Access to Information Under PIPA

A client, who is an organization governed by the Personal Information Protection Act (PIPA), received an access request where the applicant was seeking all personal information in the organization’s custody or control. 

Working with the organization’s Privacy Officer, we helped her to understand the applicable requirements under PIPA, identify which records needed to be reviewed in response to the request, and understand the timelines that they needed to follow to comply with the request. After reviewing the records, we advised the client which records constituted the applicant’s personal information.

Given that the client was concerned about disclosing the records, we also provided advice on the records that they could potentially withhold according to the exceptions in PIPA.  We then assisted the client in providing a written response to the applicant, explaining what records would be disclosed, which records were being withheld, and the reasons for withholding the records. 

The client also wanted to understand her obligations under PIPA better so that they had the tools needed to respond to similar access requests in the future.  We were able to assist by educating them regarding the requirements in PIPA, and by providing a framework that could be used to deal with future access requests.