Access to Information Requests and Protection of Privacy

Protection of Privacy Act (POPA) and Access to Information Act (ATIA)

Lacombe County is subject to Alberta's Protection of Privacy Act (POPA) and Access to Information Act (ATIA). The POPA and ATIA aim to strike a balance between the public's right to know, and an individual's right to privacy, with regard to records and information retained by Lacombe County.

POPA and ATIA Overview

All information held by the County is subject to the POPA and ATIA. Under these Acts, you have the right to:

Request access to personal information Lacombe County has about you, or about an individual you are authorized to represent;
Request correction of personal information Lacombe County has about you, or about an individual you are authorized to represent;
Request access to all other information held by Lacombe County, subject to specific and limited exceptions;
Request an independent review be completed by the Office of the Information and Privacy Commissioner (OIPC) regarding decisions Lacombe County makes in response to a formal ATIA request; and,
File a complaint with the OIPC in relation to any issue related to the County's compliance with the POPA.

The POPA and ATIA also provides controls over Lacombe County's collection, use, and disclosure of personal information, ensuring:

Only information required for collection is collected;
Personal information collected is used only for the purpose for which it was collected; and,
Personal information is protected and only disclosed in compliance with requirements of the Acts

Accessing Information held by Lacombe County without a ATIA Request

General Information Access

Lacombe County aims to be as transparent as possible regarding the information it holds, and as such, routinely discloses information deemed to be of public interest through various means, including:

Publishing information to the County's website;
Publishing information in the County News newspaper;
Publishing information through the County's social media accounts (including Twitter, Facebook, YouTube, and Instagram); and,
Processing informal information requests received in-person, by telephone, through mail, or by email.

Lacombe County encourages information access requests be processed through the above means when possible and makes every effort to ensure the pro-active release and dissemination of information, minimizing the need to request information through the formal ATIA request process.

Personal Information Access

If you are requesting personal information, either for yourself or for a person you are authorized to represent, your identity will need to be authenticated (i.e., the County will need to confirm that you are who you say you are, and that you have a right to access the records requested).

The County has a formal and documented process for authenticating identity for release of information. In summary, the authentication process requires the County to collect identifying information about you to match with the information we hold on file, this enables staff to confirm that you are who you say you are, and that you have a right of access to the personal information requested.

PLEASE NOTE: Depending on the context of the request, fees may be required for processing informal information requests.

Before Submitting a ATIA Request

Before submitting an ATIA request, you are encouraged to contact the County to ensure the information you seek is not available through informal access channels, as noted above.

It is also important to identify the correct public body to request records from before submitting the request. An ATIA request should be submitted to the public body responsible for maintaining the information you seek, as transferring your request will cause unnecessary processing delays.

If you are not sure if Lacombe County has the information you need, contact the County to confirm whether the information you seek is available within the County's record holdings. If the County does not have the information you seek, they may be able to refer you to the correct organization.

Submitting a ATIA Request

If you determine the need to proceed with a formal ATIA request, you will need complete an Access to Information Request Form and submit it by physical mail or fax to the address or fax number provided on the County's website contact page , or by email.

You will also need to know if you are submitting a personal access request, or a general access request. The information provided below will help you determine the type of request you need to submit, as well as highlight the basic fee requirements associated with each request type:

Personal Access Requests

A Personal Access Request is a request for access to records that contain personal information about yourself, or about an individual you are authorized to represent.

When your own personal information is requested, your identity must be authenticated before any requested records are disclosed. If information is requested on behalf of another individual, you must provide proof of your authorization to represent the individual before any records will be disclosed.

There is no fee for requesting personal information unless the cost of producing copies exceeds $10.

General Access Requests

A General Access Request is a request for access to records that are not the personal information of the applicant. A general access request requires payment of a $25 application fee, and processing of the request will not begin until the application fee is received.

Additional fees may also be required for a general access request if the total fee for completing the request is estimated to be greater than $150, in which case the applicant will be notified and asked to pay a 50% deposit prior to processing.

When the request is completed the applicant will be notified of the total costs for processing and will be required to pay any balance due before the requested records are disclosed.

