Owen Sound: A Four-Year City Business Plan

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Appendices

Appendix NCampaign, Private Interest and Municipal Conflict Firewall

12,551 words · Mike Seiler · Owen Sound, Ontario

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In this chapter

Public office must never become a private distribution channel, procurement advantage, data source or ownership shortcut

A person can be several things at once.

They can be:

Those roles are lawful.

The danger begins when the boundaries between them become:

A good idea does not become municipal property because:

A private company does not become the City's preferred supplier because:

A campaign mailing list does not become:

A City resident database does not become:

A municipal employee does not become:

A City communications channel does not become:

A Mayor's meeting does not become:

A public procurement does not become:

And a private platform should never acquire legitimacy through:

Mayor says the City should use it.

The standard should be stronger than:

I know I can be fair.

The better standard is:

The process should remain fair even if everyone assumes I might not be.

That is the purpose of a firewall.

The governing principle is:

Public office must never become a private distribution channel, procurement advantage, data source or ownership shortcut.

A second principle follows:

Disclosure is important, but disclosure alone is not a cure for conflict.

A third principle is:

Where the Mayor has a private interest, the Mayor should not control the municipal process used to evaluate that interest.

A fourth principle is:

Campaign, private business and municipal government must remain three separate systems.

And a fifth principle is:

The stronger the private connection, the stronger the independent safeguard.

N.1Purpose

This appendix establishes a practical firewall among:

Campaign Activity

Private Interests

Municipal Government

N.2It Applies To

N.3It Is Not a Declaration That Conflict Exists in Every Case

No.

N.4It Is a System for Determining

N.5Statutory Conflict

Must be handled according to:

N.6Broader Governance Conflict

May require safeguards even where:

N.7Appearance of Conflict

Does not automatically establish:

N.8But Appearance Can Damage

N.9Therefore

Design process so public does not need to rely solely on:

Trust me.

N.10The Three-System Rule

Maintain three institutionally separate environments:

Campaign

Private

Municipal

N.11Campaign System

Contains:

N.12Private System

Contains:

N.13Municipal System

Contains:

N.14Information Should Not Flow Freely Across Those Boundaries

No.

N.15Money Should Not Flow Freely Across Them

No.

N.16Staff Should Not Flow Freely Across Them During Work Time

No.

N.17Intellectual Property Should Not Flow Across Them Without

N.18Public Power Should Never Flow Into Private Advantage

Core principle.

The firewall must operate in addition to, and not instead of:

N.20Municipal Conflict of Interest Act

Ontario's current Municipal Conflict of Interest Act addresses direct and indirect pecuniary interests and sets duties for members. It also contains specific rules for a head of council who has a pecuniary interest in a matter involving specified head-of-council powers, including written disclosure and restrictions on using the power or attempting to influence the municipal decision.

N.21This Is Particularly Important Under Strong-Mayor Powers

Because the head of council may have statutory powers that are:

N.22Owen Sound and Strong-Mayor Powers

Owen Sound is currently designated under Ontario's strong-mayor framework. The current regulation also requires written records of certain mayoral directions to municipal employees and, subject to MFIPPA, public availability of specified written records.

N.23Election-Period Limits

Ontario also amended the strong-mayor regulation in June 2026 to limit certain head-of-council powers during the election transition once specified electoral conditions are known, including certain powers involving the CAO, organizational structure and specified property or expenditure proposals.

N.24Therefore

The firewall must cover:

N.25Integrity Commissioner

Owen Sound currently provides access to an Integrity Commissioner and maintains a registry relating to written declarations of pecuniary interest.

N.26Provincial Accountability Changes

Ontario enacted the Municipal Accountability Act, 2026, which would significantly change the provincial code-of-conduct and Integrity Commissioner framework when the relevant provisions are brought into force. As of August 2026, the current Municipal Act still identifies those Schedule 2 amendments as not yet in force.

N.27Therefore

This appendix should be:

reverified at the beginning of the new Council term.

N.28Do Not Build Firewall Around Soon-to-Be-Obsolete Law

Correct.

N.29Current City Code

Owen Sound's presently published Council code includes specific sections addressing conflicts, gifts and hospitality, use of City resources, election campaigns, improper influence and business relations. Its resource provisions also state that members are not to use City resources for personal purposes and address personal financial gain from City-developed intellectual property.

N.30Election Resources

The Municipal Elections Act requires municipalities and local boards to establish rules and procedures concerning use of municipal or board resources during regular election campaign periods.

N.31Owen Sound Current Election Policy

Owen Sound's 2026 Use of Municipal Resources for Elections Policy states that municipal resources are to be used impartially and not to support or oppose candidates or campaigns. Its detailed restrictions cover City branding, City-funded websites, municipal email and voicemail, corporate IT and data, staff campaign assistance, City-created photographs and video, and campaign displays on City property, while permitting ordinary facility rentals under standard terms.

N.32This Appendix Does Not Replace That Policy

It strengthens the long-term:

firewall.

Where application is uncertain:

Use:

as appropriate.

N.34Do Not Ask Political Staff to Interpret Conflict Law

No.

N.35The Firewall Principle

When a public decision could produce a material private benefit for the Mayor or a related private interest:

remove the Mayor from control over the evaluation path to the extent required by law and prudent governance.

N.36This Can Include Removal From

N.37Exact Requirements

Depend on:

N.38Independent Process

Should not depend on Mayor deciding:

when independence is necessary.

N.39Trigger

Established in advance.

N.40Conflict Firewall Trigger

Enhanced safeguards should be considered when municipal action could materially affect:

N.41Ownership Percentage

Do not rely on arbitrary percentage alone.

N.42Minority Holding

Can still create:

N.43Non-Equity Interest

Can still create:

N.44Royalty

Can create interest.

N.45Licence

Can create interest.

N.46Trademark

Can create interest.

N.47Domain

Can create interest.

N.48Future Sale Value

Can create interest.

N.49Reputation

Can create governance concern even where no statutory pecuniary interest exists.

N.50Public Interest Disclosure

Upon assuming office, the Mayor should establish a proactive:

Public Interest Disclosure

subject to legal and privacy review.

N.51This Is Proposed Governance Standard

Not a claim that current Ontario law requires publication of every:

N.52Public Disclosure Should Focus On Interests Reasonably Relevant to Municipal Decision-Making

Not:

N.53Possible Categories

Significant Business Ownership

Directorships

Partnerships

Founder Roles

Material Municipal-Sector Intellectual Property

Companies Potentially Seeking City Business

N.54Do Not Publish

without legal reason.

N.55Transparency Should Be Relevant

Not voyeuristic.

N.56Update

If material interest changes:

Update.

N.57Annual Confirmation

Useful.

N.58Clerk / Integrity Review

Could advise on:

N.59Public Record

Should identify:

nature of potentially relevant interest

without unnecessarily publishing:

N.60map.ca

Should be expressly included.

N.61RealMap

Should be expressly included.

N.62Other Founder-Associated Technology

Include if municipal relevance develops.

N.63Private Real-Estate Interests

Consider disclosure where:

N.64Ordinary Profession

Being:

does not automatically require withdrawal from every matter affecting that sector.

N.65Broad Class Effects

Conflict law contains:

Use legal advice.

N.66Do Not Over-Recuse

Public officials still need to:

N.67Do Not Under-Recuse

Private benefit still matters.

N.68Recusal Is Not Punishment

It protects:

N.69Disclosure Is First Step

Not always:

N.70Candidate-to-Office Transition

Election victory should trigger a formal:

Campaign-to-Government Transition Protocol.

N.71Campaign Does Not Become City Department

No.

N.72Campaign Staff

Do not automatically become:

N.73Campaign Volunteer

No automatic:

N.74Donor

No automatic:

N.75Endorser

No automatic:

N.76Political Opponent

No automatic:

N.77Transition Inventory

Separate:

Campaign Assets

Candidate Personal Assets

Private Business Assets

Municipal Records

N.78Campaign Laptop

Campaign.

N.79City Laptop

Municipal.

N.80Private Business Laptop

Private.

N.81Do Not Merge Drives

No.

N.82Campaign Email Account

Remain separate.

N.83City Email Account

Begin public-office work.

N.84Private Business Email

Remain private-business system.

N.85No Automatic Forwarding

Do not automatically forward:

N.86Resident Sends Campaign Idea

Campaign can retain according to:

N.87Municipal Adoption

If idea moves into City process:

Recreate the issue through:

without automatically importing unrelated campaign information.

Consent to receive campaign communications is not automatically:

N.89Municipal Resident Service Contact

Not automatically:

N.90Campaign Data Separation

Do not transfer into municipal systems:

N.91City Data Separation

Do not transfer into campaign systems:

N.92Private Data Separation

Do not transfer into City systems:

unless a lawful municipal acquisition specifically provides for it.

N.93Likewise

Do not transfer City data into:

without a lawful municipal decision and data-governance basis.

N.94No Informal Database Merge

Never.

N.95"But It Would Help Residents"

Not enough.

