & access decisions

The OPC investigated a complaint against the RCMP regarding the use and disclosure of personal information from the Canadian Firearms Program (CFP) to EKOS Research Associates Inc. for a survey of firearms licensees. The investigation examined whether the RCMP improperly used or disclosed personal information in contravention of sections 7 and 8 of the Privacy Act. The OPC found that the use of information for a client-satisfaction survey to improve CFP services was consistent with the original collection purpose, thus not contravening section 7. Furthermore, the disclosure to EKOS, acting as an agent under a contract with confidentiality and security provisions, did not contravene section 8. The complaint was therefore deemed not well-founded. The OPC noted that the CFP committed to updating its InfoSource entry and website to better inform the public about information use for surveys and acknowledged that a Privacy Impact Assessment would have been beneficial.

• Whether the use of personal information for a client-satisfaction survey was consistent with the purpose for which it was obtained or compiled under s.7(a) of the Privacy Act
• Whether the disclosure of personal information to EKOS Research Associates Inc. for the survey contravened s.8 of the Privacy Act
• Whether the personal information collected by the RCMP related directly to an operating program or activity of the institution under s.4 of the Privacy Act