Completing the Request to Access Information Form

Detailed instructions on how to complete the Access to Information Request Form are provided within form. In summary, you will need to:

Provide your name, address, and a telephone number where you can be contacted in case there are any questions about the request;
Specify whether it is a personal information request, or a general information request;
Be as specific as possible when describing the records you want to access (e.g. provide sufficient detail as to the subject of the request; include names of all known parties involved; provide date(s) (or date ranges) of records requested);
If the request is for general information (not your own personal information), include the $25 request fee. This fee must be paid before the request will be processed;
If you are requesting your own personal information, or personal information of an individual you are authorized to represent, be sure to provide the full name of the individual, as well as any alternate names that have been used in the past (e.g. maiden names, nicknames, aliases);
Sign and date the form;
Submit the completed form to the County for processing.

ATIA Request Fees and Response Details

The fees and response timelines associated with ATIA requests are established in Alberta's Access to Information Act Regulation.

When to Expect a Response to an ATIA Request

The County is required to respond to an ATIA request within 30 calendar days of receiving the request, however efforts will be made to respond to the request as soon as possible.

The 30-day deadline may be approved for extension if, for example, a large volume of information is required, or if third party consultation is required prior to processing the request.

PLEASE NOTE: a request is deemed to be received on the first business day after the request was submitted, however a “general information” request is not deemed to be received until the $25 request fee has been paid.

What to Expect in Response to an ATIA Request

In response to an ATIA request you will either receive the information you requested or receive an explanation as to why the information is not being disclosed. You may also receive severed documents where information has been redacted to allow disclosure of the remaining information, in this case details on the redacted information will also be provided.

Requesting Correction of Personal Information

There are two means in place to request correction of personal information held by Lacombe County, these include routine and formal change requests. The processes for each are outlined below:

Routine Changes or Corrections to Personal Information

Routine changes or corrections to personal information (such as a new address or phone number, or a change of name) do not require a formal correction request to be submitted under the POPA and ATIA Acts, simply contact the County to inform of the change or correction.

PLEASE NOTE: depending on the change requested, there may be a process in place requiring written confirmation of the change (e.g. change of address form).

Formal Requests for Correction of Personal Information

Under the POPA Act, a formal request for correction of personal information can be submitted if you believe personal information the County holds about you, or about an individual you are authorized to represent, is false or misleading. You can formally request correction of personal information by submitting a Request to Correct Personal Information Form to the County.

In the event the County agrees with the request for correction, the information will be corrected.

In the event the County does not agree with the request for correction, the information will not be corrected, however the request for change will be documented on your file, as required by the Act.

Completing the Request to Correct Personal Information Form

Detailed instructions on how to complete the Request to Correct Personal Information Form are provided within form. In summary, you will need to:
Provide your name, address, and a telephone number where you can be contacted in case there are any questions about the request;
Identify the information you believe is incorrect and provide the correction. This information must be as specific as possible;
Sign and date the form;
Send the completed request form to the County.

What to Expect in Response to a Request to Correct Personal Information

In response to a request for correction of personal information you will either receive confirmation that the correction was made, or you will be advised that the record was not corrected, but was annotated.

Requesting a Review or Filing a Complaint

If you submit an ATIA request and disagree with the response received from Lacombe County, or if you have a complaint regarding the County's information management practices, you may request a review or file a complaint with the Office of the Information and Privacy Commissioner of Alberta (OIPC). If requesting a review, the request must be submitted to the OIPC within 60 days of a decision being made by the County.

Accessing Information Outside of the POPA and ATIA Acts

Examples of information that can be accessed outside of the POPA and ATIA Acts are provided below:

