Alberta’s privacy adjudicator found that Wawanesa did not breach its access obligations when a customer sought the reasons for an insurance coverage decision, because the requested substance was not personal information. In Order PIPA2026-03, dated August 12, 2026, Teresa Cunningham, an adjudicator with the Office of the Information and Privacy Commissioner of Alberta, confirmed that The Wawanesa Mutual Insurance Company had not failed to meet any duties to the applicant under the Personal Information Protection Act (PIPA).
The decision turns on the difference between information about a person and information that affects that person’s interests. It does not exclude insurance files as a category from privacy-law access rights, nor does it decide whether the insurer’s coverage decision was correct.
A request for an explanation
The unnamed applicant asked Wawanesa in May 2024 to explain why coverage had initially been denied and later approved, and to provide any approval letter or other communication. In seeking the commissioner’s review, he complained about delay and argued that the insurer could not simply label internal documents privileged without justifying that claim.
Wawanesa maintained that he was seeking general information about policy coverage, not access to his personal information. It said requests about coverage and litigation had been directed to legal counsel. The insurer also said it had supplied the requested email after recognizing that the communication had previously been sent to the applicant, and was no longer claiming privilege over it.
The applicant pointed to a staff response directing him to Wawanesa’s Privacy Office as the route for obtaining earlier documentation. Cunningham found that using a privacy office to process records requests did not establish that the records contained personal information or that PIPA governed the request.
Policy reasoning was not information about the customer
Section 24(1) of PIPA allows individuals to request access to personal information about themselves, or information about its use or disclosure. Section 1(1)(k) defines personal information as information about an identifiable individual. Cunningham emphasized that a connection to an applicant, or an effect on their interests, was not enough.
Drawing on earlier commissioner decisions, she distinguished information about an individual from material merely associated with them. The right of access concerns the applicant’s personal information within a record, rather than automatically extending to every part of the record.
Cunningham examined the February 2, 2022 email containing the insurer’s decision. Its body described the policy’s terms and how they applied; she found no personal information about the applicant in that reasoning. His name and email address were personal information, but they were not what he was asking to obtain.
Providing only those identifying details would not have answered the request. The applicant wanted the substance of Wawanesa’s reasons and had not identified personal information he was seeking. Cunningham therefore concluded that neither this request nor the insurer’s response to it fell within PIPA’s access provisions.
No privilege ruling or new disclosure order
That conclusion resolved the other issues without validating Wawanesa’s earlier position on privilege. Cunningham expressly declined to decide whether legal privilege had been properly applied, noting that the insurer had abandoned that claim and provided the email.
For the same reason, section 28(1) did not impose a response deadline for this request, and section 27(1)(a) did not require Wawanesa to assist by searching for records. Those findings followed from the request’s non-personal subject matter, not a finding that every insurance request is exempt or that a particular search was adequate.
The order, made under section 52, confirmed that Wawanesa had not failed to meet duties imposed by PIPA in this matter. It required no further disclosure and made no ruling on the underlying insurance coverage dispute.
