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This investigation was initiated as a result of a complaint concerning the Ministry of Health (the Ministry).
The complainant was concerned that the Ministry had disclosed her personal information to the Ontario Breast Screening Program (the OBSP) contrary to the provisions of the Freedom of Information and Protection of Privacy Act (the Act).
The complainant had received a letter from the OBSP about a breast screening program. In this letter, the Director of the OBSP suggested that since the complainant was of "a certain age", she should be aware of certain facts about health risks. The Director also stated: "Your name was selected in a confidential manner using your Health Number and your age".
The OBSP had asked the Ministry to perform a mailing to women between the ages of 50 and 69, to make them aware of, and to invite them to, local breast screening clinics. The Ministry had set up a "confidentiality agreement" with Canada Post to perform the mailing from a listing that the Ministry had provided for four test sites. The listing provided to Canada Post consisted of the names and addresses of women who were between the ages of 50 and 69.
The OBSP had provided the aforementioned form letter to Canada Post. This form letter did not contain any personal information when provided by the OBSP. Canada Post then conducted a "mail merge" of the information provided by the Ministry (i.e., the names and addresses from the listing were inserted onto the form letters provided by the OBSP). Canada Post subsequently sent a letter to each of the targeted individuals.
At no time was personal information ever disclosed directly to the OBSP. The OBSP was not aware as to which individuals had received the letter unless the individual had chosen to contact one of the clinics. As well, the health number was never disclosed to either the OBSP or Canada Post.
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