Longley Condominium Services Ltd. v. Condominium Corporation No. 7910117 (Office of the Information and Privacy Commissioner - Alberta)

28/05/13 – Jurisdiction Alberta
Part 29 published on 01/02/10
Condominium minutes did not breach PIPA

An owner in a condominium complained that the corporation had improperly disclosed her personal information in the AGM Minutes. The owner felt that this disclosure contravened Alberta’s Personal Information Protection Act (PIPA). The adjudicator dismissed the complaint for the following reasons:  

A condominium corporation is required, by statute, to keep minutes of meetings. Therefore, as long as the personal information in the minutes is relevant to the corporation’s duties or powers under the Condominium Property Act (CPA), there is no “disclosure” for the purposes of PIPA. The adjudicator’s reasoning included the following:  

As a hypothetical example, it would not be a disclosure of personal information to include in the financial statements or minutes that the condominium corporation is taking action in relation to a particular unit for breach of the bylaws or to record such a statement in the minutes, but it may be a disclosure to include personal opinions about a unit owner, or the unit owner’s financial or personal circumstances, if recording that information is not done for the purpose of carrying out the business of the condominium corporation as required by the CPA.