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The Public Scorecard
Chapter 55Privacy and Information: The Public Privacy and Information Scorecard
Vote on the proposals, hear the audio, read the reviews, search the whole plan.
In this chapter
- 55.1 Purpose
- 55.2 Privacy Is an Operating Standard
- 55.3 Information Is an Asset
- 55.4 Information Is Also a Liability
- 55.5 Privacy Scorecard Headline Measures
- 55.6 No Single Privacy Score
- 55.7 Information Inventory
- 55.8 System Inventory Fields
- 55.9 Not Every Spreadsheet Needs the Same Treatment
- 55.10 Shadow Systems
- 55.11 Shadow System Risk
- 55.12 Purpose
- 55.13 Purpose Test
- 55.14 "Might Be Useful Later" Is Weak
- 55.15 Purpose Limitation
- 55.16 Example
- 55.17 Campaign Firewall
- 55.18 No Incumbent Data Advantage
- 55.19 Data Minimization
- 55.20 Form Review
- 55.21 Required Versus Optional
- 55.22 Do Not Make Optional Data Functionally Mandatory
- 55.23 Date of Birth
- 55.24 Home Address
- 55.25 Phone Number
- 55.26 Email
- 55.27 Government Identification
- 55.28 Social Insurance Number
- 55.29 Banking Information
- 55.30 Health Information
- 55.31 Accommodation Information
- 55.32 Children
- 55.33 Parent Information
- 55.34 Emergency Contact
- 55.35 Political Opinion
- 55.36 Religious Belief
- 55.37 Civic Participation
- 55.38 Strong Vote
- 55.39 Verify Person, Protect Opinion
- 55.40 Retention
- 55.41 Retention Schedule
- 55.42 Legal Retention
- 55.43 Operational Retention
- 55.44 Historical Record
- 55.45 Archive Versus Operational Database
- 55.46 Deletion
- 55.47 Vendor Deletion
- 55.48 Contract Requirement
- 55.49 Backup
- 55.50 Backup Is Not Excuse for Infinite Retention
- 55.51 Data Disposal
- 55.52 Paper Still Matters
- 55.53 Unattended Documents
- 55.54 Printing
- 55.55 Secure Destruction
- 55.56 Access Control
- 55.57 Least Privilege
- 55.58 Role Change
- 55.59 Departure
- 55.60 Contractor Access
- 55.61 Vendor Support Access
- 55.62 Shared Password
- 55.63 Individual Accounts
- 55.64 Administrative Accounts
- 55.65 Privileged Access Review
- 55.66 Dormant Accounts
- 55.67 Former Staff Accounts
- 55.68 Seasonal Staff
- 55.69 Student Accounts
- 55.70 Youth Program Access
- 55.71 Access Logging
- 55.72 Logging Is Not Employee Surveillance by Default
- 55.73 Access Review Measure
- 55.74 Authentication
- 55.75 Multi-Factor Authentication
- 55.76 Password Reset
- 55.77 Identity Verification
- 55.78 Over-Verification
- 55.79 Anonymous Access
- 55.80 Anonymous Reporting
- 55.81 Identity When Needed
- 55.82 Universal Digital Identity
- 55.83 One Account for Everything Risk
- 55.84 Service-Specific Identity
- 55.85 Resident Choice
- 55.86 No Civic Profile
- 55.87 No Resident Score
- 55.88 No Behavioural Risk Score
- 55.89 No Civic Engagement Score
- 55.90 No "Good Resident" Ranking
- 55.91 Data Sharing
- 55.92 Sharing Register
- 55.93 Sharing Fields
- 55.94 Minimum Necessary Sharing
- 55.95 Shared Is Not Surrendered
- 55.96 Partner Retention
- 55.97 Partner Reuse
- 55.98 Subcontractors
- 55.99 Cross-Border Processing
- 55.100 Canadian Hosting
- 55.101 Foreign Hosting
- 55.102 Data Sovereignty
- 55.103 Vendor Inventory
- 55.104 Vendor Role
- 55.105 Vendor Contract
- 55.106 City Owns Its Public Records
- 55.107 Export
- 55.108 Export Test
- 55.109 Export Is Not a Screenshot
- 55.110 Proprietary Format
- 55.111 API Access
- 55.112 Exit Cost
- 55.113 No Hostage Data
- 55.114 Renewal Review
- 55.115 Data Portability Score
- 55.116 Privacy Impact Review
- 55.117 Privacy Review Timing
- 55.118 High-Risk Triggers
- 55.119 Not Every Form Needs a Formal Impact Assessment
- 55.120 Privacy by Design
- 55.121 Privacy by Default
- 55.122 Consent
- 55.123 Optional Consent
- 55.124 Bundled Consent
- 55.125 Withdrawal
- 55.126 Privacy Notice
- 55.127 Long Legal Notice
- 55.128 No False Privacy Promise
- 55.129 Privacy Incidents
- 55.130 Incident Definition
- 55.131 Examples
- 55.132 Privacy Incident Is Not Always Cyberattack
- 55.133 Cyber Incident Is Not Always Privacy Breach
- 55.134 Incident Response
- 55.135 Notification
- 55.136 No Political Suppression
- 55.137 No Premature Disclosure
- 55.138 Incident Status
- 55.139 Incident Closure
- 55.140 Root Cause
- 55.141 Repeat Incident
- 55.142 Incident Count Is Not Complete Risk
- 55.143 Severity
- 55.144 No Breach Points Game
- 55.145 Internal Reporting Culture
- 55.146 No Retaliation for Good-Faith Reporting
- 55.147 Human Error
- 55.148 Auto-Complete Email Risk
- 55.149 Bulk Email
- 55.150 BCC Is Not Complete Privacy Program
- 55.151 Attachments
