Privacy commissioner raises concerns over health numbers on IDs

Diane McLeod on Alberta Primetime Dec 4, 2025

Alberta Information & Privacy Commissioner Diane McLeod joins Alberta Primetime host Michael Higgins to discuss her concerns around the addition of Alberta health care numbers to driver’s licences and other identification.

This interview has been edited for clarity and length.

Michael Higgins: You’ve written to government expressing your concerns.

What’s worrisome from your standpoint?

Diane McLeod: My letter is in response to Bill 11, which is the Health Statutes Amendment proposals. Within that is the proposal to add personal health numbers to driver’s licences in addition to adding the citizenship marker.

What I wanted to highlight, first of all, is having personal health numbers on your driver’s licence certainly creates the risk of proliferation of personal health numbers when you’re showing your driver’s licence at many different places. For example, if you go to a bar or a liquor store, if you rent a car, if you go to a hotel. There’s many places you’re showing your driver’s licence that would then expose the personal health number on the card. That is one aspect of the concern that I raised.

It’s important for people to understand these provisions in health legislation exist to prevent personal health numbers from being used as forms of identification. These laws came into effect in the early 2000s to ensure personal health numbers would only be used by health-care providers to avoid risk of fraud. Now we’ve come full circle, and now we have personal health numbers on identification cards, which means that that risk of exposure expands significantly. It creates significant risks to Albertans for a number of reasons.

One of them is, as I just said, you’re showing your health information in different places, which is copied in many occasions. Even with the controls they put in place in the amendments to the Health Information Act - which are a person who collects this information cannot use or disclose it for any purpose - that only applies to people in Alberta. For example, let’s say I’m in British Columbia. I’m renting a car, and they copy my driver’s licence with my personal health number on it. That law no longer applies in British Columbia, and they still have my personal health number. The controls don’t go far enough to protect the information. In my view, the personal health number has no business being on a driver’s license.

MH: Given those risks, how much of a window could that give someone into the lives of Albertans?

DM: There’s two pieces to it. One is actually the billing system. We have a publicly funded health care system. If people are using health numbers to obtain services, whether it be in Alberta and other parts of Canada, that is an impact on our health care billing system. Which again, is one of the reasons we had these prohibitions in the legislation in the first place.

The other thing Albertans need to be concerned about is if somebody actually uses your personal health number to obtain care. We know today we have much greater integration in our health records. As a result of that, if somebody were using your personal health number and obtaining care that information could end up on your health record. That could have some serious consequences. For example, if there’s different blood types, different allergies. These are risks that could be prevented by not having this information that’s available widely in a number of different scenarios.

MH: To what degree was your office consulted on any of these changes prior to the government going ahead with this?

DM: We have been made aware of the modernization of the health care card. We didn’t know exactly what it would look like. We haven’t met with government on this. A while back it came out with a Canadian citizen marker, which was the first thing that triggered a public response to that addition of the information. As a result of that, I contacted government.

They informed me and they were correct, that the register of motor vehicles is not subject to privacy laws in Alberta. It does not have to provide a privacy impact assessment to my office so we can assess the privacy risks associated with this activity. However, they have agreed to meet with me. We’re hoping that we can discuss the risks associated with this, which is also much broader than what I’ve even said.

MH: Is there a degree of protection that is feasible to be applied here that the government could use to take this forward?

What would need to happen?

DM: That’s a good question. If we had an opportunity to speak with government, we might find ways we could somehow mask the personal health number on the cards. I would have to talk to my technical people in my organization to look for opportunities.

Another important thing to know is government is actually offering another alternative to having personal health numbers on your driver’s license, and that is through a digital wallet. They are trying to advance that objective first. If Albertans choose that option they would be better protected. If they don’t have that, chances are they’re going to have to put it on their driver’s license.

The issue that I have with that is for seniors. Many seniors have a hard time operating technology and I think there’s many seniors that would be concerned about having their personal health number on their driver’s licence. I really do think it would be wise for a reconsideration to have a separate card that people could apply for through Alberta Health.

MH: Given all of this and the reality of now being in this age of AI, how concerned should Albertans be about privacy and protection of their information?

DM: Are you talking about AI in general, or as it relates to the identification cards, or the risk of cyber attack? Because I would say because we have artificial intelligence combined with quantum computing, I think the risk of cyber attacks are significant. Meaning if you have organizations that have collected your health information, the risk it would be accessed by a malicious actor only increases because of the use of artificial intelligence.