Legislative Unit regarding Manitoba Health, Seniors and Active Living.
Read NAID-Canada’s Submission on FIPPA Review _____________________________________________
May 23, 2017
130 – 200 Vaughan Street
Winnipeg, Manitoba, R3C 1T5
Dear Sir or Madam:
On behalf of the National Association for Information Destruction – Canada (NAID-Canada), thank you for the opportunity to
comment on the review of the Freedom of Information and Protection of Privacy Act (FIPPA).
Our Association is primarily concerned with the issue of safe information destruction, which is critical to the protection of
personal privacy. Therefore, our comments are confined to those portions of the Act that deal with privacy protection. Our
main concern is that FIPPA does not include a specific destruction requirement or a definition of information destruction.
We will return to these points shortly. First, however, please find below some background on NAID-Canada and the importance
of safe information destruction.
NAID-Canada is the national non-profit association representing companies that specialize in secure information and
document destruction. NAID-Canada’s mission is to raise awareness and understanding of the importance of secure
information and document destruction. In doing so, we want to ensure that private, personal and business information
is not used for purposes other than originally intended. NAID-Canada also plays an active role in the development and
implementation of industry standards and certification and provides a range of member services which include advocacy,
communication, education and professional development.
Many organizations have recognized the tremendous liability issues that surround the disposal of personal information,
particularly given the sustained public and media interest in issues around privacy breaches and notification of the same.
NAID-Canada members, made up of companies in the information and document destruction industries, offer their customers
peace of mind when it comes to the destruction and disposal of sensitive personal or business information.
Why Destroy Information?
As the Government reviews FIPPA, NAID-Canada wants to draw attention to a vital fact that is often overlooked when
discussing personal privacy protection: documents are only as secure as the weakest link in their lifecycle.
Our Association focuses on the end of a document’s lifecycle and the need for secure destruction practices. Unsafe
destruction presents one of the most serious threats to personal privacy, yet is one of the simplest to address. It is also one
that affects just about every aspect of day-to-day work.
Unsafe information destruction is a recurring problem. There are regular media reports about personal information being left
in dumpsters or recycling bins, or sensitive files being left on old computers or other discarded electronic equipment.
The negative impact on an individual from such a breach can be financial, emotional and even psychological. The incidents
that make the news are only the tip of the iceberg. On any given day, it would not take long to find personal information being
discarded intact and accessible to the public.
In October 2010, for example, NAID-Canada released the results of an audit into information destruction practices in the
Greater Toronto Area (GTA). That audit found that 14% of commercial dumpsters in the GTA contained confidential personal
information – a shockingly high number. The results for some specific sectors were damning. Of the doctors’ offices examined,
75% had left personal information in their publicly accessible dumpsters. For car dealerships, it was 100%.