Records about attendance at mandatory training are not personal information

Complaint: The Royal Canadian Mounted Police (RCMP) withheld in their entirety under subsection 19(1) records about the attendance of a newly commissioned inspector at the RCMP’s Officer Orientation and Developmental Course.

Investigation: The RCMP stated that the information sought (the dates of the inspector’s attendance, the complete list of courses, and the names of all the facilitators and any others in attendance), in conjunction with the name, rank and employee identification number of regular members of the RCMP, constituted personal information, as described in section 3 of the Privacy Act. However, the course was mandatory for newly commissioned officers.

Outcome: After a formal request from the Information Commissioner to justify its position, the RCMP agreed to release the information.

Information Commissioner’s position

  • The fact that a member had attended this course is not personal information, since the training was mandatory and therefore related to the position or functions of an individual who is an employee of a government institution. This constitutes an exception to subsection 19(1), as per paragraph (3)(j) of the Privacy Act.
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