Signatures provided in professional capacity must be released

Complaint: The Privy Council Office exempted as personal information under subsection 19(1) the signatures and initials of various senior public servants on correspondence and routing slips related to a briefing note for the Prime Minister.

Investigation: The OIC found that the individuals had provided their signatures to authenticate that they had viewed and approved the briefing note in their professional capacity.

Outcome: Although PCO did not accept the Information Commissioner’s recommendation to release the signatures, it later released most of them with the consent of the individuals in question.

Information Commissioner’s position

  • While a signature is information about an identifiable person, the signature of a government employee provided in the course of official functions falls within the exception to the definition of personal information found in paragraph 3(j) of the Privacy Act.
  • The presence or absence of signatures or initials is an important piece of information in the context of government accountability.
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