The Canadian Privacy Library is a new centralized website to find the privacy impact assessments (PIA) from universities across BC.
Created by former UBC staffer Ian Linkletter, the website hosts 504 PIAs from 18 of 25 BC public post-secondary institutions. According to the Privacy Library’s website, a PIA is a process that is meant to determine how a program or activity could affect someone's privacy — PIAs often generate a report which outlines how the technology works, how information is collected and where it is stored, as well as risk factors and mitigation strategies.
In accordance with BC’s Freedom of Information and Protection of Privacy Act (FIPPA), public bodies like UBC are meant to conduct a PIA when implementing new systems that collect personal information. Among others, UBC has conducted PIAs for Workday, Zoom, and Microsoft 365.
In an interview with The Ubyssey, Linkletter explained that he began the project after noticing institutions were secretive about their PIAs. “I was always curious, as someone with a huge interest in privacy. Like what did the PIA actually say? How is information being handled?” said Linkletter.
He filed freedom of information (FOI) requests for PIAs in May 2024 and said many institutions were cooperative. However, UBC was not.
Linkletter said he initially filed FOI requests for UBC documents dating from 2014 to 2024. “I worked with UBC over the following months to refine my request and make it clearer,” he said.
UBC estimated Linkletter would need to pay $6,045 for his request — he attempted to get the fee waived. It was not, but UBC reduced it to $2,045. Linkletter has not yet paid the fee and as a result has not received any PIA reports from 2017 onwards.
UBC’s Privacy Matters website has PIAs from 2020 to 2024 available.
In a statement to The Ubyssey, UBC Legal Counsel Erika Brimacombe wrote that a requestor asking UBC to waive fees is by extension asking taxpayers and students to subsidize the costs of putting together the PIA reports.
“We must balance the public benefit of fully subsidizing these costs against the impact on the University’s operations and the cost to taxpayers and students,” wrote Brimacombe. She reiterated that a PIA is an assessment process and wrote that FIPPA requires no final report to be made for a PIA.
Initially, Linkletter had reuploaded the PIAs already available on UBC’s website onto the Canadian Privacy Library. However, when responding to Linkletter’s fee waiver request, UBC stated that no third party had been granted a license to republish the PIAs and that they are protected as UBC’s intellectual property under copyright law — the university also reserves the right to enforce its legal protections.
Linkletter replaced the reuploaded PIAs with links that lead directly to UBC’s own links. However, he noted the importance of a third party archive — UBC removed a 2018 PIA for Proctorio in 2025 but it can still be found on the Canadian Privacy Library.
Brimacombe wrote that “UBC has not threatened anyone with or taken legal action for reposting UBC’s PIAs.”
She stated that UBC does not prefer third party sites hosting its PIAs, as “PIAs can be reopened and updated as systems or projects evolve, centralizing the Public PIA Summaries on UBC’s website helps ensure that the most current versions are available.”
Brimacombe also said that “UBC’s cybersecurity team advises against the publication of a comprehensive list of all PIAs conducted as this meta-information itself can aid malicious actors in identifying potential targets or vulnerabilities.”
However, Aislin Jackson, the policy staff counsel at the British Columbia Civil Liberties Association noted that private information is not actually in these records, but emphasized that it is important for people to be able to understand their privacy rights, as it gives them the ability to be free and fully open about who they are.
“Infringing on privacy, even being perceived to infringe on privacy, or people not believing that they have privacy even if they actually, in fact, do — all those things chill people's expression and reduce their freedom by causing them to self censor,” said Jackson in an interview with The Ubyssey.
Jackson also noted that it is unusual to invoke copyright law to protect privacy.
The Copyright Act reads that its purpose is to allow creators a just reward for their creation. In this case, UBC does not make a profit from its PIA reports and neither would Linkletter if he were to republish them. However, creations being shared for research, private study or education are not considered copyright infringement under the fair dealing exemption.
She said that everyone who makes a FOI request to see these PIAs has the right to access them, so in theory Linkletter could publish his lists of FOI requests and people could individually request them in order to see them.
“Ultimately [UBC is] not able to block anyone in the public from getting the records upon a request. [UBC] can just make it a little bit more difficult,” said Jackson.
In 2020, Linkletter found himself in a similar situation when he was working at UBC. Proctorio — the software UBC used during the COVID-19 pandemic to invigilate exams — filed a copyright infringement lawsuit against him for tweets where he linked unlisted Youtube videos from Proctorio which explained how the company's proctoring software worked and shared a screenshot from its help centre. This case is still pending.
“It was unprecedented for the Copyright Act to be used as a censorship tool to begin with, but here we are again,” said Linkletter. He also said he had specifically decided to centre this project on public records to avoid possible litigation.
“This UBC case raises … more fundamental [issues] that really strike at the fundamental purpose of freedom of information legislation,” said Jackson.
“If this practice of claiming copyright over FOI materials to prevent them from being more broadly distributed, if that is successful and becomes entrenched, then I think that really could undermine freedom of information.”
Since Linkletter was unable to receive the fee reduction, he said he plans to start his request over with more specific asks that can be demonstrated to be of public interest — as those requests are more likely to have their fees waived. He also said he would narrow his requests to start from 2017 onward and targeted heavily used tools like Canvas.
“I'm a librarian, and my whole career involves helping people access information,” he said. Linkletter noted that he’s motivated to do this work to protect students. According to him, the key to this is transparency.
“UBC aggression towards me is an attack on freedom itself. If it becomes normal for scholars like myself to face legal threats for pursuing and disseminating knowledge, it will become common practice,” said Linkletter.
“UBC’s academic freedom policy identifies the pursuit of knowledge as a primary function of the university. This goes completely against that.”
Ian Linkletter and Ubyssey Deputy Managing Editor and Opinion Editor Spencer Izen, in his capacity as an employee of the B.C. Freedom of Information and Privacy Association, corresponded about some of the issues mentioned here in 2024. Izen was not involved in reporting or editing this story.
First online
Share this article
Submit a complaint Report a correction
