Ontario Privacy Commissioner Releases Interpretation Bulletin On Correction Requests Made To Public Institutions

On April 22, 2025, the Information and Privacy Commissioner of Ontario (IPC) released an interpretation bulletin (the Bulletin) on the handling of correction requests received by public institutions. These requests may be submitted by an individual to correct the personal information that an institution holds on them in accordance with sections 47(2) of the Freedom of Information and Protection of Privacy Act or 36(2) of the Municipal Freedom of Information and Protection of Privacy Act (collectively, the Acts).

The Bulletin describes three requirements that must be met before an institution grants a correction request:

1. The information must be the requester’s personal information. To fulfill this requirement, the Bulletin explains that (a) the information at issue should align with the definition of “personal information” under the respective Act; and (b) a correction request is only made after an individual is given access to the personal information at issue, which is a right generally provided to individuals for only their personal information.   
2. The information must be inexact, incomplete or ambiguous. The Bulletin mentions that correction requests are meant for addressing information that is “inexact, incomplete or ambiguous”. If the information to be corrected is someone’s opinion (e.g., observations made during a police investigation), then there is no basis for correction as long as that opinion is accurate. To further clarify, the Bulletin states that “…it is not the truth of the recorded information that determines whether a correction request should be granted, but rather whether that what is recorded accurately reflects the author’s observations and impressions at the time the record was created.”
3. The correction cannot be a substitution of opinion. The Bulletin clarifies that a correction cannot replace one person’s opinion with another that is more favorable to the requester.

Even when the above requirements are met, the IPC notes that institutions still have the discretion to accept or reject correction requests if there is a valid reason.

If a request is denied, then the requester may ask for a statement of disagreement to be attached to the information in issue that describes the correction request, and that such statement is shared with any other person that received the information from the institution.

Summary By: Imtiaz Karamat