Canadian privacy & access decisions

A complainant alleged that his Internet service provider (ISP) disclosed his personal information without consent to a newspaper columnist. The complainant had contacted the columnist for assistance in resolving a service dispute with the ISP. The ISP argued it had implied consent to disclose information relevant to the dispute. The OPC found that the personal information disclosed was not sensitive and that, given the complainant's actions and familiarity with the columnist's work, it was reasonable for the ISP to infer implied consent. The ISP also limited its disclosure to information relevant to the complaint. Therefore, the OPC concluded that the complaint was not well-founded.

• Whether the ISP had the complainant's consent to disclose information to the newspaper columnist
• Whether the personal information disclosed was sensitive
• Whether implied consent was appropriate in the circumstances
• Whether the ISP limited its disclosure to relevant information

The Canada School of Public Service (the School) received a letter from the Public Sector Integrity Commissioner (PSIC) detailing allegations of wrongdoing against seven employees. The School then hand-delivered copies of this letter, which identified the seven individuals and the alleged wrongdoings, to each of the named employees. One of these employees complained to the OPC, alleging that the disclosure of his name via this letter violated the Privacy Act. The OPC found the complaint to be well-founded, concluding that the School had improperly disclosed personal information. Following the OPC's recommendations, the School developed new procedures to protect the confidentiality of information related to the Public Servants Disclosure Protection Act and a plan for addressing privacy breaches.

• Whether the Canada School of Public Service disclosed personal information contrary to the Privacy Act by hand-delivering a letter from the Public Sector Integrity Commissioner to employees named in it