Procedure for Reviewing Personal Information – June 11, 2021

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PROCEDURE FOR REVIEWING PERSONAL

INFORMATION

Procedure

Type:

Management

Initially

Approved:

June 11,

2021

Procedure

Sponsor:

General Counsel

and University

Secretary

Last Revised:

Primary

Contact:

Information

Management &

Privacy Office

Review

Scheduled:

June 11,

2026

Approver:

Executive Leadership Team

PROCEDURES

REPORTING INCORRECT PERSONAL INFORMATION

1.1

If an individual believes that their Personal Information associated with any Record

under the control or custody of the University contains an error or omission, they may

request that the information be corrected.

1.2

The individual may have their request addressed either informally by asking the

Unit(s) who holds the Record directly or by submitting a formal request to the

Information Management & Privacy Advisor (“IMPA”).

1.3

An individual who requests to review their Personal Information will be required to

authenticate their identity prior to having their request processed.

INFORMAL CORRECTION OF PERSONAL INFORMATION

2.1

Upon receipt of an informal request to correct information, the Unit may correct the

information if it is satisfied that the Record contains an error or omission.

2.2

If the Unit is aware that other Units may hold Records containing a similar error or

omission, they must notify those other Units of the request. The other Unit(s) will

determine if the request impacts the Records they hold.

2.3

If a Unit does not correct the information, it will notify the individual and advise them

of their right to submit a formal request to correct their Personal Information to the

University Information Management & Privacy Advisor.

FORMAL CORRECTION OF PERSONAL INFORMATION

3.1

All formal correction requests must be submitted through a Request to Correct

Personal Information Form to the IMPA and contain sufficient information to identify

any Records under the control or custody of the University which are alleged to

contain errors or omissions.

3.2

The IMPA, in consultation with the Unit who holds the Record, will review the request,

and determine whether a correction or annotation will be made to the Record.

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3.3

A Record will be corrected where:

a. the Record contains an error or omission;

b. the Personal Information to be corrected must belong to the individual requesting

the correction; and

c. the Record is not an opinion about the individual.

3.4

The University will provide its final response to a formal request to correct Information

within 30 calendar days of initial receipt. That timeline may be extended only in

accordance with the limited circumstances provided under the Act. The IMPA will

notify the requestor of the date of final response or if a timeline extension is

warranted.

3.5

Where a record is not corrected, that record will be annotated to note the requested

correction and the decision to not correct the Record. A requestor who disagrees

with the University's decision to annotate instead of correct Personal Information will

be advised of their right to ask the Commissioner to review the University's decision.

3.6

Any annotation that is made to a Record must be made in such a way that the

annotation is accessible when the Record is retrieved.

3.7

If a correction or annotation is made, the University must determine if it has disclosed

the Personal Information to a third party in the year preceding the initial request. If

so, the University should inform the third party about the correction or annotation

unless the correction or annotation is deemed to be not material and the requestor

agrees that notification is not necessary.

3.8

If there is disagreement with the accuracy of the Personal Information and the Unit

believes the information, they have is accurate, the file must be annotated to show

that the individual disagrees with the information contained in the Record.

DEFINITIONS

(1)

Act, the:

means the Freedom of Information and Protection of

Privacy Act (FOIP) of Alberta

(2)

Commissioner:

means the Information and Privacy Commissioner of

Alberta appointed in accordance with the Act

(3)

Employee:

means individuals who are engaged to work for the

University under an employment contract, including but

not limited to faculty, staff, exempt, casual and

management employees

(4)

IMPA:

means the University’s Information Management &

Privacy Advisor

(5)

Personal Information:

means recorded information about an identifiable

individual, including:

a. the individual’s name, home or business

address or home or business telephone

number,

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b. the individual’s race, national or ethnic origin,

colour or religious or political beliefs or

associations,

c. the individual’s age, sex, marital status or family

status,

d. an identifying number, symbol or other

particular assigned to the individual,

e. the individual’s fingerprints, other biometric

information, blood type, genetic information or

inheritable characteristics,

f. information about the individual’s health and

health care history, including information about

a physical or mental disability,

g. information about the individual’s educational,

financial, employment or criminal history,

including criminal records where a pardon has

been given,

h. anyone else’s opinions about the individual, and

i. the individual’s personal views or opinions,

except if they are about someone else.

(6)

Policy:

means the Privacy Policy

(7)

Record:

means a Record of information in any form and includes,

but is not limited to, notes, emails, letters, images,

audiovisual recordings, documents, maps, drawings,

photographs, letters, invoices, and any other information

that is written, photographed, recorded, captured, or

stored in any manner. Notably, the definition does not

include software or any mechanism that produces or

reads records.

(8)

Unit:

Means and academic or business Unit of the University

(9)

University:

means Mount Royal University

RELATED POLICIES

•

Access to Information policy

•

Information Security policy

•

RELATED LEGISLATION

•

Freedom of Information and Protection of Privacy Act, RSA, 2000, c F-25

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RELATED DOCUMENTS

•

Request to Correct Personal Information Form

REVISION HISTORY

Date

(mm/dd/yyyy)

Description of

Change

Sections

Person who

Entered Revision

(Position Title)

Person who

Authorized Revision

(Position Title)

01/19/2022

Editorial

Related Policies

Policy Advisor

General Counsel and

University Secretary

04/20/2023

Editorial

Definitions

Policy Advisor

General Counsel and

University Secretary