Snooping in a Police Database
OIPC recently issued Investigation Report 123-2025 into a case where Constable Clinton Duquette of the Regina Police Service (RPS) snooped into the personal information of six individuals over a period of three years.
The RPS is subject to The Local Authority Freedom of Information and Protection of Privacy Act (LA FOIP). Penalties for contravening LA FOIP include a fine of not more than $50,000, to imprisonment for not more than one year or to both.
There are several factors that must be considered when OIPC determines if it will recommend the matter be conveyed to the Attorney General of Saskatchewan for an opinion with respect to a prosecution under LA FOIP. The factors include (1) overall strength of the case; (2) public interest in a prosecution; (3) harm to the community as a result of the privacy breach; (4) number of complainants from the community; and (5) available litigation resources.
In Investigation Report 123-2025, OIPC determined that every factor listed above can be adequately addressed by the factual matrix of the case. As such, the Commissioner recommended that this matter be conveyed to the Attorney General of Saskatchewan for an opinion with respect to prosecution pursuant to section 56(2) of LA FOIP.
In October, OIPC issued Investigation Report 103-2025, 104-2025 into a case where a employee of the Saskatchewan Health Authority (SHA) snooped into the personal health information of 323 patients without legal authority. Employees of SHA must abide by The Health Information Protection Act (HIPA). Penalties for individuals contravening HIPA are the same as the penalties under LA FOIP. In that case, the Commissioner considered the factors but did not recommend that matter be referred to the Attorney General of Saskatchewan. However, the Commissioner decided to name the snooper in that case: Fahmida Shipa. For a more detailed explanation, you can read the blog Health Care Personal Information Snooping: When Will People Learn?