- 55.152 Metadata
- 55.153 Public Wi-Fi
- 55.154 Public Wi-Fi Purpose
- 55.155 Public Wi-Fi Is Not Resident Tracking
- 55.156 Connection Logs
- 55.157 Device Identifier
- 55.158 Location Analytics
- 55.159 Marketing Analytics
- 55.160 Captive Portal
- 55.161 No Forced Marketing Consent
- 55.162 No Political Consent
- 55.163 Email Requirement
- 55.164 Terms
- 55.165 Security Notice
- 55.166 Wi-Fi Uptime
- 55.167 Wi-Fi Coverage
- 55.168 Usage
- 55.169 Unique Devices
- 55.170 Session Count
- 55.171 No Foot-Traffic Substitution
- 55.172 Public Wi-Fi Cost
- 55.173 Free to User
- 55.174 Community Broadband
- 55.175 Broadband Study Data
- 55.176 Public Wi-Fi and Broadband Are Different
- 55.177 Connectivity Support
- 55.178 Means Testing
- 55.179 No Poverty Database
- 55.180 Device Reuse
- 55.181 Donated Device
- 55.182 Previous Owner Data
- 55.183 Recipient Data
- 55.184 Device Wipe Standard
- 55.185 Unwipeable Device
- 55.186 Account Lock
- 55.187 SIM Card
- 55.188 Memory Card
- 55.189 Photos and Messages
- 55.190 Device Recipient
- 55.191 Emergency Calling
- 55.192 No Tracking Software
- 55.193 Support Software
- 55.194 Device Program Inventory
- 55.195 No Recipient Public List
- 55.196 Device Donation Receipt
- 55.197 Donor Data
- 55.198 Website Privacy
- 55.199 Analytics
- 55.200 Page View
- 55.201 Individual Behaviour
- 55.202 Advertising Tracker
- 55.203 Third-Party Embed
- 55.204 Cookie Banner
- 55.205 Essential Cookies
- 55.206 Non-Essential Tracking
- 55.207 Consent Dark Pattern
- 55.208 Website Search
- 55.209 Form Drafts
- 55.210 Abandoned Form
- 55.211 Session Replay
- 55.212 Heatmaps
- 55.213 Social Media Pixels
- 55.214 City Newsletter
- 55.215 Unsubscribe
- 55.216 Newsletter List
- 55.217 Community Calendar
- 55.218 Event Organizer Data
- 55.219 Internal Contact
- 55.220 Event Attendee Data
- 55.221 Calendar Analytics
- 55.222 map.ca Information Infrastructure
- 55.223 No Founder Exception
- 55.224 Public Standard First
- 55.225 No Forced Account
- 55.226 Email for Life
- 55.227 Email Is High-Risk Infrastructure
- 55.228 Municipal Email Provider Question
- 55.229 Independent Governance
- 55.230 Exit
- 55.231 Domain Control
- 55.232 No Lock-In Through Identity
- 55.233 Data Locker
- 55.234 Data Locker Decision Gate
- 55.235 Data Locker Can Increase Risk
- 55.236 "Resident Controlled" Must Be Real
- 55.237 No Data Locker by Momentum
- 55.238 Alternative
- 55.239 Safe Information
- 55.240 Information Accuracy
- 55.241 Stale Page
- 55.242 Review Date
- 55.243 External Programs
- 55.244 No Stale Grant Promise
- 55.245 Current Does Not Mean Permanent
- 55.246 Source
- 55.247 City Interpretation
- 55.248 Formal Rule
- 55.249 Plain Language
- 55.250 Plain Language Is Not Legal Rewrite
- 55.251 Correction Log
- 55.252 Correction Fields
- 55.253 Minor Typo
- 55.254 Material Error
- 55.255 Correct in Place and Record
- 55.256 No Silent Rewrite of Material Error
- 55.257 Correction Is Not Failure Theatre
- 55.258 Error Rate
- 55.259 Repeat Error
- 55.260 Public Information Owner
- 55.261 Orphan Page
- 55.262 Archive
- 55.263 Search Results
- 55.264 Date Everything Important
- 55.265 Source Date
- 55.266 Publication Date Is Not Data Date
- 55.267 Official Versus Informal
- 55.268 Social Media Correction
- 55.269 Screenshot Persistence
- 55.270 Misinformation About City Services
- 55.271 No Truth Ministry
- 55.272 Scope
- 55.273 Opinion
- 55.274 Criticism
- 55.275 Data Interpretation
- 55.276 Deepfakes and Impersonation
- 55.277 Verification Page
- 55.278 Cryptographic Verification
- 55.279 Official Domains
- 55.280 Domain Inventory
- 55.281 Account Succession
- 55.282 Mayor Account
- 55.283 Social Media Archive
- 55.284 Deleted Post
- 55.285 Direct Messages
- 55.286 Personal Account
- 55.287 Text Messaging
- 55.288 Messaging Apps
- 55.289 Records Management
- 55.290 Public Record Is Not Public Personal Data
- 55.291 Access to Information
- 55.292 Open by Default
- 55.293 Redaction
- 55.294 Over-Redaction
- 55.295 Under-Redaction
- 55.296 Privacy Versus Open Government
- 55.297 Contracts
- 55.298 Employee Personal Information
- 55.299 Individual Service Request
- 55.300 Aggregate Service Data
- 55.301 Open Data
- 55.302 Direct Identifier
- 55.303 Indirect Identifier
- 55.304 Small Cell
- 55.305 Vulnerable Population
- 55.306 No Vulnerability Map
- 55.307 Neighbourhood Aggregation
- 55.308 Open Data Review
- 55.309 Mosaic Effect
- 55.310 Property Data
- 55.311 RealMap
- 55.312 Property Is Not Person
- 55.313 Real Estate Listings
- 55.314 No Resident Behaviour Layer
