Which of the following incidents will require reporting to OPC?
A.
A sales report with aggregated information that was sent to the wrong person internally.
B.
A file with client ID, sales amount and sales date that was sent to the wrong processors who cannot identify the clients.
C.
An organization’s point-of-sale system that was subject to an attempted hack that was blocked by the organization’s firewall.
D.
As part of a freedom of information request, a nursing home that released an e-mail with everybody’s e-mail address in the "to" section unredacted.
The Answer Is:
D
This question includes an explanation.
Explanation:
Under PIPEDA, any breach of security safeguards involving personal information that poses a real risk of significant harm (RROSH) requires reporting to the Office of the Privacy Commissioner of Canada (OPC). In the scenarios given, sending a sales report with aggregated information (option A) or a file with client data to wrong processors who cannot identify the clients (option B), or blocking an attempted hack (option C), may not necessarily pose a RROSH. However, a nursing home releasing an email with everyone's email address in the "to" section unredacted during a freedom of information request (option D) potentially exposes individuals to a risk of spam, phishing, and other malicious activities, thereby posing a real risk of significant harm. This constitutes a breach requiring reporting to the OPC.
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