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TitleGuide to Identifying Personal Information Banks
File Size96.4 KB
Total Pages13
Table of Contents
Purpose of this Guide
What is a Personal Information Bank?
How to Identify Personal Information Banks
What Information to Provide
Commonly Asked Questions
	Example #3
		Example #4
Document Text Contents
Page 1

Guide to Identifying
Personal Information Banks

Revised April 2004

Page 2

ISBN 0-7785-2089-7

Produced by:

Access and Privacy
Service Alberta

3rd Floor, 10155 - 102 Street
Edmonton, Alberta, Canada T5J 4L4

Office Phone: 780-422-2657

Fax: 780-427-1120

FOIP Help Desk: 780-427-5848
Toll free dial 310-0000 first

E-mail: [email protected]


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Guide to Ident i fy ing Personal Informat ion Banks

information about the individual’s health and health care history, including information
about a physical or mental disability,

information about the individual’s educational, financial, employment or criminal history,
including criminal records where a pardon has been given,

anyone else’s opinions about the individual, and

the individual’s personal views or opinions, except if they are about someone else.

This list is not exhaustive. Rather, it includes common types of information that is considered
personal. Any information that can be associated with a specific individual would also be
considered personal information.

2. Does the “personal information” take the form of a “collection?”

The Oxford English Dictionary defines collection as “a group of things collected together,
especially systematically.” In the context of records containing personal information, the number
of records should not be the criteria. Here are some general types of “collections” that illustrate
the range of collections of personal information that may support operations of your organization:

applications or registrations for benefits or services

client or customer files and databases

membership lists, mailing lists and contact databases

licensing applications and certificates

program participation information

investigations, inspections, audits, claims adjudication

A collection can also include records in multiple media, such as pictures, audiotapes, videotapes,
print and electronic media.

3. Is the collection of personal information organized or retrievable by the
name of an individual or by an identifying number, symbol or other
particular assigned to an individual?

In practice, this means the information has to be organized or retrievable by name, health card
number, driver’s license number, student identification number or some other unique identifier.

In many cases, client files are organized by client number or the name of the client. These files
are both organized and retrievable from filing cabinets by the unique identifier (i.e. client number
or client name) and would be considered a personal information bank. For example, a database
of registrants for a training program that contains a person’s name and telephone number, where
each number is associated with a specific name, is both “organized” and “retrievable” by the
person’s name and is considered a PIB. Another example might be a list of “sign-in” sheets at
secure buildings. These lists often include the names of individuals and the time the person

4 Revised Apr i l 2004

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Guide to Ident i fy ing Personal Informat ion Banks

enters and exits the building. While the list is not in alphabetical order, it is organized by name (as
a column on the sheet).

Most electronic databases can be searched by any data field, including name or an identification
number. In some electronic databases personal information is incidental or not the main purpose
of the database. For example, an inventory of computer equipment will list manufacturers, model
numbers, peripherals, software, warranties etc. It may also include the computer user’s name.
Such a database is not required to be listed as a personal information bank.

Figure 1 below is a decision chart that can help you identify personal information banks in your

Figure 1
Identifying personal information banks






Do the records
contain personal

The collection of
records is not a
Personal Information

Are the records
organized by name,
symbol or other
unique identifier
assigned to an

Is the personal
information retrievable
by name, symbol or
other unique identifier
assigned to an


The collection of
records is not a
Information Bank.

The collection of records form a
Personal Information Bank

Revised Apr i l 2004 5

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Guide to Ident i fy ing Personal Informat ion Banks

Example #4

Alberta Registries of Service Alberta maintains vital statistic records. There is a wide
range of personal information in the collection, and the personal information is
retrievable by a person’s name. While the information is maintained as a single
collection, the authority to collect the information is based on a number of Acts. Here
is how this PIB could be described in the directory.

Title: Vital Statistics registration records.

Location: Alberta Registries.

Information maintained: Names (including former names), citizenship, date and
place of the event, family history, information pertaining to death, length of
residence, mailing address, marital history, medical information, occupation, place of
residence, registration date and number, religion, sex.

Individuals: Persons born, married, authorized to solemnize marriage, deceased,
stillborn, changing their name or sex or declaring parentage in Alberta.

Use: Register and record Alberta births, deaths, marriages, persons authorized to
solemnize marriage, stillbirths, name changes, record corrections, amendments, sex
changes and court orders regarding parentage; compile, publish and distribute
statistics; and provide certified copies, extracts, certificates and search notices for
research, medical and law enforcement purposes.

Legal authority: Vital Statistics Act, Marriage Act, and Change of Name Act

5. When would a public body have “per sonal information” that would not
be considered a PIB?

Many public bodies have files that may contain “personal information” such as names, addresses,
and phone numbers, but which are not organized or searchable by a personal identifier. Because
these collections do not meet all three criteria discussed earlier, they are not PIBs.

For example, there might be a collection of paper files containing research results that include a
contact person. The files are organized by the ten individual research studies, and are not
searchable by the contact’s name. This would not be considered a PIB, although there is
“personal information” maintained which must be safeguarded as personal information.

Sometimes, personal information in paper records is not considered a PIB because the
information is neither organized nor retrievable by the individual’s name or other unique
identifier. However, if the information has been entered into a computer system, it may
become retrievable by an individual’s name or unique identifier. In these cases, the
electronic collection of information may be considered a personal information bank. An
example of this is illustrated in Example #5.

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Guide to Ident i fy ing Personal Informat ion Banks

Example #5

Alberta Finance and Enterprise manages the collection of taxes and certain
receivables on behalf of the province. As part of the administration of the Hotel
Room Tax, tax returns are stored in paper records and organized by the name of the
hotel filing the tax return. While the collection of records (i.e. files) contains the
personal information (for example, the names, addresses and financial information of
hotel owners), the collection of personal information is not organized or retrievable
by an individual’s unique identifier. Thus, the paper records of the tax returns are not
a PIB.

However, certain information in the tax return, including the names and financial
information of hotel owners, is entered into a computer system. While information in
the paper files is not organized by individual or retrievable by an individual’s name or
identifier, the computer system allows for a search, by individual, of hotel properties
owned in the province. In this case, the paper records would not be considered a PIB.
However, the computer database is considered a PIB because the personal
information is retrievable by an individual’s name.

Please note that the public bodies and PIBs cited in the above examples are for illustrative
purposes only. For current information about a public body’s personal information banks, contact
the public body’s FOIP Coordinator. Contact information is available on the FOIP website at

Revised Apr i l 2004 11

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