Information accessible outside of the POPA and ATIA Acts

Document Type	Release Requirements	Access Means
Agreements and Contracts	Agreements and contracts are generally available for public disclosure, however information may be redacted from the document as information deemed harmful to the business interests of a third-party and proprietary information is protected under the Act.	If the information is expected to be released in non-severed form, third-party consent for release by all parties named in the agreement or contract must be collected and provided to the County prior to release.
Assessment Roll	Section 307 of the Municipal Government Act provides that “any person may inspect the municipal assessment roll during regular business hours on payment of the fee set by the council”	The assessment roll is made available for physical inspection at the Lacombe County office. This information is available for physical review only, and copies cannot be made. Fees are charged when time spent viewing the roll exceeds 30 minutes.
Cemetery Records	The POPA Act provides that personal information of deceased individuals is protected under the Act until the individual has been deceased for more than 25 years.	Disclosure of information related to deceased individuals will be limited to the information that is made publicly available on the cemetery headstone. Limited and specific exceptions may be made in extenuating circumstances.
Contact Information for Residents (requested for service of documents, collection of debt, or other legal matters).	The POPA and ATIA Acts only permits this information to be disclosed if another piece of legislation permits disclosure (e.g. Maintenance Enforcement Act).	If you are permitted access to this information by legislative authority the authority to collect the information must be included with your request, and a written request is required in the form of business correspondence.
Complaint Records	The County's practice is to protect the personal information of individuals who file complaints with the County unless the information is required to resolve the issue (e.g. disclosed for legal purposes).	Documented complaint records may be accessed by the person who submitted the complaint (the complainant), however information about the complainant will not be released to the individual(s) the complaint is about.
Tax and Utility Account Information	If you are not the registered owner of the subject property, or named on the account, written permission to access these records is required from the registered owner, or from an individual named on the account.	Tax and utility account information can be requested in-person, by telephone, or by email.

Personal Information Banks (PIB) Directory

Under the Protection of Privacy Act (POPA), all public bodies in Alberta must publish a directory that lists the public body’s personal information banks.

A personal information bank (PIB) identifies what information about an identifiable individual is held by a public body. It provides a summary of the information available at Lacombe County, why it is collected, and how it is used.

Under the Protection of Privacy Act, a PIB directory must include:

The title and location of the PIB.
A description of the kind of personal information and the categories of individuals whose personal information is included.
The authority for the collection of personal information.
The purposes for which the personal information was collected or compiled, and the purposes for which it is used or disclosed.

Important: A PIB does not include any individual’s personal information or provide direct access to an individual’s records or information. A PIB only describes the type of personal information held by Lacombe County.

Access to Information Act Requests

PIB #:	1
Location:	Privacy and Access Coordinator’s Office.
Information Maintained:	Name (including former names of the person making the request), address, telephone numbers, description of information requested and/or reasons for and evidence to correct information, fees paid, banking information, correspondence and copies of requested records.
Individuals:	Individuals submitting requests under the Act, including individuals acting on behalf of another person (third parties).
Use:	Respond and process requests, compile statistics.
Legal Authority:	Access to Information Act Protection of Privacy Act

Business Representatives

PIB #:	2
Location:	Various offices in Lacombe County’s Administrative Building, Shop Building, or Remote Building Locations.
Information Maintained:	Business contact information – Name, address, telephone number and/or cell phone number, fax number, email address, title, company/organization name.
Individuals:	Individuals who represent organizations registered in a program administered by the business unit.
Use:	To contact the business representative with respect to any issue concerning the organization.
Legal Authority:	Protection of Privacy Act

Bylaw Enforcement and Investigations

PIB #:	3
Location:	Community Peace Officer Services.
Information Maintained:	May include name, address, telephone numbers, email addresses, complaint details, investigation notes, witness statements, photographs, enforcement actions, fines, and correspondence.
Individuals:	Individuals involved in bylaw complaints, investigations, or enforcement activities.
Use:	To investigate complaints, enforce municipal bylaws, and administer enforcement proceedings.
Legal Authority:	Municipal Government Act Protection of Privacy Act

Cemetery Records

PIB #:	4
Location:	Various offices or vaults in Lacombe County’s Administrative Building.
Information Maintained:	Name, address, telephone numbers, email addresses, interment records, next of kin, plot ownership, and payment records.
Individuals:	Individuals who own or purchased a plot at a cemetery managed by Lacombe County.
Use:	To administer cemetery plot ownership, interment records, related services, and associated payments.
Legal Authority:	Municipal Government Act Protection of Privacy Act

Contract Management System

PIB #:	5
Location:	Various offices in Lacombe County’s Administrative Building, Shop Building, or Remote Building Locations.
Information Maintained:	Name, address, telephone numbers, email addresses, banking information, and fee amount. May include information regarding procurement or vendor competition records such as sole proprietor information, evaluation committee notes, bid submissions, references, and conflict declarations.
Individuals:	Individuals who are under contract or agreement to provide products or services to Lacombe County.
Use:	To manage the contract or agreement arrangements of payments upon delivery of products or services.
Legal Authority:	Municipal Government Act Protection of Privacy Act

