Canadian privacy & access decisions

The Office of the Privacy Commissioner of Canada (OPC) investigated a complaint against Immigration, Refugees and Citizenship Canada (IRCC) regarding a privacy breach. IRCC inadvertently disclosed the personal information of 497 individuals when sending mass email notifications for a work permit extension program. An employee failed to apply a filter to the email address column in an Excel spreadsheet, causing email addresses to misalign with other personal data, leading to notifications being sent to incorrect recipients. The OPC found that IRCC contravened section 8 of the Privacy Act by disclosing personal information without a permissible purpose and that its prevention measures were insufficient. While IRCC's mitigation efforts, including notifying affected individuals, were deemed adequate, the OPC recommended implementing robust procedural and administrative controls. IRCC accepted these recommendations, committing to measures such as a 'two pairs of eyes' rule, updated operating procedures, and data quality assurance checks. Consequently, the OPC considered the matter resolved.

• Whether IRCC's disclosure of personal information to unintended recipients contravened section 8 of the Privacy Act.
• Whether IRCC had sufficient measures in place to prevent unauthorized disclosures of personal information of this nature.
• Whether IRCC's response to mitigate the impact of the breach on affected individuals was adequate.