Complaint: The Department of Justice Canada withheld information under section 19 when responding to a request for all records related to surveys responses of beneficiaries of a fund for victims of crime.

Investigation: The OIC learned that most of the information withheld as personal was exempted because it was handwritten.

Outcome: In response to a request from the OIC, the institution severed the records and only withhold information such as names of individuals, dates, details of crimes and family particulars that could lead to the individuals who had completed the survey being identified.

Information Commissioner’s position:

• For records to qualify as personal information, they have to be linked to an identifiable individual. In this case, the handwriting in itself could not reveal the individuals’ identity.
• Section 25 states that institutions must sever records to facilitate the release of as much information as possible. Access personnel should keep this obligation in mind when reviewing records.