N.96Public Purpose

Required.

Required.

N.98Privacy

Required.

N.99Procurement / Agreement

Required where applicable.

N.100Data Firewall

Appendix J applies.

N.101Staff Firewall

Municipal staff work for:

N.102Not Mayor Personally

N.103Not Campaign

N.104Not Mayor's Private Company

N.105Staff Direction

Must relate to:

N.106Private Business Request

Use:

N.107Example

Mayor should not tell City communications employee:

Improve my private company's website.

N.108Nor

Prepare a map.ca investor presentation.

N.109Nor

Research RealMap competitors for my company.

N.110Nor

Export businesses from City system so I can market to them privately.

N.111Obvious

But worth writing.

N.112Staff Protection Standard

A municipal employee should be able to say:

I believe this request may cross the municipal-private firewall. I need it reviewed before proceeding.

N.113Without Retaliation

Essential.

N.114Escalation

Could include:

Manager

City Manager / CAO

Clerk

Integrity Commissioner

N.115Appropriate Route Depends On

N.116No Staff Forced to Confront Mayor Alone

Important.

N.117Written Direction

Particularly important under:

N.118Strong-Mayor Direction

Current Ontario regulations require written records of certain directions to municipal employees under the strong-mayor framework.

N.119Firewall Standard

Any mayoral direction touching a founder-associated private interest should receive:

automatic conflict screening.

N.120If Conflict Confirmed

Do not issue direction.

N.121If Uncertain

Seek:

N.122Staff Should Not Be Penalized for Delay Required by Conflict Review

No.

N.123No Performance Review Retaliation

N.124No Schedule Retaliation

N.125No Promotion Retaliation

N.126No Public Shaming

N.127Staff Independence

A City Manager or statutory official should be able to:

N.128Political Authority

Does not erase:

N.129Procurement Firewall

When founder-associated business could benefit:

Mayor does not:

N.130Independent Procurement Owner

Assign.

N.131Possible Owner

as lawful.

N.132Procurement Policy

Appendix L applies.

N.133Same Rules

Founder-associated supplier receives:

N.134Also

No artificially harder rules purely for:

N.135Same Defensible Standard

With stronger independence.

N.136Equality of Process

Not equality of influence.

N.137Founder Knowledge

Mayor may know technology deeply.

N.138That Knowledge Can Be Useful to Public Policy

But must be separated from:

N.139Public Standard

Mayor can advocate:

City should improve digital property information.

N.140Mayor should not direct:

City should buy my exact platform.

N.141Policy Objective

Legitimate political role.

N.142Supplier Selection

Independent municipal role.

N.143Separation Is Key

N.144Open Standard

Where possible:

Define desired:

N.145Then Market Can Respond

Possible only after:

requirements are satisfied.

N.147But

Public ownership or open standard may be:

N.148No Presumption

Evaluate.

N.149Sole Source

Founder association should increase scrutiny.

N.150"Only My Company Can Do It"

Needs:

N.151No Self-Certification

No.

N.152Prototype

Can demonstrate:

N.153Prototype Does Not Prove

N.154Independent Business Case

Required before major adoption.

N.155Independent Valuation

Where City may acquire:

N.156Valuation Should Consider

Replacement Cost

Development Cost

Market Comparables

Revenue Potential

Liabilities

Maintenance Burden

Restrictions

Transferability

N.157Development Cost Alone

Not value.

N.158Founder Time

Not automatically:

N.159Future Potential

Not guaranteed value.

N.160Public Ownership

If municipal adoption depends on a private founder-associated asset:

A strong default should be to examine whether public ownership, open licensing or independent nonprofit governance is more appropriate than:

N.161map.ca Proposal

The original initiative brief already contemplates protected public ownership before City adoption of map.ca-related infrastructure.

N.162That Principle Should Be Enforced Through Independent Process

Not founder declaration.

N.163Public Ownership Means

Actual enforceable ownership or control.

N.164Not

Founder promises City can use it forever.

N.165Ownership Questions

Domain

Trademark

Source Code

Database

Design

Documentation

Accounts

Hosting

Keys

Contracts

Analytics

N.166Licence

May be appropriate.

N.167Assignment

May be appropriate.

N.168Open Licence

May be appropriate.

N.169Nonprofit Ownership

May be appropriate.

N.170Municipal Ownership

May be appropriate.

N.171Private Ownership

May be appropriate.

N.172Model Chosen By

N.173Not Founder Preference Alone

N.174Founder Windfall Test

Ask:

Would municipal adoption materially increase the private value of a related company, domain, trademark or other asset?

N.175If Yes

Enhanced safeguards.

N.176Even If City Pays Nothing

Important.

N.177Free Municipal Adoption Can Create Private Value Through

N.178Therefore

"Free" does not eliminate:

N.179No Promotional Testimonial

City staff should not become:

for founder business without independent authority.

Do not place on private company marketing merely because:

N.181Case Study

Any public-sector case study involving a related company should follow:

approval.

N.182No "Official City Partner"

Unless actual agreement supports:

N.183RealMap Firewall

Any municipal consideration of RealMap should begin with:

What municipal objective are we trying to achieve independently of RealMap?

N.184Examples

N.185Then Ask

What lawful and competitive models could achieve that objective?

N.186If RealMap Vanishes

Policy should still make:

N.187Sign Transition

Must stand independently.

N.188No Sign Rule Designed to Force RealMap Usage

Never.

N.189No RealMap Requirement

No.

N.190No RealMap-Linked Permit

No.

N.191No RealMap-Linked Municipal Ranking

No.

N.192No Municipal Data Feed Reserved Exclusively for RealMap Without Defensible Public Basis

No.

N.193Open Data

If City data is lawfully public:

Provide according to:

N.194Private Platform Can Use Open Data

Like others.

N.195No Private API Privilege

Without agreement / procurement.

N.196map.ca Firewall

Any municipal map.ca evaluation should be led by:

N.197Mayor May State Vision

For example:

I want residents to have a better public map and public information system.

N.198Mayor Should Not Determine

N.199Independent Architecture Review

Required where major.

N.200Independent Privacy Review

Required.

N.201Independent Cybersecurity Review

Required.

N.202Accessibility Review

Required.

N.203Procurement Review

Required.

Required.

N.205Financial Review

Required.

N.206No One Reviewer Selected Solely by Founder

No.

N.207Reviewer Independence

Document.

N.208Reviewer Conflict

Disclose.

N.209Review Scope

Publish where appropriate.

N.210Findings

Publish where appropriate.

N.211Negative Findings

Do not suppress.

N.212Founder Rebuttal

Can be heard.

N.213Founder Does Not Approve Final Report

No.

N.214Municipal Technology Pilot

If related platform is tested:

Use:

N.215Pilot Does Not Equal Procurement Award

No.

N.216Pilot Does Not Equal Endorsement

No.

N.217Pilot Does Not Equal Transfer of Ownership

No.

N.218Pilot Result

Can be:

Proceed

Modify

Compete

Transfer

Stop

N.219Private Intellectual Property

An elected official may continue to own private IP subject to:

N.220But

Private IP should not be quietly developed using:

N.221Municipal IP

Likewise should not be privately captured.

N.222Current Owen Sound Code

The City's currently published code says members should not use City resources for personal purposes and addresses personal financial gain from City-developed intellectual property, reflecting the importance of keeping public resources and public IP separate from private benefit.

N.223New Idea Created in Office

Ownership can be fact-specific.

N.224Therefore

Document boundary.

N.225Mayor Sketches Private Invention on Weekend

Potentially private.

N.226City Employees Develop It During Paid Work

Potential municipal interest.

N.227City Funds Development

Potential municipal interest.

N.228Joint Development

Needs agreement.

N.229Do Not Resolve Later From Memory

Define before work.

N.230IP Development Notice

For founder-sensitive project:

Identify:

Existing Private IP

Municipal Contributions

New IP

Ownership

Licence

Commercialization

Public Reuse

N.231Pre-Existing IP

Document before municipal work begins.

N.232Otherwise

Future ownership disputes become likely.

N.233Git Repository

Ownership.

N.234Design Files

Ownership.

N.235Data Schema

Ownership / licence.

N.236Domain

Ownership.

N.237Brand

Ownership.

N.238Training Materials

Ownership.

N.239City-Funded Improvements

Define.

N.240Public Money

Should not invisibly increase private IP value without:

arrangement.

N.241Commercialization Rights

If public asset can later be commercialized:

Decide in advance.

N.242Revenue Share

Possible.

N.243Open Source

Possible.

N.244Public Domain

Possible where lawful.

N.245Municipal Licence

Possible.

N.246Private Retention

Possible only with defensible public benefit.

N.247Founder Royalty

High conflict threshold.

N.248Do Not Negotiate Own Royalty With City

No.

N.249Independent Negotiation

Required.

N.250Public Value

Demonstrate.

N.251Private Business Time

Mayor should clearly separate:

in practice.

N.252Mayor Is Not Hourly Employee

True.