Correspondence / Action Request Tracking

PIB #:	6
Location:	Various offices in Lacombe County’s Administrative Building, Shop Building, or Remote Building Locations.
Information Maintained:	May include name, address, telephone numbers, and email addresses, other personal information included by the originator within the content of the correspondence including opinions or comments.
Individuals:	Individuals requesting information or a response from a public body senior executive.
Use:	To manage receipt of and responses to correspondence, inquiries, and briefings.
Legal Authority:	Access to Information Act Protection of Privacy Act

Council and Elected Official Administration

PIB #:	7
Location:	Various offices in Lacombe County’s Administrative Building.
Information Maintained:	May include contact information, remuneration and expense records, training and conference registrations, disclosure statements, appointment records, constituent correspondence.
Individuals:	Councillors or Elected Officials of Lacombe County.
Use:	To administer Council operations, remuneration, expense reimbursements, appointments, training, and official communications.
Legal Authority:	Municipal Government Act Protection of Privacy Act

Development, Planning, and Permit Applications

PIB #:	8
Location:	Various offices in Lacombe County’s Administrative Building.
Information Maintained:	May include name, home and mailing addresses, telephone numbers, email addresses, property ownership information, site plans, permit applications, inspection records, and correspondence relating to development or land use matters.
Individuals:	Property owners, applicants, contractors, and individuals participating in development or planning processes.
Use:	To administer development permits, subdivision applications, inspections, and land use planning processes.
Legal Authority:	Municipal Government Act Protection of Privacy Act

Emergency Management and Fire Services

PIB #:	9
Location:	County Fire and Emergency Management Services.
Information Maintained:	May include name, address, telephone numbers, emergency contact information, incident reports, response records, evacuation information, and emergency planning records.
Individuals:	Individuals involved in or affected by emergency management activities or fire services responses.
Use:	To prepare for, coordinate, and respond to emergency situations and protective services incidents.
Legal Authority:	Emergency Management Act Protection of Privacy Act

Employee Directories

PIB #:	10
Location:	Various offices in Lacombe County’s Administrative Building, Shop Building, or Remote Building Locations.
Information Maintained:	Name, office telephone numbers, office name and address, email address, and position title.
Individuals:	Employees of Lacombe County.
Use:	Directing calls, visitors, and mail to appropriate staff.
Legal Authority:	Protection of Privacy Act

Employee Files

PIB #:	11
Location:	Human Resources Offices.
Information Maintained:	May include name, birth date, gender, social insurance number, home and office addresses, telephone numbers, employment authorization, email addresses, employee identification number, resume/application for employment, official oath, education, employment history, appointment records, performance appraisals, employee relations, attendance records, pay and benefits information, staff development and training, learning accounts, occupational health and safety, employee assistance, medical board records, health and life insurance records, employee conflict of interest disclosure statements, grievances, recognition awards, job classification, professional association memberships and certifications, security clearance, parking/building passes, employee authentication log-on, and other personal data related to employment.
Individuals:	All Lacombe County employees.
Use:	Record the employee’s work history and payroll/benefit transactions. NOTE: Employee files are in partitioned formats that limit access to only those staff who have a need to access specific information.
Legal Authority:	Alberta Human Rights Act Canadian Charter of Rights and Freedoms Employment Standards Code Protection of Privacy Act

Expense Claims

PIB #:	12
Location:	Finance Department.
Information Maintained:	May include name, organizational unit, mailing address, telephone numbers, employee number, classification/ occupation, kilometers travelled, purpose of travel, and other expenses claimed.
Individuals:	Lacombe County employees and non-employees (i.e. contracted staff, job applicants) submitting a personal expense claim.
Use:	To process expense claims.
Legal Authority:	Employment Standards Code Protection of Privacy Act

Financial Management

PIB #:	13
Location:	Finance Department.
Information Maintained:	Name, address, telephone numbers, email addresses, financial information, amount paid or outstanding.
Individuals:	Individuals who pay or owe money to Lacombe County.
Use:	To collect outstanding revenue or repay overpayments.
Legal Authority:	Municipal Government Act Protection of Privacy Act

