Freedom of Information and Protection of Privacy Policy

To set out the provisions for stewardship of information under Seneca’s custody or control, while safeguarding individuals’ personal information.

This policy applies to Seneca employees and authorized third parties who collect, use, disclose, retain or dispose of information on behalf of Seneca.

Information about an identifiable individual, including:

• race, national or ethnic origin, religion, age, gender, sexual orientation, and marital or family status
• employment and educational history
• medical, psychiatric and psychological history, prognosis, condition, treatment and evaluation
• an identifying number (e.g., Social Insurance Number, student number)
• home address and telephone number
• personal opinions of or about the individual

Information about individuals acting in their business or professional capacity is not personal information. This includes their name, title, business address, business telephone number and business email address.

A risk management and accountability tool that public institutions must use to identify and address privacy and security risks associated with the collection, use, retention and disclosure of personal information.

Any information in Seneca’s custody or control relating to students, employees and business operations.

1. Seneca is committed to complying with the Freedom of Information and Protection of Privacy Act (FIPPA) and conducting its operations in a transparent and accountable manner, while also taking reasonable steps to protect the privacy of individuals.
2. Seneca will maintain a Privacy Notice providing details of institutional privacy and information handling practices and the legal authority to collect, use and disclose personal information.
   
3. Seneca will use technical, physical and administrative safeguards to protect personal information from loss, theft and unauthorized use and disclosure.
   
4. Seneca will monitor and review internal and third-party practices to ensure compliance with FIPPA.

1. Individuals have a right to request access to records in the custody and/or under the control of Seneca.
2. Individuals have the right to access their own personal information and the right to request correction of personal information that they consider inaccurate or incomplete.
   
3. Individuals seeking to make a formal request under FIPPA should be directed to Seneca’s Freedom of Information website.  

1. Some records will be exempt from disclosure in certain circumstances including, but not limited to:
   • where the disclosure could reasonably be expected to interfere with a law enforcement matter
   • where the disclosure could reasonably be expected to compromise Seneca’s economic interest or competitive position
   • where the disclosure could reasonably be expected to prejudice the use or results of tests, testing procedures or techniques used for an educational purpose

1. Records excluded under FIPPA include, but are not limited to:
   • labour relations and employment related records
   • records respecting or associated with research conducted by an employee of Seneca
   • teaching materials that are collected, prepared, or maintained by or on behalf of Seneca for use at Seneca

1. Seneca collects, uses and discloses personal information in accordance with FIPPA and only for purposes that are necessary and directly related to its legitimate functions.
2. Where possible, personal information will be collected directly from the individual to whom it relates and only necessary information will be collected.
   
3. The purposes for which Seneca collects, uses and discloses personal information include:
   • administering academic and non-academic programs and evaluations
   • facilitating experiential learning activities (e.g., work/field placements, work-integrated learning, applied research)  
   • managing student recruitment, admission and graduation
   • providing financial aid
   • supporting philanthropic initiatives
   • administering employment-related matters 
   • ensuring security and information technology systems
   • conducting institutional planning
   • statistical analysis and reporting 
   • working with third-party organizations for Seneca-related activities

1. Seneca will conduct a privacy impact assessment for any new or significantly changed program or system that collects, uses or discloses personal information.
2. Academic and service areas will consult the Privacy Office when new programs or systems that collect personal information are implemented.

1. Any actual or suspected theft, loss or unauthorized use or disclosure of personal information will be investigated by the Privacy Office.
2. Seneca will notify affected individuals and the Information and Privacy Commissioner of Ontario of any theft, loss or unauthorized use or disclosure of personal information, in accordance with applicable legislation.
3. Seneca will maintain records of all reported privacy incidents.
4. Reprisal against an individual who, in good faith, reports a privacy incident is prohibited.

1. Seneca retains personal information for a period of at least one year from its last use, unless the affected individual consents to a shorter period.
2. Personal information may be subject to longer retention periods as required by FIPPA or other applicable legislation.
3. Prior to disposing records containing personal information, employees will consult the Privacy Office for approval (see Appendix).

• Appendix: Disposal of Personal Information Form (PDF)

• Personal Health Information Protection Policy
• Recording Lectures and Educational Activities Policy
• Whistle Blower Policy

• Freedom of Information and Protection of Privacy Act, R.S.O. 1990

• Information and Privacy Commissioner of Ontario

• Ontario Colleges of Applied Arts and Technology Act, 2002, S.O. 2002

• Personal Health Information Protection Act, 2004, S.O. 2004

• Seneca Polytechnic Freedom of Information website
• Seneca Polytechnic Privacy Notice

Approval Date: April 2018

Last Revision: February 2026