N.253Therefore "Hours" Are Not Perfect Boundary

Better question:

What role is being exercised?

N.254Municipal Role

If meeting occurs because person is Mayor:

Treat as:

N.255Private Role

If meeting concerns private company sales:

Treat as:

N.256Mixed Meeting

Avoid where possible.

N.257If Mixed

Split agenda.

Record:

N.258Example

Municipal conference meeting:

First:

Then if appropriate and ethically permissible:

Separate private discussion after clear transition.

N.259Better

Schedule separately.

N.260No Municipal Introduction as Private Sales Leverage

Mayor should not say to another mayor:

As Mayor of Owen Sound, I want you to buy my company product.

N.261Public Office Network

Should not become:

N.262Private Business Can Exist

But business development must not exploit:

N.263Business Card

Separate.

N.264Municipal Email

Not private sales email.

N.265City Letterhead

Not private sales letterhead.

N.266Mayor Title

Use carefully in private commercial context.

N.267Biography

Factual public office can be mentioned where appropriate.

N.268But

Do not imply:

N.269"Mayor of Owen Sound recommends..."

High concern if referring to own private company.

N.270Private Company Website

Should not imply City adoption that does not exist.

N.271City Website

Should not market private founder business.

N.272Neutral Public Directory

Different.

N.273If map.ca / RealMap Appears in Neutral Directory

Same rules as:

No.

N.275No Exclusion of Competitor

No.

N.276Communications Firewall

City communications should serve:

N.277Campaign Communications

Serve:

N.278Private Communications

Serve:

N.279Separate Branding

Essential.

N.280Owen Sound's current election-resource policy prohibits candidate use of City branding, City-funded web properties, City email and voicemail, corporate IT and data, City communications staff and City-created photo or video for campaign purposes.

N.281Extend the Principle Beyond Election Day

Municipal communications should never function as:

N.282Mayor Update

Can explain:

N.283Mayor Update Should Not Say

Visit my private company to solve this.

N.284Public Policy Discussion

Can reference market examples when necessary.

N.285Founder Product

Higher disclosure.

N.286Press Conference

No private product placement.

N.287City Video

No private product demonstration unless part of:

N.288City Photographer

Not private marketing photographer.

N.289City Social Media

Not campaign or private channel.

N.290Campaign Can Share City Post

Like any member of public.

N.291But City Should Not tailor post to:

N.292Official Mayor Social Account

Needs clear policy.

N.293Personal Political Account

Different.

N.294Campaign Account

Different.

N.295Do Not Quietly Convert Campaign Account Into Official City Account

Without clear:

decision.

N.296Followers

Not municipal property automatically.

N.297City Account

Should be institutionally controlled.

N.298Passwords

City-controlled.

N.299Account Survives Mayor

Yes.

N.300Official Website

Same.

N.301Mayor Domain

If personal:

N.302City Domain

Municipal.

N.303map.ca Domain

Private unless lawfully transferred.

N.304Do Not Blur

N.305City Events

Campaign participation should comply with:

N.307Equal Terms

Critical.

N.308Incumbent

Same rental terms.

N.309Challenger

Same.

N.310Private Company

Same ordinary commercial terms where facility use allowed.

N.311No Free Room Because Mayor Owns Company

No.

N.312No Hidden Staff Support

No.

N.313City Event Sponsorship

If Mayor-associated company wants to sponsor:

Enhanced conflict review.

N.314Better Default

Avoid founder-associated sponsorship of City events during term unless independent review establishes:

N.315Why

Even small sponsorship can create:

N.316Donation

Same concern.

N.317"Free Gift"

Still benefit.

N.318Gifts and Hospitality

Current Owen Sound Code contains a dedicated gifts, benefits and hospitality framework.

N.319This Appendix Adds Founder-Specific Rule

Do not accept gifts from a vendor seeking:

as a way to normalize relationship.

N.320Mayor-Owned Company Gift to City

Requires same scrutiny as:

plus conflict review.

N.321Free Software Licence

Gift or contract implications.

N.322Free Equipment

Same.

N.323Free Consulting

Same.

N.324Free Hosting

Same.

N.325Free Trial

Same.

N.326"No Cost"

Does not mean:

N.327Political Gifts

Campaign contribution rules separate.

N.328Campaign Donation

Does not buy:

N.329Procurement Donor Firewall

Procurement evaluator should not be selected because:

N.330Donor Identity

Need not be routinely injected into procurement.

Handle appropriately.

N.332No Donor Blacklist Either

Political contribution should not penalize:

N.333Campaign Contribution Rules

Use current election law.

N.334Private Corporations and Campaigns

A private corporation is legally distinct from:

N.335Third-Party Advertising

Owen Sound's current 2026 election guidance states that candidates cannot register as third-party advertisers and that registered third-party advertising must operate independently of candidates.

N.336Therefore

A candidate-controlled business should not be used as:

an indirect campaign advertising arm

to evade candidate campaign rules.

Obtain:

N.338Do Not Coordinate Through Back Channel

No.

N.339Private Company Employees

May have personal political rights.

N.340Employment Pressure

Do not require private employees to:

N.341Voluntary Political Activity

Separate.

N.342Business Customer List

Do not use for campaign without:

N.343Conversely

Campaign list should not become:

N.344"Same People"

Not same purpose.

N.345City Officials and Private Employees

Do not blur reporting lines.

N.346Private employee should not direct City staff

No.

N.347City staff should not direct private company

Unless acting through:

N.348Private Employee at City Meeting

Identify role.

N.349Mayor's Private Advisor

Does not gain municipal authority.

N.350Campaign Advisor

Does not gain municipal authority.

N.351If Appointed to City Job

Then:

rules apply.

N.352No Automatic Job

N.353No Automatic Consulting Contract

N.354No Automatic Board Appointment

N.355Appointments

Should use:

where appropriate.

N.356Campaign Loyalty

Not qualification.

N.357Political Opponent

Should not be disqualified merely because:

N.358Staff Hiring

Mayor should not seek to use appointment powers to reward:

N.359Strong-Mayor Powers

Particularly sensitive.

N.360Personnel Firewall

For any statutory mayoral staffing authority:

Role first.

Qualifications first.

Public need first.

Conflict review.

N.361Campaign Staff Candidate

Can be qualified.

N.362But Relationship

Should be:

N.363Independent HR Input

Useful.

N.364No Fictitious Competition

Do not advertise job if outcome:

N.365No Political Loyalty Requirement for Professional Staff

No.

N.366City Manager

Must serve:

N.367Not campaign.

N.368Political Office Staff

If Ontario municipal law permits specific structures, define separately.

N.369Do Not Invent Unfunded Mayor's Private Office

No.

Conflict rules may extend beyond the official's direct personal interest depending on:

N.371Therefore

Do not attempt to create own legal family definition.

Use:

N.372Governance Standard

If close family member could materially benefit:

Seek:

N.373Family Business

High concern.

N.374Family Employment

High concern.

N.375Family Property

Potential concern.

N.376Ordinary Citywide Benefit

Different.

N.377Do Not Treat Every General Policy as Family Conflict

No.

N.378But

Do not hide specific benefit inside:

Look through:

where law requires.

N.380Ownership Disclosure

Sufficient to permit proper advice.

N.381No Hidden Beneficial Interest

N.382Private Meetings

Mayor will meet:

That is normal.

N.383Meeting Itself Is Not Improper

No.

N.384But

Founder-associated opportunity creates boundary issue.

N.385Municipal Meeting Register

For material external meetings involving:

a public meeting register could improve transparency where lawful.

N.386Proposed Fields

Date

Organization

General Topic

Municipal Participants

N.387Do Not Publish

N.388Private-Business Meeting

Keep separate.

N.389If Person Meets Mayor Because of Office

Treat as:

N.390If They Also Want Private Product

Do not pivot casually.

N.391Say

That is a private matter and should be scheduled separately.

N.392Lobbying

If City establishes lobbying registry:

Apply equally.

N.393No Founder Exemption

N.394No Opponent Penalty

N.395Access

Mayor should not give preferred vendors:

N.396But

Mayor must be able to hear:

N.397Listening Is Not Procurement

Correct.

N.398Meeting Is Not Commitment

Correct.

N.399"Send it to staff"

Can be proper.

N.400But

Staff should evaluate:

N.401No "I Already Promised Them"

No.

N.402Developer Meeting

Same.

N.403Investor Meeting

Same.

N.404Community Organization

Same.

N.405Open Door

Good.

N.406Favouritism

Not.

N.407Private Real-Estate Work

If Mayor remains involved in private real estate:

Establish additional practical boundaries.

N.408City Development Information

Confidential information obtained through office must not be used for:

N.409Upcoming Municipal Land Sale

No private use.

N.410Confidential zoning discussion

No private use.

N.411Infrastructure timing

If non-public and material:

No private use.

N.412Development lead

No private brokerage solicitation.

N.413Resident property issue

No private client recruitment.

N.414City Introduces Business

No automatic private lead.

