PROCEDURE FOR CORRECTING/ANNOTATING PERSONAL INFORMATION
|Under ATIPPA (Section 35), individuals have a right, within statutory timelines, to formally request correction of their personal information if they believe it contains an error or omission. This right relates to the university's obligations to ensure that decisions are based on accurate information and to individuals' right of access to their own personal information.
When a person advises a unit that s/he believes personal information in a university record contains an error or omission, and they can demonstrate the information is inaccurate or incomplete, every effort should be made to accommodate the request and make the correction, within statutory timelines. If the same error is contained in records in other units of the university or has been disclosed by the university to an outside party, the other units should also be advised of the corrected information.
If the university unit disagrees with the person and maintains that its record is accurate, the file must be annotated to show that the individual disagrees with the information. In addition to providing an explanation of their refusal to correct the information, the unit must advise the individual of her/his right to file a formal request to correct personal information with the University Privacy Officer.
Formal request for correction of factual information
All formal correction requests must be submitted to the University Privacy Officer, who has statutory timelines and obligations to fulfill for all requests. Applications are available from the University Privacy Officer. An applicant whose request for correction is refused has the right to ask the Information and Privacy Commissioner to review the university's decision.
Include correction or annotation with original file
Whenever a correction or an annotation is made, the file should be set up so that the correction or annotation will always be retrieved when the original file is retrieved.
Duty to inform other organizations
If a correction or annotation is made, the University unit should determine if other units or other external organizations have received the information in the past year. If so, the unit should inform the other unit/organization about the correction/annotation. A year runs from the date the correction was requested.
When a unit receives information about a correction or annotation, it is required to make the correction on their own files, as well. Individuals or organizations not covered by the ATIPP Act are not compelled to correct/annotate their records but they must be notified by the University unit.
As normal practice, a record should be kept of all personal information disclosed to other public bodies and third parties, enabling subsequent notification of a correction or annotation to a disclosed record.