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Can a school continue to maintain a student contact information system that includes a photograph of the student on Rolodex or in a database or CD?

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Can a school continue to maintain a student contact information system that includes a photograph of the student on Rolodex or in a database or CD?

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• In Investigation Report 2000-IR-007, the Information and Privacy Commissioner found that if a school decides that including a photograph of a student in a contact information system is directly related to and necessary for the delivery of its educational services and programs, then the collection may be authorized under section 33(c) of the FOIP Act. • The collection of a photograph from a student would be considered to be a collection of personal information directly from an individual and under section 34(2) of the FOIP Act, when a school is collecting personal information directly from an individual, the school must provide notification for the collection. A school may provide the notification at the time of registration or at the time when the photographs are taken. • If the personal information is being disclosed to a contractor to prepare the disk, the contract should include provisions to protect the privacy and security of the personal information.

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