N.415Private Brokerage Client

If requires City service:

Use normal:

N.416No Fast Lane

No.

N.417No Slow Lane for Competitor

No.

N.418Planning Staff

Must not be asked to:

outside normal lawful process.

N.419Mayor Can Advocate for Better System

For everyone.

N.420Not Queue-Jump for Specific Client

N.421Private Property Owned by Mayor

Municipal service should be:

N.422Permit

Ordinary process.

N.423Inspection

Ordinary process.

N.424Tax

Ordinary process.

N.425Enforcement

Ordinary process.

N.426No Special Access

N.427No Special Punishment

N.428Firewalls Protect Mayor Too

Yes.

N.429Complaint

If someone alleges private benefit:

There should be:

to answer.

N.430Campaign Branding

Campaign slogan should remain:

N.431City Strategic Plan

Should not simply adopt campaign slogan as:

N.432Campaign Policy

Can become municipal proposal.

N.433But It Must Go Through

process as appropriate.

N.434"It Was My Platform"

Not authority.

N.435Election Mandate

Politically relevant.

N.436But

Does not erase:

N.437City Communications

Should describe adopted policy as:

City policy

not:

Mayor's campaign promise

after lawful adoption.

N.438Credit

Can acknowledge origin where relevant.

N.439But Public Asset Belongs to

N.440Public Playbook

If initiative developed publicly:

Other municipalities should be able to reuse where intended.

N.441No Hidden Founder Licence

If public playbook says:

N.442Campaign Photos

Do not become official City photo library automatically.

N.443City Photos

Do not become campaign library automatically under current resource policy. Owen Sound's current election policy specifically prohibits use of City-created photographic and video material in campaign materials.

N.444Personal Photo

Different.

N.445Publicly Available City Fact

Campaign may discuss:

N.446City Staff Draft

Do not ask staff to:

N.447Campaign Fact Check

Campaign pays / performs.

N.448City Correction

If official City information is wrong:

City corrects for everyone.

N.449Incumbent Criticism

City communications should not become:

N.450Staff Can Correct False Statement About City Operations

Through neutral:

communication.

N.451Not Personal Attack

N.452Press Office Firewall

Communications staff should distinguish:

Municipal information request

from

campaign media request.

N.453Reporter Asks About City Policy

Municipal.

N.454Reporter Asks Why Candidate Deserves Re-Election

Campaign.

N.455Reporter Asks About Private Company

Private.

N.456Mixed Question

Separate answers.

N.457Contact Channels

Provide correct:

contact.

N.458No Staff Answering Campaign Phone

No.

N.459No Campaign Volunteer Answering City Phone

No.

N.460Municipal Newsletter

No campaign ask.

N.461No "Vote for"

Obvious.

N.462No Subtle Incumbent Promotion

Election-period resource policy should be interpreted and followed according to:

N.463Official Achievements

Government still has obligation to communicate:

N.464Election Does Not Shut Down Government

Correct.

N.465Distinction

Communicate:

Avoid:

N.466Election-Year Work

Should continue where:

N.467Do Not Stop Infrastructure Repair Because Election

No.

N.468Do Not Accelerate Ribbon Cutting Because Election

No.

N.469Do Not Delay Bad News Until After Election

No.

N.470Do Not Rush Good News Before Verification

No.

N.471Strong-Mayor Election Transition

Current Ontario regulation imposes specific election-period restrictions on certain mayoral powers once defined electoral conditions are met. The municipal firewall should incorporate those rules into the election-transition checklist rather than relying on memory.

N.472Election Transition Checklist

Strong-mayor restrictions checked

Resource policy active

Staff communications guidance issued

Campaign contacts separated

Municipal accounts secured

Conflict-sensitive files independently assigned

N.473Candidate Incumbency

Incumbent may still:

N.474Challenger Equality

City should not provide incumbent with candidate services unavailable to:

N.475City Election Information

Neutral.

N.476Current Candidate Information

Owen Sound's 2026 candidate materials explicitly state that the City does not endorse or support any candidate.

N.477Keep That Principle

Beyond candidate listing.

N.478Third-Party Groups

City should not coordinate campaign activity with:

N.479Candidate

Likewise.

N.480Private Business Advocacy

Issue advocacy and election advertising can engage different rules.

Seek:

where related private entities participate.

N.481No Corporate Back Door

Core.

N.482Donations and Sponsorships During Election Year

Extra scrutiny.

N.483Municipal Sponsor

Should not become:

N.484Private Founder Company Sponsor

Avoid heightened conflict where possible.

N.485City-Funded Event

No campaign stage.

N.486Candidate Debate

Different.

May be hosted under:

N.487Equal Invitation Rules

Where relevant.

N.488City Facility

Use ordinary terms.

N.489Campaign Event

Current City policy permits ordinary facility use under standard agreements and fees while maintaining resource restrictions.

N.490Municipal Equipment

No campaign use.

N.491Municipal Vehicle

No campaign use.

N.492City Uniform

No campaign staging where policy prohibits or creates endorsement impression.

N.493Public Asset

Campaign may use public space only under:

as others.

N.494Campaign Sign

Separate by-law.

N.495Real-Estate Sign Reform

Do not combine with:

N.496Policy Independence

Critical.

N.497Private-to-Public Asset Transfer

If founder wishes to donate private IP to City:

Donation still needs:

N.498Why

Gift can carry:

N.499Donation Does Not Cure Conflict

No.

N.500$1 Sale

Same.

N.501$0 Licence

Same.

N.502Independent Acceptance Review

Required for material founder-associated gift.

N.503Questions

Do we need it?

Who owns it?

Are rights clear?

What liabilities attach?

What does maintenance cost?

Can City modify it?

Can City share it?

Can City abandon it?

N.504No Ceremonial Donation

Before review.

N.505Transfer Before Adoption

Could reduce conflict.

N.506But

Only if transfer is:

N.507Founder Retained Royalty

Means private interest remains.

N.508Founder Retained Control Right

Means private interest remains.

N.509Founder Retained Veto

Means private interest remains.

N.510Founder Retained Exclusive Commercialization

Means private interest may remain.

N.511Public Ownership Claim

Must match:

N.512No "Community-Owned" Marketing

Unless governance actually reflects:

N.513Independent Nonprofit

Must be genuinely independent.

N.514Founder Appoints Majority Forever

Not independent.

N.515Founder Veto

Not independent.

N.516Board Filled With Campaign Team

Not convincingly independent.

N.517Governance Independence Test

Who appoints?

Who removes?

Who votes?

Who owns assets?

Who controls budget?

Who benefits?

Who can amend bylaws?

N.518Public Benefit Corporation / Nonprofit

Legal form alone does not guarantee:

N.519Governance Substance

Matters.

N.520Data and Private Platforms

No founder-associated private platform should obtain:

N.521Public Data

Can be open to:

under same terms.

N.522Protected Data

No.

N.523Early Access

Can create:

N.524Embargoed Data

No founder preference.

N.525Draft City Data

No.

N.526Resident Feedback

No.

N.527Business Registration Data

No.

N.528Tender Information

No.

N.529Upcoming Land Decision

No.

N.530Confidential Development Information

No.

N.531Municipal Analytics

No private use.

N.532AI Training

City data should not train founder-associated commercial AI without:

N.533Public Open Data

Could be used like anyone else.

N.534Private Platform User Data

City should not receive:

merely because founder is Mayor.

N.535"Helpful Insight"

Still data transfer.

N.536Aggregate Public Insight

Could be provided under:

N.537Personal Data

No.

N.538Data Sharing Agreement

Does not cure conflict alone.

N.539Independent Need

First.

N.540MFIPPA

Municipal personal information remains governed by Ontario's municipal freedom-of-information and privacy framework.

N.541Campaign List

Not exempt from election / privacy responsibility because:

N.542Data Minimization

Appendix J.

N.543Records

Conflict-related municipal decisions should be:

N.544But

Do not create unnecessary public record of:

N.545Conflict File

Maintain appropriate:

N.546Privileged Advice

Protect.

N.547Public Explanation

Where possible:

Explain:

without revealing privileged details.

N.548Recusal Record

Clear.

N.549Current Owen Sound Practice

The City's accountability page maintains an index of written pecuniary-interest declarations and notes the current legal requirement for written statements of an interest and its general nature.

N.550Additional Founder-Sensitive Register

Could publicly identify:

File

Mayor Participation Status

Independent File Owner

Review Status

N.551Do Not Publish

N.552Public Should Know

Who is making the decision?

N.553Conflict Does Not Require Project Disappearance

Sometimes project can proceed through:

N.554Sometimes

Project should stop.

N.555Sometimes

Private asset should transfer.

N.556Sometimes

Open competition solves.

N.557Sometimes

Independent nonprofit solves.

N.558Sometimes

No lawful or credible firewall exists.

N.559Then

Do not proceed.

N.560Conflict Risk Levels

For internal governance:

Level 0 - No Known Private Connection

Level 1 - Remote / General Connection

Level 2 - Material Appearance or Relationship

Level 3 - Direct Private Interest

Level 4 - Direct Financial Interest in Proposed Municipal Transaction

N.561This Is Governance Tool

Not legal classification.