- 55.315 RealMap Access
- 55.316 YouthMap
- 55.317 Seniors Map
- 55.318 Snow Brigade
- 55.319 Safety Maps
- 55.320 Infrastructure Map
- 55.321 Indigenous Knowledge
- 55.322 Consent and Governance
- 55.323 Archaeology
- 55.324 No Open Data Absolutism
- 55.325 Data Classification
- 55.326 Classification Is Not Secrecy Button
- 55.327 Sensitive-by-Default Fields
- 55.328 Public-by-Default Fields
- 55.329 Classification Review
- 55.330 AI Inventory
- 55.331 AI Definition
- 55.332 AI Use Categories
- 55.333 High-Impact AI
- 55.334 Low-Risk AI
- 55.335 AI Input
- 55.336 Protected Data
- 55.337 Vendor Training
- 55.338 Default Assumption
- 55.339 AI Data Retention
- 55.340 AI Output
- 55.341 Human Accountability
- 55.342 No AI Excuse
- 55.343 AI Hallucination
- 55.344 AI Correction
- 55.345 AI Source
- 55.346 AI Records
- 55.347 AI Procurement
- 55.348 AI Pilot
- 55.349 AI Stop Condition
- 55.350 AI Is Not Modernization by Itself
- 55.351 AI Reduction
- 55.352 No Employee Surveillance AI
- 55.353 No Resident Emotion Detection
- 55.354 No Political Sentiment Profiling
- 55.355 Surveillance
- 55.356 Surveillance Inventory
- 55.357 Camera Purpose
- 55.358 Retention
- 55.359 Access
- 55.360 Facial Recognition
- 55.361 Licence Plate Recognition
- 55.362 Drone
- 55.363 Drone Purpose
- 55.364 No Casual Residential Surveillance
- 55.365 Incidental Capture
- 55.366 Body-Worn Cameras
- 55.367 Audio Recording
- 55.368 Meeting Recording
- 55.369 Call Recording
- 55.370 Call Analytics
- 55.371 Biometric Data
- 55.372 Fingerprint
- 55.373 Face
- 55.374 Voiceprint
- 55.375 Convenience Is Not Enough
- 55.376 Location Data
- 55.377 City App
- 55.378 "Always Allow"
- 55.379 Service Request
- 55.380 Photo Metadata
- 55.381 Minimum Needed Location
- 55.382 Parking Apps
- 55.383 Payment Information
- 55.384 Payment Token
- 55.385 Financial Analytics
- 55.386 Utility Data
- 55.387 No Behavioural Inference
- 55.388 Leak Detection
- 55.389 Smart Infrastructure
- 55.390 Sensor Inventory
- 55.391 Sensor Purpose
- 55.392 Aggregate First
- 55.393 Smart City
- 55.394 Public Benefit Test
- 55.395 Delete Useless Data
- 55.396 Information Debt
- 55.397 Data Cleanup
- 55.398 Duplicate Data
- 55.399 Master Resident Database
- 55.400 Federated Approach
- 55.401 Data Quality
- 55.402 Correction Request
- 55.403 Identity Check
- 55.404 No Impossible Correction
- 55.405 Audit
- 55.406 Personal Data Accuracy
- 55.407 Data Source
- 55.408 Duplicate Source Conflict
- 55.409 One Source of Truth
- 55.410 Non-Digital Service
- 55.411 Phone
- 55.412 In Person
- 55.413 Paper
- 55.414 Assisted Digital
- 55.415 No Penalty for Non-Digital Access
- 55.416 Digital Convenience
- 55.417 Paper Privacy
- 55.418 Phone Privacy
- 55.419 Public Counter
- 55.420 Translation
- 55.421 AI Translation
- 55.422 Interpreter
- 55.423 Accessibility and Privacy
- 55.424 Open Books and Privacy
- 55.425 Grant Recipients
- 55.426 Procurement
- 55.427 Conflict Disclosure
- 55.428 Privacy Is Not Secrecy
- 55.429 Secrecy Is Not Privacy
- 55.430 Privacy Protects People
- 55.431 Security
- 55.432 Cybersecurity Scorecard
- 55.433 Patch Status
- 55.434 Unsupported Software
- 55.435 End-of-Life System
- 55.436 Backups
- 55.437 Restore Test
- 55.438 Ransomware
- 55.439 Offline or Segmented Backup
- 55.440 Incident Plan
- 55.441 Tabletop Exercise
- 55.442 Vendor Breach
- 55.443 Supply Chain
- 55.444 Cyber Insurance
- 55.445 Insurance Is Not Security
- 55.446 Phishing
- 55.447 Training Click Rate
- 55.448 Simulated Phishing
- 55.449 Report Button
- 55.450 Cyber Culture
- 55.451 Public Cyber Claims
- 55.452 Resilience
- 55.453 Privacy Scorecard Table
- 55.454 Data Inventory Table
- 55.455 Privacy Incident Table
- 55.456 Vendor Table
- 55.457 Public Information Table
- 55.458 Public Wi-Fi Table
- 55.459 Device Reuse Table
- 55.460 AI Table
- 55.461 Data Sharing Table
- 55.462 Traffic Lights
- 55.463 Green Is Not "No Risk"
- 55.464 Red Is Not Automatic Public Disclosure of Technical Details
- 55.465 Grey Is Better Than False Assurance
- 55.466 Anti-Gaming Rule One
- 55.467 Anti-Gaming Rule Two
- 55.468 Anti-Gaming Rule Three
- 55.469 Anti-Gaming Rule Four
- 55.470 Anti-Gaming Rule Five
- 55.471 Anti-Gaming Rule Six
- 55.472 Anti-Gaming Rule Seven
- 55.473 Anti-Gaming Rule Eight
- 55.474 Anti-Gaming Rule Nine
- 55.475 Anti-Gaming Rule Ten
- 55.476 Anti-Gaming Rule Eleven
- 55.477 Anti-Gaming Rule Twelve
- 55.478 Anti-Gaming Rule Thirteen
- 55.479 Anti-Gaming Rule Fourteen
- 55.480 Anti-Gaming Rule Fifteen
- 55.481 Anti-Gaming Rule Sixteen
