Canadian Privacy Decisions

The complainant alleged that Veterans Affairs Canada (VAC) inappropriately disclosed her health and financial information to the Royal Canadian Mounted Police (RCMP). The investigation found that VAC disclosed the complainant's medical diagnosis and financial information to the RCMP's National Compensation Policy Centre via its pension award letter. This disclosure was found to contravene the Privacy Act because it was not a 'consistent use' of the information, as neither consent nor a clear need-to-know was established for the RCMP's National Compensation Policy Centre to receive this sensitive personal information. The issue was also found to be systemic, affecting numerous RCMP employees.

• Was the disclosure of the complainant's medical and financial information by VAC to the RCMP a contravention of the Privacy Act?
• Did the complainant provide informed consent for the disclosure of her personal information?
• Was the disclosure of information considered a 'consistent use' under paragraph 8(2)(a) of the Privacy Act?
• Was the disclosure of personal information systemic in nature?

The Office of the Privacy Commissioner of Canada investigated a complaint concerning the RCMP's collection of a member's medical diagnosis and financial information from Veterans Affairs Canada (VAC). The OPC found that the RCMP's National Compensation Policy Centre collected sensitive personal information that was not necessary for the administration of pension benefits or health care, contravening the Privacy Act. The investigation revealed this practice was systemic and occurred over several years, despite the transfer of responsibility for pension adjudication to VAC.

• Necessity of collecting medical and financial information by the RCMP from VAC.
• Consistency of collection with the purposes for which information was originally collected by VAC.
• Systemic nature of the inappropriate collection of sensitive personal information.
• Adequacy of information sharing agreements between federal institutions.