N.562Statutory Conflict Still Determined Under Law

Yes.

N.563Level 0

Normal process.

N.564Level 1

Disclosure if appropriate.

N.565Level 2

Independent screening.

N.566Level 3

Likely recusal / independent file ownership subject to legal advice.

N.567Level 4

Maximum safeguards and legal review.

N.568Do Not Self-Assign Lower Level

Independent review for founder-sensitive file.

N.569Independent File Owner

Should receive authority to:

N.570Mayor Should Not Receive Confidential Updates

If legally recused from:

N.571Public Information

Mayor can receive like:

only as law permits.

N.572No Informal Text Messages

To file owner.

N.573No "Just Curious"

Back channel.

N.574No Proxy Influence

Through:

N.575MCIA Head-of-Council Rule

Ontario's current statute expressly addresses attempts by a head of council with a pecuniary interest to use office to influence municipal decisions relating to specified mayoral powers.

N.576Recusal Scope

Follow exact legal advice.

N.577Do Not Invent Rule

No.

N.578Integrity Commissioner Advice

Use early.

N.579Advice Before Decision

Better than:

N.580Written Advice

Where appropriate.

N.581Facts Supplied

Must be complete.

N.582Do Not Omit

where material.

N.583Advice Can Become Stale

If facts change.

N.584Re-ask.

N.585Provincial Reform

Because Ontario enacted but has not yet brought into force its 2026 municipal accountability changes, the incoming Council should recheck the Integrity Commissioner and code-of-conduct framework once the new term begins.

N.586Gifts and Benefits

Founder-sensitive procurement should avoid:

that could complicate independence.

N.587Conference

Normal networking possible.

N.588Vendor-Paid Travel

Higher concern.

N.589City-Paid Official Travel

Municipal.

N.590Private-Company-Paid Travel

Private.

N.591Mixed Trip

Separate costs.

N.592No City Paying Private Sales Trip

No.

N.593No Private Company Paying Municipal Procurement Trip

Without appropriate:

N.594Travel Log

For material official travel:

N.595Expense

Appendix E.

N.596Private Meeting During Official Trip

If unavoidable:

Separate.

N.597City Staff

Should not attend as private sales support.

N.598Private Staff

Should not attend confidential municipal meeting without:

N.599Conference Booth

If private company booths:

Mayor should not staff it in apparent:

N.600Title Usage

Distinguish.

N.601Private Investment

Mayor may invest.

N.602But

Cannot use non-public municipal information to:

N.603Confidential Information

Never private benefit.

N.604Land Purchase

Particularly sensitive.

N.605If City planning confidentially affects parcel

Do not use information privately.

N.606Business Purchase

Same.

N.607Technology Company Investment

Same.

N.608Former Private Activity

Pre-election activity should be documented where it later intersects:

N.609Prior Proposal to City

Disclose.

N.610Prior Negotiation

Disclose.

N.611Prior Licence

Disclose.

N.612Prior Relationship With Vendor

Disclose where material.

N.613Historic Business Dispute

Could affect appearance.

N.614Does Not automatically require:

N.615Seek advice.

N.616Staff Personal Interests

This appendix should also protect against staff:

N.617Employee Ethics

Existing City rules apply.

N.618Procurement Staff

Declare conflicts.

N.619Developer Relationship

Declare.

N.620Vendor Family Member

Declare.

N.621No Mayor Exception

No staff exception either.

N.622Council-Wide Standard

Apply generally.

N.623But Founder-Specific Rules

Needed because:

create unusual overlap.

N.624Public Cannot Be Asked to Pretend That Overlap Does Not Exist

No.

N.625Better

Design around it.

N.626Complaint Process

Residents should know where to raise concerns regarding:

N.627Different Complaints

Different routes.

N.628Integrity Commissioner

Member conduct / conflict issues within jurisdiction.

N.629Clerk

Election administration / municipal process as applicable.

N.630Procurement

Procurement complaint process.

N.631Privacy

MFIPPA / privacy process.

N.632Employee Ethics

City employee process.

N.633No One Giant Political Complaints Office

No.

N.634Route Correctly

N.635Whistleblower Protection

Staff should have route to report:

N.636Without Retaliation

Critical.

N.637Anonymous Reporting

May be useful.

N.638But

Not every complaint can be investigated anonymously.

N.639Good-Faith Complaint

Protect.

N.640Malicious Complaint

Different.

N.641Criticism

Not misconduct by itself.

N.642Investigation

Independent where Mayor is:

N.643Mayor Should Not Select Investigator

No.

N.644Mayor Should Not Set Scope

No.

N.645Mayor Should Not Receive Draft for Approval

No.

N.646Mayor Can Respond to Allegation

Yes.

N.647Procedural Fairness

Applies.

N.648Public Result

Follow legal process.

N.649No Trial by Social Media

No.

N.650No Political Exoneration by Self-Statement

No.

N.651Evidence

Appendix H.

N.652Correction

If allegation unsupported:

Say.

N.653If breach found:

Say according to lawful process.

N.654Remediation

More important than:

N.655Procurement Remedy

Could include:

N.656Data Remedy

Could include:

N.657Communication Remedy

Could include:

N.658Resource Misuse

Could require:

where applicable.

N.659Campaign Finance

Follow election law.

N.660Compliance Audit

Owen Sound participates in a Grey County joint compliance-audit framework for 2026 campaign-finance applications under the Municipal Elections Act.

N.661This Is Separate From Municipal Ethics Complaint

Yes.

N.662Do Not Mix

into one accusation.

N.663Specificity

Protects fairness.

N.664Post-Election Transition

If elected:

Firewall starts:

N.665Campaign Wind-Down

Campaign still has financial-reporting obligations after:

N.666Campaign Treasurer / Records

Remain campaign.

N.667City Finance

Not campaign bookkeeper.

N.668No City Staff Preparing Campaign Financial Statement

No.

N.669No City Auditor Doing Campaign Return as City work

No.

N.670Campaign Debt

Private campaign matter.

N.671Campaign Surplus

Election-law matter.

N.672Inauguration

Municipal event.

N.673Campaign Celebration

Campaign / private event.

N.674Keep Costs Separate

N.675Transition Team

If informal campaign transition team assists:

They do not automatically receive:

N.676Background Briefings

City decides what can be shared.

N.677Incoming Mayor

May receive official transition information according to:

N.678Private Advisors

Not automatically.

N.679NDA

Does not create entitlement to:

N.680Municipal Appointment

Required where role requires.

N.681First 24 Hours in Office

Change:

appropriately.

N.682Campaign Phone

Could remain personal.

N.683City Phone

Institutional.

N.684Contact Forwarding

Carefully designed.

N.685Residents Will Keep Using Campaign Contact

Expected.

N.686Response

Direct them to:

for municipal files.

N.687Do Not Build Municipal record inside campaign inbox

No.

N.688If substantive City matter arrives there

Forward to appropriate:

then continue municipally.

N.689Preserve record as required.

N.690First 30 Days

Create:

Conflict and Firewall Baseline.

N.691First 30-Day Actions

File required statutory declarations.

Publish appropriate voluntary public-interest disclosure.

Inventory founder-associated municipal proposals.

Assign independent owners to conflict-sensitive files.

Separate accounts and data.

Brief senior staff on firewall.

Confirm campaign resource separation.

N.692First 30 Days

Review:

and classify each:

Private Only

Potential Municipal Relevance

Independent Review Required

Not Proceeding

N.693No Assumption of Adoption

None.

N.694First 30 Days

Freeze any founder-associated municipal procurement until:

N.695Freeze Does Not Mean Reject

It means:

N.696First 60 Days

Publish:

Founder-Associated Initiative Review Protocol.

N.697Protocol Should Define

File owner

Procurement reviewer

Privacy reviewer

Valuation trigger

Public reporting

Mayor participation limits

N.698First 60 Days

Create:

Private / Campaign / Municipal Data Separation Checklist.

N.699First 60 Days

Review municipal websites and accounts for:

N.700First 60 Days

Review official social media ownership.

N.701First 60 Days

Confirm intellectual-property boundaries.

N.702First 100 Days

Complete independent initial review of any founder-associated system the City may reasonably consider.

N.703Review Is Not Adoption

Again.

N.704First 100 Days

Publish non-privileged conclusions:

Proceed to Further Review

Compete

Transfer / Restructure

Hold

Stop

N.705First 100 Days

Establish staff escalation route.

N.706Year One

Primary objective:

Make the firewall institutional rather than dependent on personal restraint.

N.707Year One

Complete:

N.708Year One

Any municipal use of map.ca or RealMap should occur only after:

N.709If Gates Fail

Stop.

N.710No Sunk-Cost Argument

N.711Year Two

Audit whether firewall worked in:

N.712Questions

Did staff receive improper private requests?

Were conflicted files independently managed?