- 55.482 Anti-Gaming Rule Seventeen
- 55.483 Anti-Gaming Rule Eighteen
- 55.484 Anti-Gaming Rule Nineteen
- 55.485 Anti-Gaming Rule Twenty
- 55.486 Anti-Gaming Rule Twenty-One
- 55.487 Anti-Gaming Rule Twenty-Two
- 55.488 Anti-Gaming Rule Twenty-Three
- 55.489 Anti-Gaming Rule Twenty-Four
- 55.490 Anti-Gaming Rule Twenty-Five
- 55.491 Election-Year Integrity
- 55.492 No Data Access Expansion for Campaign
- 55.493 No Campaign Export
- 55.494 Campaign Data Goes the Other Direction Too
- 55.495 Resident Consent to Campaign Is Not Consent to City
- 55.496 City Consent Is Not Campaign Consent
- 55.497 Official Account Transition
- 55.498 Campaign Account
- 55.499 No Data Purge Before Transition
- 55.500 No Data Hoarding After Leaving Office
- 55.501 Baseline
- 55.502 Unknown Baseline
- 55.503 Do Not Pretend Legacy Systems Are Known
- 55.504 Year One Objective
- 55.505 Year Two Objective
- 55.506 Year Three Objective
- 55.507 Year Four Objective
- 55.508 Four-Year Core Measures
- 55.509 Do Not Set "Zero Privacy Incidents" as Only Goal
- 55.510 Serious Incident Goal
- 55.511 Incident Trend
- 55.512 New Reporting System
- 55.513 Four-Year Privacy and Information Audit
- 55.514 Name the Biggest Privacy Improvement
- 55.515 Name the Biggest Privacy Failure
- 55.516 Name the Highest-Risk Legacy System
- 55.517 Name the Biggest Unnecessary Dataset Removed
- 55.518 Name the Most Important Retention Reform
- 55.519 Name the Most Important Vendor Exit Improvement
- 55.520 Name a Vendor Relationship That Remains Too Dependent
- 55.521 Name the Most Important Public-Wi-Fi Privacy Improvement
- 55.522 Name the Device-Reuse Result
- 55.523 Name the Most Important AI Governance Decision
- 55.524 Name an AI Use That Was Stopped
- 55.525 Name the Most Important Information Correction
- 55.526 Name the Most Persistent Stale-Information Problem
- 55.527 Name the Largest Privacy Liability Handed to the Next Council
- 55.528 Collection Test
- 55.529 Purpose Test
- 55.530 Retention Test
- 55.531 Access Test
- 55.532 Vendor Test
- 55.533 Exit Test
- 55.534 Sharing Test
- 55.535 Wi-Fi Test
- 55.536 Device Test
- 55.537 AI Test
- 55.538 Surveillance Test
- 55.539 Open Data Test
- 55.540 Information Accuracy Test
- 55.541 Correction Test
- 55.542 Non-Digital Test
- 55.543 Campaign Test
- 55.544 Rights Test
- 55.545 Resilience Test
- 55.546 Independence Test
- 55.547 Institution Test
- 55.548 What Success Looks Like
- 55.549 What Failure Looks Like
- 55.550 The Privacy and Information Scorecard Commitment
A City needs information to function.
It needs to know enough to:
- collect taxes;
- issue permits;
- operate recreation programs;
- answer service requests;
- manage infrastructure;
- communicate during emergencies;
- process payments;
- administer employment;
- meet legal obligations.
But the ability to collect information does not create a reason to collect everything.
Modern municipal systems can quietly accumulate:
- names;
- addresses;
- phone numbers;
- emails;
- payment histories;
- service requests;
- photographs;
- locations;
- device identifiers;
- website behaviour;
- program participation;
- video;
- access logs;
- AI prompts;
- vendor analytics;
- archived accounts.
Individually, each dataset may appear harmless.
Combined, they can become:
a detailed profile of a resident's life.
That should not be the default condition of municipal government.
The central principle is:
The City should know enough to serve residents well, but not so much that ordinary municipal life becomes a permanent profile of the resident.
The second principle is equally important:
Information the City publishes should be accurate, attributable, current and correctable.
Privacy and public information are therefore connected.
Residents should know:
- what the City knows about them;
- why it needs it;
- how long it keeps it;
- who can access it;
- who else receives it;
- what happens if it is breached;
- whether they can access service without unnecessary data collection.
And when the City tells residents something:
They should know:
- where it came from;
- when it was verified;
- whether it changed;
- how a correction is handled.
The original Safe Information proposal specifically contemplates public Wi-Fi and connection support without relying on property-tax-funded broadband expansion, as well as reuse of functional phones rather than assuming every resident must purchase new hardware.
The source framework also proposes stronger public data stewardship and community information infrastructure.
