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Section 2.5 of Directive 059: Well Drilling and Completion Data Filing Requirements requires licensees to submit electronic copies of directional survey reports in certain circumstances. Section 2.5 expressly states that licensees are not to include other types of well information with directional surveys submitted to the Energy Resources Conservation Board (ERCB) under this provision.
Recently the ERCB has discovered a number of instances where licensees have included confidential information in directional survey reports submitted to the ERCB.
Directional survey reports and data are not confidential under Section 12.150 of the Oil and Gas Conservation Regulations. Therefore, following submission to the ERCB, directional survey reports are made publicly available. The ERCB is under no obligation to and does not perform any checks on the content or status of additional information included by licensees with directional survey reports. As a result, licensees that include confidential data in directional survey reports need to be aware that such information will be made publicly available following submission to the ERCB.
It is the sole responsibility of licensees to ensure they do not include confidential information in directional survey reports submitted to the ERCB.
Licensees and their representatives that include personal information in directional survey reports or other information submitted to the ERCB may be in violation of applicable privacy legislation (including the Personal Information Protection Act or the Privacy Act) and may be subject to review by the Office of the Information and Privacy Commissioner of Alberta or by the Office of the Privacy Commissioner of Canada.
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CIO and Executive Manager
Information and System Services