Did founder data cross boundaries?

Were campaign accounts used for municipal business?

Were private companies given unusual access?

N.713Fix Weakness

N.714Year Two

Review private-interest disclosure for:

N.715Year Three

Review institutionalization.

N.716Ask

Would this firewall still work if the Mayor were less careful?

N.717If No

Strengthen.

N.718Governance Should Protect Against

N.719Year Three

Review related digital platform ownership.

N.720If municipal dependence remains on founder-controlled asset

Reassess.

N.721Year Four

Election year deserves:

N.722Do Not Relax Because Record Is Good

No.

N.723Election-Year Review

Before nomination period / campaign period:

Resource policy

official accounts

staff guidance

event rules

City photography

municipal communications

founder-associated businesses

data separation

strong-mayor transition rules

N.724Incumbent Candidate

Should be able to run vigorous:

N.725But

Using:

N.726Government Continues

Using:

N.727Private Businesses Continue

Using:

N.728Three Systems

Remain.

N.729Four-Year Audit

Publish:

Campaign, Private Interest and Municipal Firewall Audit.

N.730Audit Should Answer

What material interests were disclosed?

What founder-associated municipal files arose?

Which were independently reviewed?

Which proceeded?

Which stopped?

Which entered procurement?

Which transferred ownership?

Which remained private?

What recusals occurred?

Were any municipal resources improperly used?

Were any data-boundary incidents identified?

Were any procurement processes restarted?

Were any staff concerns raised?

What changes followed?

N.731Do Not Publish Protected Details

No.

N.732Public Audit

Should be enough to establish:

N.733Name map.ca Outcome

Clearly.

N.734Name RealMap Outcome

Clearly.

N.735Possible Outcomes

Municipally Adopted After Independent Process

Open Standard Adopted Instead

Independent Nonprofit Model

Remained Private

Not Proceeding

N.736No Face-Saving Category

No.

N.738Show Result

N.740State consideration

Where lawful and appropriate.

N.741Name Any Private Benefit Safeguard

N.742Name Any Firewall Failure

If one occurred.

N.743Name Remediation

N.744Election-Year Resource Review

Include.

N.745Handoff

The next Council receives:

Relevant interest disclosures

Founder-sensitive file list

Independent review records

Procurement status

Public-ownership agreements

IP agreements

Data-sharing restrictions

Recusal history

Pending conflict advice

Election-resource procedures

N.746No Conflict Surprise

Next Council should not discover:

The Mayor's company owns the software City depends upon.

N.747Or

The domain is personally owned.

N.748Or

The City cannot leave without founder permission.

N.749Or

Municipal data was copied into a private platform.

N.750Or

City staff developed private commercial IP.

N.751Or

A campaign list became the City's communications list.

N.752Or

City resident data went to campaign.

N.753Or

A municipal procurement was designed by the person financially benefiting from it.

N.754Or

Nobody documented the conflict because everybody trusted each other.

N.755Anti-Gaming Rule One

Do not say:

There is no conflict because I disclosed it.

N.756Rule Two

Do not say:

There is no conflict because City pays nothing.

N.757Rule Three

Do not say:

There is no conflict because project is good.

N.758Rule Four

Do not say:

There is no conflict because I would have done this even if I were not Mayor.

N.759Rule Five

Do not say:

There is no conflict because everyone knows I own it.

N.760Rule Six

Do not self-certify:

N.761Rule Seven

Do not use public office to create:

N.762Rule Eight

Do not use City adoption to increase private company valuation without:

N.763Rule Nine

Do not call software:

free

if municipal adoption creates private commercial benefit.

N.764Rule Ten

Do not allow founder to:

N.765Rule Eleven

Do not allow founder to:

N.766Rule Twelve

Do not allow founder to:

N.767Rule Thirteen

Do not allow founder to:

N.768Rule Fourteen

Do not allow founder to:

N.769Rule Fifteen

Do not allow founder to:

N.770Rule Sixteen

Do not use private meeting to:

N.771Rule Seventeen

Do not use intermediary to:

N.772Rule Eighteen

Do not text staff about file after:

N.773Rule Nineteen

Do not use Council ally to:

N.774Rule Twenty

Do not use campaign volunteer as:

N.775Rule Twenty-One

Do not give donor:

N.776Rule Twenty-Two

Do not punish donor's competitor.

N.777Rule Twenty-Three

Do not hire campaign supporter because:

N.778Rule Twenty-Four

Do not reject qualified campaign opponent because:

N.779Rule Twenty-Five

Do not turn public-policy campaign mandate into:

N.780Rule Twenty-Six

Do not write:

City shall use map.ca

before independent governance / procurement review.

N.781Rule Twenty-Seven

Do not write:

City shall use RealMap

into sign regulation.

N.782Rule Twenty-Eight

Do not create regulatory burden whose practical purpose is to force residents toward:

N.783Rule Twenty-Nine

Do not make private platform a condition of:

N.784Rule Thirty

Do not give private platform early access to:

N.785Rule Thirty-One

Do not give private platform non-public data because:

N.786Rule Thirty-Two

Do not give City private customer data because:

N.787Rule Thirty-Three

Do not merge City and private analytics.

N.788Rule Thirty-Four

Do not train private commercial AI on protected City information without:

N.789Rule Thirty-Five

Do not train City system on private customer data without:

N.790Rule Thirty-Six

Do not use City employees to:

private business.

N.791Rule Thirty-Seven

Do not use City contractors for private work billed to:

N.792Rule Thirty-Eight

Do not use City equipment for:

N.793Rule Thirty-Nine

Do not use City photography for campaign contrary to current election-resource rules.

N.794Rule Forty

Do not use City logo or branding for campaign contrary to current policy.

N.795Rule Forty-One

Do not use City email for campaign activity contrary to current policy.

N.796Rule Forty-Two

Do not use City data for campaign activity.

N.797Rule Forty-Three

Do not transfer campaign contact list into City database.

N.798Rule Forty-Four

Do not transfer City resident list into campaign database.

N.799Rule Forty-Five

Do not transfer City business directory into private sales CRM unless information is separately public and used on the same terms available to everyone.

N.800Rule Forty-Six

Do not use municipal office to obtain private sales introductions.

N.801Rule Forty-Seven

Do not use title of Mayor to imply municipal endorsement of:

N.802Rule Forty-Eight

Do not use municipal conference as private trade show through:

N.803Rule Forty-Nine

Do not mix private invoice into:

N.804Rule Fifty

Do not mix City expense into:

N.805Rule Fifty-One

Do not have private company pay official municipal expense unless proper:

process exists.

N.806Rule Fifty-Two

Do not have City pay private company expense.

N.807Rule Fifty-Three

Do not accept founder-associated donation without:

N.808Rule Fifty-Four

Do not treat donation as cure for:

N.809Rule Fifty-Five

Do not describe platform as publicly owned until:

actually supports statement.

N.810Rule Fifty-Six

Do not describe nonprofit as independent if founder retains:

N.811Rule Fifty-Seven

Do not create board of campaign allies and call it:

N.812Rule Fifty-Eight

Do not hide founder royalty.

N.813Rule Fifty-Nine

Do not hide related IP interest.

N.814Rule Sixty

Do not hide related domain ownership.

N.815Rule Sixty-One

Do not hide option, warrant or future payment.

N.816Rule Sixty-Two

Do not route payment through:

to disguise benefit.

N.817Rule Sixty-Three

Do not use related nonprofit as:

to avoid conflict.

N.818Rule Sixty-Four

Do not use unrelated-looking corporation if beneficial control remains:

N.819Rule Sixty-Five

Do not use recusal theatrically while exercising:

N.820Rule Sixty-Six

Do not receive confidential file updates after withdrawal where law and advice prohibit involvement.

N.821Rule Sixty-Seven

Do not pressure staff who request:

N.822Rule Sixty-Eight

Do not punish whistleblower.

N.823Rule Sixty-Nine

Do not direct Integrity Commissioner.

N.824Rule Seventy

Do not select investigator into your own conduct.

N.825Rule Seventy-One

Do not approve investigator's draft findings.

N.826Rule Seventy-Two

Do not dismiss complaint merely because:

without examining evidence.

N.827Rule Seventy-Three

Do not sustain complaint merely because:

N.828Rule Seventy-Four

Do not conflate:

Use precise terms.

N.829Rule Seventy-Five

Do not label lawful interest:

without evidence.

N.830Rule Seventy-Six

Do not minimize actual statutory conflict as:

N.831Rule Seventy-Seven

Do not hide behind legal minimum when stronger governance safeguard is reasonably available.

N.832Rule Seventy-Eight

Do not invent stricter legal requirement than law actually imposes.

N.833Rule Seventy-Nine

Do not let conflict policy paralyze:

N.834Rule Eighty

Use proportionality.

N.835The Three-System Test

Is this campaign, private or municipal activity?

N.836The Authority Test

What public authority is being exercised?

N.837The Private-Benefit Test

Could this decision materially increase the official's private financial or commercial position?

