Procedure for Reviewing Personal Information – March 26, 2026
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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:
March 26,
2026
Primary
Contact:
The Access and
Privacy Office
Review
Scheduled:
March 26,
2031
Approver:
Executive Leadership Team
A.
PROCEDURES
1.
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
Department(s) who hold the Record directly or by submitting a formal request to the
Access and Privacy Office.
1.3
An individual who requests to review their Personal Information will be required to
authenticate their identity prior to having their request processed.
2.
INFORMAL CORRECTION OF PERSONAL INFORMATION
2.1
Upon receipt of an informal request to correct Personal Information, the Department
may correct the information if it is satisfied that the Record contains an error or
omission.
2.2
If the Department is aware that other Departments may hold Records containing a
similar error or omission, they must notify those other Departments of the
request. The other Departments will determine if the request impacts the Records
they hold.
2.3
If a Department does not correct the Personal Information, it will notify the individual
and advise them of their right to submit a formal request to correct their Personal
Information to the Access and Privacy Office.
3.
FORMAL CORRECTION OF PERSONAL INFORMATION
3.1
All formal correction requests must be submitted through a Request to Correct
Personal Information Form to the Information Management & Privacy Advisor (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.
Procedure for Reviewing Personal Information – March 26, 2026
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3.2
The IMPA, in consultation with the Department who holds the Record, will review
the request, and determine whether a correction or annotation will be made to the
Record.
3.3
A Record will be corrected where:
a. the Record contains an error or omission concerning the Personal Information;
b. the Personal Information to be corrected must belong to the individual requesting
the correction; and
c. the Record does not contain an opinion about the individual, including a
professional or expert opinion in accordance with applicable privacy legislation.
3.4
The University will provide its final response to a formal request to correct the
Personal Information within 30 business 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 containing Personal Information 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 in accordance with the parameters outlined
under the Act
3.8
If there is disagreement with the accuracy of the Personal Information and the
Department 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.
B.
DEFINITIONS
(1)
Access and Privacy
Office:
means the Information Management & Privacy Advisor
and/or Senior Leaders of the Access & Privacy Office
as delegated by the President in writing.
(2)
Act, the:
means the Protection of Privacy Act of Alberta. Also
known as the “POPA” or the Act.
(3)
Commissioner:
means the Information and Privacy Commissioner of
Alberta appointed in accordance with the Act.
Procedure for Reviewing Personal Information – March 26, 2026
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(4)
Department:
means a faculty within the Academic Division or a
department outside of the Academic Division.
(5)
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.
(6)
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,
b. the individual’s race, national or ethnic origin,
colour or religious or political beliefs or
associations,
c. the individual’s age, marital status or family
status,
d.
the individual’s gender identity, sex or sexual
orientation,
e. an identifying number, symbol or other
particular assigned to the individual,
f. the individual’s fingerprints, other biometric
information, blood type, genetic information or
inheritable characteristics,
g. information about the individual’s health and
health care history, including information about
a physical or mental health,,
h. information about the individual’s educational,
financial, employment or criminal history,
including criminal records where a pardon has
been given,
i. anyone else’s opinions about the individual, and
j. the individual’s personal views or opinions,
except if they are about someone else.
(7)
Policy:
means the Privacy Policy.
(8)
Record:
means any electronic record or other record in any form
in which information is contained or stored, including
information in any written, graphic, electronic, digital,
photographic, audio or other medium, but does not
include any software or other mechanism used to store
or produce the record.
(9)
University:
means Mount Royal University.
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C.
RELATED POLICIES
● Access to Information policy
● Information Security policy
● Privacy policy
D.
RELATED LEGISLATION
● Protection of Privacy Act, SA, 2024, c P-28
●
Access to Information Act, SA, 2024, c A-1.4
E.
RELATED DOCUMENTS
● Request to Correct Personal Information Form
F.
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
03/26/2026
Major
All
Information
Management &
Privacy Advisor
Executive Leadership
Team