The Scorecard should determine whether those ideas improve access without creating:
- unnecessary surveillance;
- vendor lock-in;
- identity systems;
- behavioural profiles.
55.1Purpose
The Privacy and Information Scorecard should answer:
What personal information does the City collect?
Why?
Which systems hold it?
How long is it retained?
Who can access it?
Which vendors can access it?
Which other governments or organizations receive it?
What data is no longer needed?
Is it being deleted according to lawful retention rules?
Are privacy incidents occurring?
Are they being corrected?
Can residents still obtain essential service without unnecessary digital profiling?
Is public Wi-Fi private enough for ordinary use?
Are recycled-device programs handled safely?
Are City websites collecting unnecessary analytics?
Are AI systems receiving sensitive information?
Are surveillance systems proportionate?
Is public information current and sourced?
Are corrections visible?
Can residents obtain information by phone, paper or in person?
Is public data released without exposing private residents?
Can the City leave its software vendors without losing its own information?
Those are the meaningful measures.
55.2Privacy Is an Operating Standard
Privacy should not sit solely with:
- Clerk;
- IT;
- lawyer;
- privacy officer.
Every department that collects information owns part of the responsibility.
55.3Information Is an Asset
Municipal information has value.
It should be:
- accurate;
- protected;
- organized;
- portable;
- appropriately retained.
55.4Information Is Also a Liability
Data that no longer has a lawful or operational purpose can create:
- privacy risk;
- security risk;
- legal cost;
- vendor dependency.
More information is not automatically better.
55.5Privacy Scorecard Headline Measures
A first-page dashboard could include:
- Major information systems inventoried.
- Systems containing personal information.
- Systems with documented collection purpose.
- Systems with current retention rules.
- Systems with external vendor access.
- High-risk systems reviewed.
- Privacy-impact reviews completed where appropriate.
- Material privacy incidents.
- Material cybersecurity incidents affecting personal information.
- Unresolved privacy incidents.
- Access-control reviews completed.
- Departed-user accounts removed on time.
- Vendor accounts reviewed.
- Data-sharing arrangements reviewed.
- High-risk datasets reduced or eliminated.
- Public Wi-Fi privacy review.
- Public Wi-Fi uptime.
- Device-reuse privacy compliance.
- AI systems inventoried.
- AI systems receiving protected data.
- Surveillance systems reviewed.
- Public-information corrections.
- Stale public pages corrected.
- External program pages with verification dates.
- Non-digital service availability.
- Open-data privacy reviews.
- Data export tests.
- Vendor exit tests.
- Major unresolved privacy risks.
55.6No Single Privacy Score
Avoid:
Privacy Score: 94/100
One serious breach can matter more than:
- hundreds of low-risk compliant forms.
Show components.
55.7Information Inventory
The City should maintain a current inventory of important information systems.
55.8System Inventory Fields
For significant systems:
System name
Department
Purpose
Information types
Personal information?
Sensitive information?
System owner
Vendor
Hosting arrangement
Access roles
Data sharing
Retention
Export capability
Last privacy review
Last security review
Contract renewal
55.9Not Every Spreadsheet Needs the Same Treatment
Use:
- risk;
- materiality.
But important unofficial datasets should not escape inventory simply because they are:
- spreadsheets;
- shared drives.
55.10Shadow Systems
Departments may create informal tools because:
- official system is difficult.
Identify significant shadow systems.
55.11Shadow System Risk
A spreadsheet containing:
- names;
- addresses;
- complaints;
can be just as sensitive as a formal database.
55.12Purpose
Every significant personal-information collection should have:
- a legitimate municipal purpose;
- lawful authority where required.
55.13Purpose Test
Ask:
What specific municipal service or legal obligation requires this information?
If the answer is unclear:
Reconsider collection.
55.14"Might Be Useful Later" Is Weak
Do not collect personal information simply because:
it could be useful one day.
55.15Purpose Limitation
Information collected for one purpose should not quietly become:
- marketing data;
- political data;
- behavioural analytics;
without proper authority and notice.
55.16Example
A recreation registration list exists to:
- administer recreation.
It is not automatically:
- business marketing list;
- election list.
55.17Campaign Firewall
Municipal data does not become campaign data.
Ever.
55.18No Incumbent Data Advantage
An elected official should not receive privileged access to resident information for:
- campaigning;
- voter targeting;
- fundraising.
55.19Data Minimization
Collect:
the least amount of information reasonably necessary to perform the service.
55.20Form Review
For major public forms:
Review each field.
Ask:
Do we still need this?
55.21Required Versus Optional
Clearly distinguish:
- required;
- optional.
55.22Do Not Make Optional Data Functionally Mandatory
A form should not reject submission because an optional demographic field is blank.
55.23Date of Birth
Do not collect full birthdate where:
- age range;
- age confirmation;
would satisfy the purpose.
55.24Home Address
Do not collect full home address merely because a form template always has one.
55.25Phone Number
Same.
55.26Email
Same.
55.27Government Identification
Do not collect government ID numbers unless:
- necessary;
- lawful.
55.28Social Insurance Number
Collect only where legitimate legal, employment or tax administration requires it.
Never through ordinary public-interest registrations.
55.29Banking Information
Only where:
- payroll;
- authorized payment;
requires it.
Use secure systems.
55.30Health Information
Avoid unless a specific service requires it.
Use stronger safeguards.
55.31Accommodation Information
Collect:
- accommodation need;
rather than unnecessary diagnosis where possible.
55.32Children
Information about minors deserves additional care.
55.33Parent Information
Collect only what the program requires.
55.34Emergency Contact
May be legitimate for certain programs.
Do not reuse for unrelated purposes.
55.35Political Opinion
Ordinary municipal service should not collect it.