N.838The Appearance Test

Could a reasonable resident reasonably question the independence of the process?

N.839The Disclosure Test

Has the relevant interest been disclosed to the proper authority?

N.840The Recusal Test

Does current law or prudent governance require withdrawal?

N.841The Influence Test

After withdrawing, is the official still influencing the matter directly or indirectly?

N.842The Staff Test

Would staff feel free to disagree with the Mayor on this file?

N.843The Procurement Test

Would another supplier receive the same path?

N.844The Founder Test

Would we accept this process if the private platform belonged to a political opponent?

N.845The Reverse-Founder Test

Would we impose these same safeguards if the founder were someone we liked less?

N.846The Public-Ownership Test

Who legally owns the domain, software, IP, data and administrative control?

N.847The Windfall Test

Does municipal adoption increase a private asset's value even if no City money changes hands?

N.848The Data Test

Did information cross campaign, private or municipal boundaries?

Was information collected for the purpose for which it is now being used?

N.850The Staff-Resource Test

Did publicly paid staff contribute to private or campaign work?

N.851The Time Test

Was this meeting or work undertaken in a municipal, private or campaign capacity?

N.852The Account Test

Which email, device, cloud account and records system is being used?

N.853The Communications Test

Would a reasonable resident mistake this message for City endorsement of a campaign or private business?

N.854The Title Test

Is the title Mayor being used to create private commercial credibility?

N.855The Gift Test

Would City accept this gift on the same terms if it came from an unrelated business?

N.856The Appointment Test

Is this person being selected because they are best suited or because they helped the campaign?

N.857The Donor Test

Would this supplier receive the same treatment if they had donated to a different candidate?

N.858The Opponent Test

Would this resident or business receive the same service if they campaigned against the Mayor?

N.859The Confidentiality Test

Did public office provide information unavailable to ordinary market participants?

N.860The IP Test

Did public money or staff create value that remains privately owned?

N.861The Valuation Test

Who determined fair value and were they independent?

N.862The Free Test

If the City pays zero dollars, does somebody still receive material commercial value?

N.863The Exit Test

Can the City leave without the founder's permission?

N.864The Future-Mayor Test

Would we want the next Mayor to inherit the same power to benefit their own business?

N.865The Staff-Safety Test

Can a staff member flag this concern without fear?

N.866The Public Test

Could the process be explained openly without asking residents to simply trust the interested person?

N.867The Evidence Test

Can each safeguard be demonstrated through records rather than recollection?

N.868The Conflict Firewall Commitment

Owen Sound should commit to:

Maintain a hard institutional separation among campaign activity, private interests and municipal government.

Recognize that a person may lawfully be a business owner, inventor, candidate and public official while still requiring strong boundaries among those roles.

Use the Municipal Conflict of Interest Act, Municipal Act, Municipal Elections Act, MFIPPA and current City policies as the legal floor for the firewall.

Reverify the legal framework whenever Ontario changes municipal accountability law.

Recognize that Ontario enacted significant municipal accountability changes in 2026 that were not yet in force as of August 2026 and therefore require re-verification for the incoming term.

Recognize that Owen Sound is currently subject to the strong-mayor framework and that conflict safeguards must cover mayoral powers and directions as well as Council votes.

Comply with current statutory restrictions that apply when a head of council has a relevant pecuniary interest in matters involving specified mayoral powers.

Use the City's Integrity Commissioner and appropriate legal advice for conflict questions rather than allowing elected officials to self-certify compliance.

Maintain required declarations and written records.

Add a proportionate voluntary Public Interest Disclosure for significant private interests that could reasonably intersect with City business.

Keep that disclosure relevant rather than turning municipal transparency into unnecessary publication of unrelated private information.

Disclose founder roles and related interests in map.ca, RealMap and other private systems before any municipal evaluation of those systems.

Treat disclosure as the beginning of conflict management rather than automatic permission to participate.

Use recusal whenever current law requires it.

Use additional independent safeguards where appearance or institutional confidence reasonably requires them even if the exact statutory issue is broader or different.

Do not overuse recusal merely to avoid difficult political decisions.

Do not underuse recusal merely because an elected official believes personally that they can remain impartial.

Create a Campaign-to-Government Transition Protocol before inauguration.

Keep campaign staff, campaign volunteers, campaign donors and campaign endorsers separate from municipal appointments and employment unless they independently qualify through the appropriate process.

Never reward campaign activity with municipal employment, contracts or appointments.

Never punish political opponents through municipal service, contracts or appointments.

Keep campaign computers, email, websites, cloud storage and contact lists separate from municipal systems.

Keep private-company systems separate from both campaign and municipal systems.

Do not automatically forward municipal email into campaign or private accounts.

Move substantive municipal matters received through campaign channels into the official municipal record rather than continuing City business through campaign systems.

Never import campaign supporters, donors, canvass results, survey responses or political-preference information into municipal databases.

Never export resident-service information, permit contacts, business information, Civic Corps lists, seniors' contacts, Resident Pulse data or Strong Vote information to an election campaign.

Never merge private RealMap, map.ca, brokerage or other commercial customer data into municipal systems without a specific lawful municipal purpose and independent process.

Never export protected municipal data into private founder-associated platforms without lawful authority, independent review and proper agreement.

Ensure City staff work for the City rather than the Mayor personally, the campaign or the Mayor's businesses.

Never ask City staff to design, research, market, sell or support a private founder-owned product except pursuant to a lawful municipal arrangement under independent control.

Never ask City staff to prepare campaign content.

Give staff a protected way to identify requests that may cross the campaign-private-municipal boundary.

Protect employees who seek good-faith conflict review from retaliation.

Allow staff to escalate questionable requests to appropriate management, Clerk, legal or Integrity Commissioner channels.

Recognize that written mayoral direction requirements under the strong-mayor regime can strengthen accountability but do not themselves cure a conflict.

Automatically screen founder-sensitive mayoral directions for conflict before they are acted upon.

Keep the Mayor out of municipal specification, evaluation, negotiation and procurement decisions where a related private interest could benefit and the applicable legal or independent review requires separation.

Assign an independent municipal file owner to material founder-associated proposals.

Allow the Mayor to advocate for broad public policy goals such as better public mapping, property information or digital sovereignty without converting that advocacy into direction to purchase a related private product.

Separate Policy Objective from Supplier Selection.

Define the public standard first.

Allow the municipal organization and market to determine how that standard can best be delivered.

Use independent legal, procurement, privacy, cybersecurity, accessibility, financial and architecture review for material map.ca or RealMap municipal proposals.

Do not allow the founder to select all reviewers, control their scope or approve their conclusions.

Publish non-privileged findings where appropriate, including negative findings.

Do not suppress an independent recommendation merely because it would stop a founder-associated project.

Do not reject a founder-associated project merely to create an appearance of independence if it can demonstrate public value under a fair process.

Apply the same substantive standard with stronger process independence.

Require independent market evidence before claiming that only a founder-associated supplier can provide a service.

Treat prototypes as evidence of possibility rather than proof of procurement value, readiness or exclusivity.

Require a municipal business case before significant adoption.

Use independent valuation before the City purchases, licenses or receives material founder-associated intellectual property where value is significant.

Recognize that development cost, founder time and future potential are not by themselves fair market value.

Examine public ownership, open licensing and genuinely independent nonprofit structures where a founder-associated platform is intended to become public infrastructure.

Implement the original map.ca principle that protected public ownership should precede municipal adoption through actual legal governance rather than a verbal promise.

Define who owns the domain, trademarks, source code, databases, design files, accounts, administrative credentials and analytics before calling any system publicly owned.

Do not describe a system as community owned if the founder retains practical control.

Do not describe an organization as independent if the founder retains permanent veto, appointment or financial control.

Assess whether municipal adoption could create a private commercial windfall even when the City pays no money.

Recognize that municipal endorsement, reference-customer status, traffic, data and market credibility can create private value.

Do not treat Free as Conflict Free.

Do not allow City staff to become private sales references without independent authorization.

Do not use City branding to market founder-associated private products.

Require RealMap-related municipal policy to make public-policy sense even if RealMap disappeared.

Never regulate real-estate signs for the purpose of compelling use of RealMap.

Never make RealMap a municipal permit, regulatory or listing requirement without an independently justified lawful public process.

Do not reserve municipal open data to RealMap when comparable lawful access should be available under neutral terms.

Treat any map.ca pilot as a municipal pilot, not as an automatic endorsement, procurement award or permanent platform selection.

Use pre-established measures and stop conditions.

Permit a pilot to end with Stop.

Do not use public staff, public money or public information to invisibly increase the value of privately retained intellectual property.

Document pre-existing private IP before municipal development begins on a related concept.

Define ownership of new IP created through municipal work before the work begins.

Never negotiate a personal founder royalty with one's own municipality.

Use independent negotiation and valuation if a royalty or licence is legally and publicly justified.

Keep private-business meetings distinct from municipal meetings.

Avoid mixed-purpose meetings where possible.

