Alberta Record

· Bill / Data matching and privacy changes · tabled

Bill 11 — Expanded Data Matching Capabilities for Health Information

This bill expands the ability of health custodians and repositories to perform data matching, including with non-custodians, while requiring privacy impact assessments for such activities.

Low impactPrivacy & surveillanceCentralization of powerHealth-care bodiesThe public, directlyIndependent watchdogs

What changed

  • Repeals and substitutes Section 69, explicitly allowing custodians or health information repositories to perform data matching using information in their custody or control.
  • Repeals and substitutes Section 70, allowing data matching by custodians or repositories by combining information in their custody with information from other custodians or health information repositories.
  • Repeals and substitutes Section 71, allowing data matching by custodians or repositories with information from persons that are not custodians or health information repositories.
  • Requires a privacy impact assessment (PIA) to be prepared and submitted to the Commissioner before performing data matching, with specific requirements for the PIA content (new Sections 70(4), 70(5), 71(4), 71(5)).

Why it matters

  • Expands the scope of data matching, enabling more extensive linkage of health information across various entities, including those outside the traditional health care system.
  • Increases the potential for secondary uses of personal health information, raising concerns about privacy and the aggregation of sensitive data.
  • While requiring PIAs, the fundamental expansion of data matching capabilities without explicit individual consent for each match represents a significant shift in privacy governance.

Rights affected

  • Privacy — Control over personal information held by governments and institutions.

Other governance concerns

  • Increased data linkage and aggregation
  • Potential for privacy breaches and misuse of data
  • Scope of data matching with non-custodians

Primary sources (1)

Secondary sources (2)