55.36Religious Belief
Likewise, unless a highly specific lawful purpose exists.
Ordinary service does not need it.
55.37Civic Participation
Participation in:
- petitions;
- delegations;
- public consultation;
should not become a generalized ideology profile.
55.38Strong Vote
Any voluntary civic-participation tool should use:
- minimum necessary verification;
- strong separation from political profiling.
55.39Verify Person, Protect Opinion
This principle applies throughout resident participation.
55.40Retention
Information should not be kept indefinitely because storage is cheap.
55.41Retention Schedule
Important information systems should have:
- documented retention requirements.
55.42Legal Retention
Some records must be kept.
Follow:
- applicable law;
- records schedules.
55.43Operational Retention
Some data may be needed temporarily for:
- service administration.
Delete or archive appropriately when that purpose ends.
55.44Historical Record
Some municipal records legitimately deserve long-term preservation.
55.45Archive Versus Operational Database
Long-term archival value does not mean:
- every record stays in the active production system forever.
55.46Deletion
Deletion should be:
- real;
- documented where material.
55.47Vendor Deletion
When data is deleted by the City:
Ask whether copies remain with:
- vendor;
- backup;
- subcontractor.
55.48Contract Requirement
Important vendors should have clear:
- retention;
- return;
- deletion;
obligations.
55.49Backup
Backups may retain information temporarily.
Document the lifecycle.
55.50Backup Is Not Excuse for Infinite Retention
Design systems so deleted data does not persist forever without reason.
55.51Data Disposal
Old:
- hard drives;
- phones;
- paper records;
require secure disposal.
55.52Paper Still Matters
Privacy is not only digital.
55.53Unattended Documents
Sensitive records should not sit:
- on public counters;
- in open recycling bins.
55.54Printing
Review unnecessary printing of personal information.
55.55Secure Destruction
Use appropriate processes.
55.56Access Control
Not every employee should access every dataset.
55.57Least Privilege
Give users only the access needed for:
- their role.
55.58Role Change
When an employee changes jobs:
Review access.
55.59Departure
Remove access promptly.
55.60Contractor Access
Give temporary contractors:
- only required access;
- only for required period.
55.61Vendor Support Access
Remote vendor access should be:
- controlled;
- logged where appropriate.
55.62Shared Password
Avoid.
55.63Individual Accounts
Use where practical.
55.64Administrative Accounts
Stronger controls.
55.65Privileged Access Review
High-level system access should be reviewed periodically.
55.66Dormant Accounts
Disable.
55.67Former Staff Accounts
No.
55.68Seasonal Staff
Access should expire appropriately.
55.69Student Accounts
Same.
55.70Youth Program Access
Young participants should not receive unnecessary access to personal resident records.
55.71Access Logging
For sensitive systems:
Maintain appropriate audit records.
55.72Logging Is Not Employee Surveillance by Default
Use logs for:
- security;
- accountability.
Do not transform them into unnecessary behavioural monitoring.
55.73Access Review Measure
Possible:
Percentage of designated high-risk systems completing scheduled access review.
55.74Authentication
Use proportionate security.
55.75Multi-Factor Authentication
Appropriate for many administrative systems.
Do not make essential resident services smartphone-only without alternative.
55.76Password Reset
Protect against:
- social engineering.
55.77Identity Verification
Verify only as strongly as the service requires.
55.78Over-Verification
Do not require government photo ID merely to:
- ask a pothole question;
- browse a public calendar.
55.79Anonymous Access
Many public services should permit anonymous:
- browsing;
- information access.
55.80Anonymous Reporting
Some reporting systems may permit anonymous concerns.
Use carefully.
55.81Identity When Needed
Payments, permits and formal applications may legitimately require identity.
55.82Universal Digital Identity
Do not require a universal municipal digital identity for ordinary civic life.
55.83One Account for Everything Risk
A single account can be convenient.
It can also create:
- cross-service profiling;
- single point of failure.
55.84Service-Specific Identity
Use where appropriate.
55.85Resident Choice
Where a unified account exists:
Residents should still be able to access appropriate public information without signing in.
55.86No Civic Profile
Do not build a single profile showing:
- permits;
- recreation;
- complaints;
- opinions;
- business;
- parking;
- event attendance;
unless truly required for specific lawful administration.
55.87No Resident Score
Never.
55.88No Behavioural Risk Score
Never.
55.89No Civic Engagement Score
Never.
55.90No "Good Resident" Ranking
Never.
55.91Data Sharing
Some municipal services require sharing with:
- Grey County;
- Ontario;
- Canada;
- police;
- health;
- service partners.
55.92Sharing Register
Maintain an inventory of major recurring data-sharing arrangements.
55.93Sharing Fields
For significant arrangements:
Partner
Purpose
Data categories
Authority
Frequency
Retention
Security
Review date
55.94Minimum Necessary Sharing
Do not provide a complete dataset when:
- a limited field;
- aggregate result;
will do.
55.95Shared Is Not Surrendered
The City should understand what happens to data after transfer.
55.96Partner Retention
Where agreements permit:
Define.
55.97Partner Reuse
Restrict unrelated reuse where appropriate.
55.98Subcontractors
Understand whether partner vendors can access the information.
55.99Cross-Border Processing
For important systems:
Understand where data may be processed.
55.100Canadian Hosting
Canadian hosting can improve jurisdictional clarity and resilience in some cases.
It is not a substitute for:
- security;
- privacy;
- contract quality.
55.101Foreign Hosting
Should not be dismissed automatically.
Evaluate:
- legal;
- security;
- operational;
- sovereignty;
risk.