Where a meeting changes from municipal to private subject matter, make the transition explicit or reschedule it separately.

Do not use municipal office and intergovernmental relationships as private sales channels.

Do not use a City email address, City letterhead or City staff for private business development.

Do not imply municipal endorsement through the title Mayor.

Do not give founder-owned products privileged placement in City directories, websites or events.

Apply the same neutral public-directory rules to competitors.

Maintain clear separation among municipal, campaign and private communications.

Continue to enforce Owen Sound's election-resource rules governing City branding, websites, IT, email, staff and City-created media during election periods.

Do not treat City communications staff as an incumbent political communications office.

Allow City staff to communicate accurate institutional information while keeping electoral persuasion with the campaign.

Separate official mayoral social media accounts from personal or campaign accounts.

Keep institutional account credentials under City control so public accounts survive a change of Mayor.

Do not silently convert campaign followers or account data into municipal property.

Use municipal facilities for campaign activities only according to the same lawful ordinary terms available under City policy.

Do not provide free municipal facility access, equipment or staff support to an incumbent campaign.

Apply the same lawful facility rules to challengers.

Apply heightened conflict review when a Mayor-associated business proposes to sponsor or donate to a municipal event.

Recognize that free software, equipment, consulting or hosting can still create contractual obligations, dependence or private commercial value.

Do not use campaign contributions, gifts or sponsorships as pathways to procurement advantage.

Do not penalize a supplier merely because the supplier supported another candidate.

Keep candidate campaigns legally separate from registered third-party advertisers and obtain election-law advice before any related private corporation participates in election advertising.

Never use a candidate-controlled company as an indirect campaign advertising vehicle designed to circumvent candidate campaign rules.

Keep private-company customer lists separate from candidate campaign lists unless lawful purpose and consent independently support the communication.

Never pressure private employees, contractors or clients to donate, volunteer or endorse.

Do not allow campaign volunteers or private advisors to exercise municipal authority merely because they have the Mayor's trust.

Require normal appointment, hiring, procurement and confidentiality processes before any such person receives municipal authority or access.

Apply heightened safeguards when campaign staff seek municipal employment or contracts.

Do not use strong-mayor staffing powers as a patronage system.

Use qualifications, public need and independent HR input for professional municipal appointments.

Seek conflict advice where close-family financial interests may be affected materially.

Do not invent municipal conflict law from intuition.

Do not treat every broad sectoral policy as a personal conflict merely because an elected official works in that sector.

Do not hide a specific private benefit inside a broadly framed policy.

Use transparent meeting records for material external municipal meetings where lawful and useful.

Do not turn normal mayoral accessibility to businesses and residents into secret preferential access.

Listen to ideas openly while keeping procurement and regulatory decisions independent.

Do not allow the Mayor's private real-estate interests or clients to receive accelerated municipal permits, planning decisions, inspections or service.

Do not delay a competitor's municipal matter because of private competition.

Never use confidential municipal planning, development, property, infrastructure or business information for private real-estate or investment advantage.

Keep campaign branding distinct from municipal strategic planning and City branding.

Recognize that an election mandate may create political support for a proposal but does not bypass Council, law, procurement, financial review or evidence.

Once a campaign proposal becomes duly adopted municipal policy, treat it as City policy rather than continuing to market it as an incumbent campaign product.

Do not use municipal photography, staff, websites or branding for campaign purposes contrary to Owen Sound's current election-resource policy.

Keep private-to-public asset transfers subject to due diligence even when the transfer price is one dollar or zero dollars.

Recognize that donated software, domains, land and equipment may carry substantial maintenance, legal and operational liabilities.

Use independent review before accepting material founder-associated donations.

Do not call an asset publicly owned until the legal transfer and governance actually make it so.

Do not call a nonprofit independent merely because it has been incorporated separately.

Examine appointment rights, vetoes, budgets, ownership and beneficial control.

Do not provide founder-associated private systems preferential access to non-public municipal information.

Provide open municipal data according to neutral standards where lawful.

Do not use municipal data to train commercial founder-associated AI systems without a specifically approved municipal purpose, independent process and lawful data governance.

Do not import private-platform behavioural analytics into municipal government merely because they could be interesting.

Apply MFIPPA and the City's privacy framework to municipal personal information.

Keep conflict-related municipal records sufficient to demonstrate what was disclosed, who decided, who withdrew and what independent safeguards were used.

Protect privileged and legitimately confidential material.

Provide public explanations of safeguards where doing so does not improperly disclose protected information.

Maintain the existing statutory declaration process and consider an additional public founder-sensitive file register showing independent file ownership and review status.

Recognize that conflict can sometimes be managed through independent process and sometimes requires a project to stop.

Do not force a project forward merely because significant private development effort has already been invested.

Use early Integrity Commissioner and legal advice rather than waiting for a complaint after the decision.

Supply reviewers with complete facts.

Reverify advice when material facts change.

Recheck the provincial municipal accountability framework after the enacted 2026 reforms are brought into force.

Separate official, private and campaign travel expenses.

Do not require City staff to support private commercial activity during municipal travel.

Do not privately exploit non-public municipal information concerning land, development, infrastructure, procurement or regulation.

Extend conflict safeguards to municipal staff and evaluators as well as elected officials.

Maintain clear routes for residents and staff to raise concerns through the correct Integrity Commissioner, Clerk, procurement, privacy or employee-ethics processes.

Do not turn every concern into one political complaint.

Protect good-faith staff reporting of possible private-benefit, campaign-resource, procurement or data misuse.

Use independent investigation where the Mayor is the subject of a material allegation and independence is required.

Do not allow the subject of an investigation to select the investigator, define the findings or approve the final report.

Give the subject a fair opportunity to respond.

Do not conduct ethics investigations through social media.

Use evidence and precise terminology when distinguishing appearance of conflict, statutory conflict and actual wrongdoing.

Recognize that election-finance compliance processes are separate from municipal code-of-conduct, privacy, procurement and employment processes.

Keep post-election campaign financial administration separate from City staff and City accounting.

Separate inauguration costs from campaign celebration costs.

Do not automatically provide private transition advisors with confidential municipal information.

Move municipal correspondence arriving through old campaign channels into official City systems.

Use the first 30 days to establish the Conflict and Firewall Baseline, obtain appropriate advice, publish relevant disclosure, separate data and assign independent owners to founder-sensitive files.

Use the first 60 days to publish a Founder-Associated Initiative Review Protocol and verify municipal, private and campaign accounts and intellectual-property boundaries.

Use the first 100 days to complete initial independent review of any founder-associated platform being seriously considered for municipal use.

Permit the first 100-day outcome to be Proceed, Compete, Transfer, Hold or Stop.

Use Year One to make the firewall institutional rather than dependent on personal restraint.

Use Year Two to audit whether staff, data, procurement and conflict boundaries actually worked.

Use Year Three to test whether the system would remain safe under a less careful future Mayor.

Use Year Four to apply heightened election-year resource, data and communications safeguards.

Incorporate Ontario's current election-period restrictions on specified strong-mayor powers into the transition checklist.

Publish a Four-Year Campaign, Private Interest and Municipal Firewall Audit that identifies material founder-sensitive files, independent reviews, recusals, transfers, procurements, failures and remaining risks without exposing protected information.

State clearly what ultimately happened with map.ca and RealMap rather than allowing their status to remain ambiguous.

Give the next Council all ownership agreements, independent reviews, procurement records, conflict-sensitive file records and pending issues needed to understand the City's relationship with any founder-associated system.

Never leave the next Council dependent on the former Mayor's personal permission, passwords, domains, relationships or recollection.

Never allow public office to become a private distribution channel, procurement advantage, data source or ownership shortcut.

Apply the final firewall test to every material overlap: Is this campaign, private or municipal activity, what public authority is being used, who could benefit privately, who independently controls the municipal process, what information crossed the boundary, and would we accept the same arrangement if the private interest belonged to a political opponent?

The firewall can therefore be reduced to twelve rules:

Three systems: campaign, private, municipal.

Never merge the data.

Never merge the staff.

Never merge the money.

Never use public power for private sales.

Disclose relevant interests.

Recuse when required.

Remove the interested person from control of the evaluation process.

Value private assets independently.

Public ownership must be real ownership.

Protect staff who question the boundary.

Use the political-opponent test every time.

The objective is not to prevent:

That would make municipal government poorer.

The objective is to ensure that when those worlds intersect:

the public receives the benefit without surrendering the integrity of the public process.

The strongest protection is not a promise that the Mayor is:

It is a system that does not require residents to gamble on:

A trustworthy person should welcome that system.

A future untrustworthy person should be constrained by it.

That is the test of good governance.

Public office must never become a private distribution channel, procurement advantage, data source or ownership shortcut. Disclose the interest. Separate the systems. Protect the staff. Independentize the decision. Keep the record. Apply the same rules even when the private idea is your own.

← Appendix M: Partnership, Shared-Service and Intergovernmental Agreement StandardsAppendix O: Glossary and Common Municipal Language →