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Submitted by admin on August 12, 2023

ID numbers are considered personal data under the Act as it is information relating to a living individual or an individual who has been deceased for less than thirty years who can be identified from that information alone or from that information and other information in the possession of, or likely to come into the possession of the data controller.
In determining whether personal data is processed, regard must be had to its definition under the Act. The term process is defined as obtaining, recording, or storing the information or personal data or carrying out any operation or set of operations (whether or not by automated means) on the information or data, including:

  • organization, adaptation, or alteration of the information or data
  • retrieving, consulting, or using the information or data
  • disclosing the information or data by transmitting, disseminating, or otherwise making it available; or
  • aligning, combining, blocking, erasing, or destroying the information or data, or rendering the data anonymous.

In view of the wide definition, simply obtaining or recording, or storing personal data is processing the personal data. In this regard, the ID numbers of a Notary Public are to be treated in the manner as prescribed for all personal data under the Act. 
 

Detailed Question

We are not processing [the ID numbers of a Notary Public], it was not requested but we do have it, how is it to be treated?