Queen’s University, like all universities in Ontario, is subject to the Freedom of Information and Protection of Privacy Act (FIPPA), which governs the way personal information is collected, used, disclosed, retained and destroyed. This document is designed to help you ensure that, as a Queen’s employee, your email practices comply with FIPPA, as well as with the University’s records management requirements.
Access to Information
Under FIPPA, anyone can request access to records of the University, including emails. The exceptions to disclosure are limited and can’t be applied until after records have been reviewed by University staff.
Email is a Record
Whenever an email message is sent in the course of University business, that email becomes an official record of the University. Such records can be subject to disclosure in response to an Access to Information Request under FIPPA or subject to subpoena by the courts. So it’s important that you take care when sending emails for a business purpose.
Use Your Queen's Email Account
In today’s world, we all have multiple email accounts. Some are personal (such as a Gmail or Hotmail account), and some will be institutional (such as your Queen’s employee account). Always use your Queen’s University employee email account for University business. If you use a non-Queen’s employee account to create, respond to, or store work-related information you are increasing the risk of causing an inadvertent privacy breach by using a non-authorized service provider. In addition, those emails are still subject to FIPPA so you run the risk that your own personal emails will be drawn into an access to information request. For these reasons, it is imperative that you keep your personal and work-related correspondence separate.
|Use your Queen's employee email account for work-related correspondence||Forward your Queen's business-related emails to a personal email account (such as Gmail or Hotmail)|
Use your personal email account for personal correspondence
|Use the alias function in a personal email account to compose messages so that they look like they are coming from your Queen's address but are really created, sent, and stored using your personal account|
Create Email Records with Access in Mind
Because the public (including the media) has the right to access the emails that you create in the course of your job, it is important that all work-related emails be composed in a professional tone, and with the basic assumption that they might be made public under an Access to Information request.
Consider whether a record is necessary
Use email when you need a record of the communication. Use the phone for preliminary discussions, or when a record is not strictly necessary.
|When you need a record:||When you do not need a record:|
|To officially confirm something previously discussed||Preliminary discussions before an official decision is made|
|To demonstrate due diligence||Discussions involving opinions about others, unless an official record of those opinions is necessary|
Create professional records
Don’t put anything in an email that you would be embarrassed to see on the front page of the newspaper.
Protect personal and confidential information
There may be times when you may need to transmit sensitive and confidential information, including personal information. With email, there is always a risk that messages will be accidentally forwarded to an unauthorized individual or opened and saved on a mobile device that is later lost, or stolen. Personal information that is lost, stolen, or disclosed to an unauthorized individual constitutes a privacy breach under FIPPA.
Ontario’s Information and Privacy Commissioner has taken the position that if personal information is encrypted, then it is not a privacy breach if it is lost or stolen.
For this reason, when you need to transmit personal information, ask yourself first whether there is another, more secure way to deliver the information than by email, such as by hand, or by using a document sharing service, such as QShare, or OneDrive for Business, that requires users to authenticate their identity to obtain access to the document(s).
If you must use email to communicate personal or confidential information,
- remove as much personal information as possible
- put the information in an attachment and encrypt the attachment before sending
- include a confidentiality statement at the bottom of your email
- verify the email addresses of all recipients
Encrypting Email Attachments
You can encrypt email attachments by assigning them a password.
- Give the recipient the password over the telephone or in a separate communication.
- Do not provide the password in the same message as the attachment.
- Visit ITServices’ online tutorials for instructions on how to encrypt Word, Excel, and PDF documents.
Keep and File Email Records Appropriately
Retain messages that are sent and received only if they relate to University business; all other messages can be treated as transitory and deleted (see Fact Sheet on Transitory Records).
- When retaining a series of replies or forwards, keep only the last message as long as the thread is complete and hasn’t been changed in the course of the exchange.
- Make sure to retain information in the header regarding the sender, recipients, date and time; this helps preserve the context of the message.
- The email system is not a recordkeeping system. A recordkeeping system organizes records according to a file plan, provides shared access to those who need it, and applies retention and disposition rules. Here are some options for filing email messages:
- If you have an electronic recordkeeping system, file email (and attachments) in that system.
- If you have a paper-based recordkeeping system, periodically print and file the email (and attachments) and then delete them from the email system.
- As a temporary measure before filing in a proper recordkeeping system, create folders within the email system that reflect your department’s file plan. Move email to these folders every day.