55.102Data Sovereignty
Ask:
Who controls the data, who can access it, and can we leave?
55.103Vendor Inventory
Every major personal-information vendor should be visible internally.
55.104Vendor Role
Distinguish:
Processor
Host
Software Provider
Analytics Provider
Support Contractor
as appropriate.
55.105Vendor Contract
Important contracts should address:
- ownership;
- access;
- security;
- breach;
- export;
- deletion;
- subcontractors;
- termination.
55.106City Owns Its Public Records
A vendor should not become the practical owner simply because:
- software stores them.
55.107Export
The City should be able to retrieve its information in:
- usable;
- documented;
format.
55.108Export Test
Do not wait until contract termination.
Test periodically for high-risk systems.
55.109Export Is Not a Screenshot
A true exit requires usable:
- records;
- metadata;
- attachments;
- relationships;
where needed.
55.110Proprietary Format
Understand conversion risk.
55.111API Access
Where appropriate:
Use documented interfaces.
55.112Exit Cost
Include:
- migration;
- extraction;
- conversion;
- validation.
55.113No Hostage Data
Vendor pricing should not make leaving practically impossible.
55.114Renewal Review
Before contract renewal:
Ask:
Can we still leave?
55.115Data Portability Score
Do not reduce to a simplistic number.
Use pass/fail tests by system.
55.116Privacy Impact Review
High-risk projects should receive appropriate privacy review before launch.
55.117Privacy Review Timing
Before:
- procurement;
- collection;
- deployment.
Not after controversy.
55.118High-Risk Triggers
Possible triggers:
- surveillance;
- biometrics;
- AI decisions;
- sensitive information;
- large-scale location data;
- cross-department profiling;
- new data-sharing;
- public Wi-Fi analytics.
55.119Not Every Form Needs a Formal Impact Assessment
Use proportionate thresholds.
55.120Privacy by Design
Ask early:
Can we accomplish the purpose with less data?
55.121Privacy by Default
Default settings should favour:
- minimum collection;
- limited sharing.
55.122Consent
Do not rely on vague consent where the City is actually exercising legal authority.
Use the proper legal basis and notice.
55.123Optional Consent
Where an optional service genuinely relies on consent:
Make it understandable.
55.124Bundled Consent
Avoid:
Agree to everything or receive no unrelated service.
55.125Withdrawal
Where consent is the appropriate basis:
Explain withdrawal.
55.126Privacy Notice
Forms should tell residents enough to understand:
- why information is collected;
- how to ask questions.
55.127Long Legal Notice
May still be required.
Provide a plain-language summary.
55.128No False Privacy Promise
Do not say:
Your data will never be shared
if law may require disclosure.
Use accurate language.
55.129Privacy Incidents
Track material privacy incidents.
55.130Incident Definition
Use the City's applicable professional and legal framework.
55.131Examples
May include:
- information sent to wrong person;
- lost device;
- unauthorized account access;
- exposed online record;
- inappropriate internal access.
55.132Privacy Incident Is Not Always Cyberattack
Distinguish:
- human error;
- process failure;
- technical attack.
55.133Cyber Incident Is Not Always Privacy Breach
A service outage may involve no personal data exposure.
Keep categories separate.
55.134Incident Response
Every material incident should have:
- containment;
- investigation;
- notification where required;
- correction;
- lesson.
55.135Notification
Follow applicable law and professional advice.
55.136No Political Suppression
A privacy incident should not be hidden because:
- election is approaching;
- project is politically important.
55.137No Premature Disclosure
Likewise, do not release unverified details that:
- worsen security;
- misidentify impact.
55.138Incident Status
Possible:
Detected
Contained
Investigating
Corrective Action
Closed
55.139Incident Closure
Do not close until:
- immediate issue;
- reasonable corrective action;
are addressed.
55.140Root Cause
Possible:
- training;
- access control;
- software;
- process;
- vendor;
- phishing;
- configuration.
55.141Repeat Incident
Repeated incidents of the same type require:
- systemic correction.
55.142Incident Count Is Not Complete Risk
One severe breach can matter more than:
- ten minor misdirected emails.
55.143Severity
Use professionally defined severity levels.
55.144No Breach Points Game
Do not create a public game where departments hide small incidents to protect a score.
Encourage reporting.
55.145Internal Reporting Culture
Staff should report mistakes early.
55.146No Retaliation for Good-Faith Reporting
Important.
55.147Human Error
Design systems to reduce predictable errors.
55.148Auto-Complete Email Risk
For sensitive communication:
Use appropriate safeguards.
55.149Bulk Email
Use proper recipient privacy.
55.150BCC Is Not Complete Privacy Program
Use appropriate mailing systems for significant communications.
55.151Attachments
Check:
- correct file;
- hidden data;
- intended recipient.
55.152Metadata
Documents can contain hidden information.
Staff training and tools should address material risks.
55.153Public Wi-Fi
The Safe Information proposal specifically includes free public Wi-Fi as an access tool.
The Privacy Scorecard must ensure access does not become surveillance.
55.154Public Wi-Fi Purpose
Possible purpose:
provide basic Internet access in selected public spaces or facilities.
55.155Public Wi-Fi Is Not Resident Tracking
Do not use it to build:
- movement histories;
- recurring device profiles;
- consumer behaviour dossiers.
55.156Connection Logs
Retain only what:
- security;
- operations;
- law;
require.
55.157Device Identifier
Avoid long-term use for:
- behavioural analytics.
55.158Location Analytics
Do not track devices across multiple municipal locations simply because the Wi-Fi vendor offers the feature.
55.159Marketing Analytics
Disable where unnecessary.
55.160Captive Portal
Keep simple.
