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OPC issues Interpretation Bulletin on sensitive information

May 16, 2022

The Office of the Privacy Commissioner of Canada (OPC) has issued an Interpretation Bulletin dealing with the issue of sensitive information, as noted when it updated guidance documents relating to the kinds of information considered sensitive under the Personal Information Protection and Electronic Documents Act (PIPEDA).

While under PIPEDA any personal information can be sensitive depending on the context, certain types of personal information will generally be considered sensitive because of the specific risks to individuals associated with the collection, use or disclosure of these categories of information.

Health and financial data, ethnic and racial origins, political opinions, genetic and biometric data, an individual’s sex life or sexual orientation, and religious/philosophical beliefs are among the types of information that will generally be considered sensitive and require a higher degree of protection. PIPEDA requires that the safeguards organizations put in place to protect personal information be appropriate to the sensitivity of the information.

The OPC creates interpretation bulletins in an effort to summarize the general principles that have emerged from court decisions and the Commissioner’s findings on particular issues. These Interpretations are not binding legal interpretations, but rather, are intended as a guide for compliance with PIPEDA. As the Commissioner issues more findings, and the courts render more decisions, these Interpretations may evolve and be further refined.

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