Health and Safety / Incident Reporting

PIB #:	14
Location:	Various offices in Lacombe County’s Administrative Building, Shop Building, or Remote Building Locations.
Information Maintained:	Name, address, telephone numbers, email addresses, workplace incident reports, WCB documentation, hazard investigations, and OH & S reporting.
Individuals:	Individuals involved in workplace incidents, hazards, WCB claims, or occupational health and safety reporting activities.
Use:	To track health and safety related matters at Lacombe County.
Legal Authority:	Occupational Health and Safety Act Protection of Privacy Act Workers’ Compensation Act

Information Technology and Systems Access

PIB #:	15
Location:	Information Technology.
Information Maintained:	May include usernames, employee identification numbers, login credentials, system access logs, device identifiers, internet usage records, and network activity information.
Individuals:	Employees, contractors, and authorized system users.
Use:	To administer, secure, monitor, maintain, and investigate municipal information technology systems, networks, and security incidents.
Legal Authority:	Protection of Privacy Act

Insurance Claims and Legal Matters

PIB #:	16
Location:	Various offices in Lacombe County’s Administrative Building.
Information Maintained:	May include name, address, telephone numbers, email addresses, claim details, incident reports, witness statements, legal correspondence, settlement information, and supporting documentation.
Individuals:	Individuals involved in insurance claims, legal actions, or liability matters involving Lacombe County.
Use:	To investigate, manage, and resolve insurance claims and legal matters.
Legal Authority:	Municipal Government Act Protection of Privacy Act

Job Competitions

PIB #:	17
Location:	Human Resources Offices.
Information Maintained:	May include name, home and office addresses, telephone numbers, application form, resume, references, samples of work, job advertisement, screening and evaluation results, and appointment of successful candidate.
Individuals:	Applicants for Lacombe County jobs.
Use:	Document the hiring process and provide statistical data.
Legal Authority:	Employment Standards Code Protection of Privacy Act

Municipal Election Administration

PIB #:	18
Location:	Director of Corporate Services, Administrative Assistant to the Director of Corporate Services, and Lacombe County vaults.
Information Maintained:	Candidate nominations, elector records, campaign disclosure filings, voter assistance records, and recount materials.
Individuals:	Candidates, electors, and individuals participating in municipal election processes.
Use:	To administer and document municipal election processes and results.
Legal Authority:	Local Authorities Election Act Protection of Privacy Act

Property Taxation and Utility Accounts

PIB #:	19
Location:	Various offices in Lacombe County’s Administrative Building.
Information Maintained:	May include name, mailing and service addresses, telephone numbers, email addresses, roll numbers, account numbers, payment history, banking information, tax arrears, utility consumption and billing information.
Individuals:	Property owners, utility account holders, and individuals responsible for payment of municipal taxes or utilities.
Use:	To administer property taxation, utility billing, collections, and customer account services.
Legal Authority:	Municipal Government Act Protection of Privacy Act

Stakeholder / Contact Lists

PIB #:	20
Location:	Various offices in Lacombe County’s Administrative Building, Shop Building, or Remote Building Locations.
Information Maintained:	Name, address, telephone numbers, and email addresses. May include opinions / comments, survey responses, meeting attendance, submissions regarding municipal projects or bylaws.
Individuals:	Individuals receiving correspondence, information, or publications relating to programs or services delivered by Lacombe County.
Use:	Disseminate information or publications to interested individuals or to individuals participating in consultations or government programs.
Legal Authority:	Protection of Privacy Act

Surveillance and Security Systems

PIB #:	21
Location:	Third-party security management office.
Information Maintained:	May include video recordings, photographs, access control logs, identification information, vehicle information, and dates and times of entry to municipal facilities.
Individuals:	Employees, contractors, visitors, and members of the public accessing municipal facilities or properties.
Use:	To maintain the safety and security of municipal facilities, employees, assets, and the public.
Legal Authority:	Municipal Government Act Occupational Health and Safety Act Protection of Privacy Act

Still Have Questions?

Still have questions about requesting information from Lacombe County? Contact the County's Privacy Coordinator by email or by telephone at 403-782-6601.