Disclosure of Saskatchewan Health Numbers

Pursuant to section 11 of The Health Information Protection Act (HIPA), individuals cannot be asked to produce their Health Services Number (HSN) unless it is required in order to receive health services or is authorized by a statute.


School divisions do not need to have student HSN for emergency situations. If a student is injured and must be taken to a doctor or a hospital, the student will be treated even if the student does not have a HSN with them at the times.

Ministry of Education Registration Forms

Boards must complete the student registration forms set by the Ministry of Education in order to receive funding. Section 28(2)(i) of LAFOIP allows personal information to be disclosed for the purpose of complying with an Act or regulation.

However, the Ministry of Education does not require schools to include the Saskatchewan students’ HSN on its registration forms. Although there is room on the Ministry forms for this information, it is not mandatory.


Section 11(1(3)(a)  of HIPA which allows collection for purposes related to provision of health services may allow some very limited circumstances where a school division might require a student HSN. In such cases it must be necessary in order for the student to obtain health services and must be collected directly from the student or parent at the time it was needed. The HSN would not be retained as part of the student file.

Some examples of the limited circumstances in which collecting a student HSN might be acceptable would include:

  • if students are going on out of province travel where the HSN may be required in order to obtain health services or access health insurance outside the province
    • the HSN should be collected only for the purposes of the trip and should not be retained on the student file.
  • where boards of education enter into an agreement with the Saskatchewan Health Authority so that the division can provide contact information for student who have not been immunized:
    • the HSN may be used to confirm the identity of specific students for the purpose of obtaining service from Saskatchewan Health Authority
    • the HSN should be used only for the purpose indicated and should not be retained on the student file.

There is no instance in which the HSN should be routinely collected on school division registration forms.

Proof of Medical Insurance or Saskatchewan Residency

School divisions can, however, ask if a student does have a HSN. This is to ensure that the student is covered by medical insurance. If a student does not have a HSN, the school division may require them to obtain private medical insurance.

Similarly, school divisions can ask if a student has a HSN as evidence that the student is a resident of Saskatchewan and is eligible for publicly funded education.

The needs of the school division can be met by having the parent or student produce the HSN card or a true copy of the HSN card – the HSN number does not need to be recorded.

Note: Boards should also consider whether there are other means of confirmation that would not require use of the HSN card.

Tracking Students

Arguments have been made that the HSN is required in order to develop strategies for increasing student retention rates and finding students who might otherwise be lost to the education system. The argument asserts that section 24 of LAFOIP would allow the board to collect the HSN and section 28(2)(n) of LAFOIP and section 10(c) of the LAFOIP Regulations would allow the school division to disclose the HSN to the Ministry of Education. However, this issue has not been addressed or settled by the courts or by the Information and Privacy Commissioner.

As the Ministry of Education and boards of education move towards a provincial student registration system, there is less likely to be support for using the HSN for tracking purposes.


The Health Information Protection Act

 Rights re production of health services number

11(1) An individual has the right to refuse to produce his or her health services number or any other prescribed identifying number to any person, other than a trustee who is providing a health service, as a condition of receiving a service.

(2) Except as provided in subsection (3), no person shall require an individual to produce a health services number as a condition of receiving any product or service.

(3) A person may require the production of another person’s health services number:

(a) for purposes related to:

(i) the provision of publicly funded health services to the  other person;

(ii) the provision of a health service or program by a trustee; or

(b) where authorized to do so by an Act or regulation