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
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
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.
2.
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.
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 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.
Procedure for Reviewing Personal Information
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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.
B.
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,
Procedure for Reviewing Personal Information
– June 11, 2021
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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
C.
RELATED POLICIES
• Access to Information policy
• Information Security policy
• Privacy policy
D.
RELATED LEGISLATION
• Freedom of Information and Protection of Privacy Act, RSA, 2000, c F-25
Procedure for Reviewing Personal Information
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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