pulverization and incineration for physical destruction and over- writing and degaussing for electronic destruction. In anticipation of information becoming subject to a security breach, organizations should update breach response protocols to include notification to the Information and Privacy Commis- sioners and conduct risk assessments of the potential harm to affected individuals. Even if the information transmitted would not be useful by itself for fraud, the Alberta Commissioner found in In- vestigation Report H2009-IR-007 that notifying individuals may be the prudent and responsible course of action where the infor- mation could be used as a starting point to put together an indi- vidual profile for fraudulent purposes, or is inherently sensitive (e.g., health information) that individuals deserve to know it has been exposed. Even without these amendments, private sector privacy laws across Canada place obligations on companies to safeguard information in their possession. In light of the changing legal landscape, organizations are likely to be more proactive about security. Based on the experience in the United States, companies have made investments in their security programs where breach notification requirements became mandatory.

Meaghan McCluskey is a privacy research lawyer with Nymity Inc. (www.nymity.com), a provider of PrivaWorks, a privacy support tool.

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