ss.(1)

• Once an access request is received, an institution has an inherent responsibility regardless of the requirements of a retention schedule to ensure that personal information and general records responsive to a request are retained until the request/appeal process is completed.(Order #M-1121, M-1135)

• Where the integrity of copies of original records were challenged, the Commission ruled that when an institution receives a request, there is an obligation on the institution to ensure that the original responsive records are not destroyed until the request is completed and any subsequent proceedings before the Commission or the courts is completed. (Order #M-1121

ss.(2)

• Mistakes re: personal information should be corrected as soon as reasonably possible in order that this section be complied with.(Privacy Investigation Report #I95-031M)

• Reasonable steps to ensure that personal information is accurate and up-to-date does not require that every possible step be pursued to ensure accuracy. (Privacy Investigation Report #I95-110M)