55.161No Forced Marketing Consent
Do not require residents to subscribe to:
- City marketing;
to obtain public Wi-Fi.
55.162No Political Consent
Obviously.
55.163Email Requirement
Consider whether an email is actually necessary.
Anonymous or low-friction access may be preferable.
55.164Terms
Use understandable terms.
55.165Security Notice
Explain that public Wi-Fi has inherent security considerations.
Do not promise:
- perfectly secure connection.
55.166Wi-Fi Uptime
Track:
- availability;
- major outages.
55.167Wi-Fi Coverage
Measure whether it serves the intended public locations.
55.168Usage
Aggregate usage may help planning.
55.169Unique Devices
Do not casually equate:
- devices;
- people.
55.170Session Count
Not residents.
Label correctly.
55.171No Foot-Traffic Substitution
Wi-Fi connections are not:
- pedestrian counts.
55.172Public Wi-Fi Cost
Show:
- equipment;
- connectivity;
- support;
- security.
55.173Free to User
If taxpayer-funded:
Say:
no user fee
rather than:
free to provide.
55.174Community Broadband
A community-owned broadband study should proceed only if a real:
- access;
- affordability;
- resilience;
problem is established.
The source proposal expressly frames such a study around external broadband funding rather than property-tax financing.
55.175Broadband Study Data
Do not build household-level poverty maps merely to justify a broadband project.
Use:
- aggregate;
- service coverage;
- affordability;
evidence.
55.176Public Wi-Fi and Broadband Are Different
Do not treat a few Wi-Fi hotspots as:
- universal broadband.
55.177Connectivity Support
Low-income connectivity assistance should use minimal information.
55.178Means Testing
If another program already determines eligibility:
Consider whether the City can avoid duplicative collection.
55.179No Poverty Database
Do not create a permanent municipal profile of residents receiving connectivity help.
55.180Device Reuse
The source plan also proposes reusing functional phones and devices.
Privacy must be designed into the program.
55.181Donated Device
Before reuse:
Ensure proper:
- data wiping;
- reset;
- inspection.
55.182Previous Owner Data
Must not transfer to recipient.
55.183Recipient Data
Should not remain with the City after distribution beyond what is necessary for program administration.
55.184Device Wipe Standard
Use a documented process appropriate to the device.
55.185Unwipeable Device
Do not redistribute.
Dispose securely.
55.186Account Lock
Check for:
- activation lock;
- linked accounts.
55.187SIM Card
Remove prior SIM and associated data.
55.188Memory Card
Check.
55.189Photos and Messages
Must not remain.
55.190Device Recipient
Explain:
- what device can do;
- what support is included;
- what is not guaranteed.
55.191Emergency Calling
Verify capability before claiming:
- emergency use.
55.192No Tracking Software
Do not install hidden City tracking on reused devices.
55.193Support Software
If remote support is offered:
Make it:
- disclosed;
- optional where possible.
55.194Device Program Inventory
Track:
- devices received;
- wiped;
- distributed;
- recycled.
55.195No Recipient Public List
Never.
55.196Device Donation Receipt
Where appropriate:
Provide.
55.197Donor Data
Do not keep unnecessary personal information from donors.
55.198Website Privacy
The municipal website itself should be reviewed.
55.199Analytics
Ask:
What website analytics do we actually need?
55.200Page View
Often enough.
55.201Individual Behaviour
Usually unnecessary.
55.202Advertising Tracker
Municipal websites should not casually embed:
- advertising trackers.
55.203Third-Party Embed
A video, map or social feed can transmit data to:
- third parties.
Review significant embeds.
55.204Cookie Banner
A banner is not proof of good privacy.
Reduce unnecessary tracking instead of merely asking residents to click:
Accept All.
55.205Essential Cookies
Use as needed.
55.206Non-Essential Tracking
Justify or remove.
55.207Consent Dark Pattern
Do not make:
- accept;
bright and easy while:
- reject;
is hidden through several screens.
55.208Website Search
Search terms may reveal sensitive concerns.
Retain only as needed.
55.209Form Drafts
Understand whether incomplete form data is stored.
55.210Abandoned Form
Do not retain indefinitely without reason.
55.211Session Replay
Avoid invasive website recording unless a compelling case exists.
55.212Heatmaps
Use caution.
Aggregate design analytics may help.
Individual behavioural replay usually offers more detail than a City needs.
55.213Social Media Pixels
Do not install political or advertising-platform tracking merely for:
- campaign-style communications analytics.
55.214City Newsletter
Collect:
- email;
- preferences;
needed to send it.
55.215Unsubscribe
Easy.
55.216Newsletter List
Not a campaign list.
55.217Community Calendar
The public calendar should collect enough information to:
- display events.
55.218Event Organizer Data
Publish only what is intended as:
- public contact information.
55.219Internal Contact
May differ from public contact.
55.220Event Attendee Data
The City does not need attendee identity merely because an event is listed.
55.221Calendar Analytics
Aggregate.
55.222map.ca Information Infrastructure
The source proposal imagines map.ca as potential public infrastructure, with public ownership protections before municipal adoption.
Any implementation must therefore pass the same Privacy Scorecard as every other system.
55.223No Founder Exception
A system associated with the Mayor receives:
- more scrutiny;
- not less.
55.224Public Standard First
Define:
- information;
- portability;
- privacy;
- accessibility;
requirements before choosing platform.
55.225No Forced Account
Residents should be able to browse appropriate public information without:
- creating map.ca account.
55.226Email for Life
Any permanent-email concept must be treated as:
- aspiration;
until governance, security, retention, portability and funding are proven.
55.227Email Is High-Risk Infrastructure
Email can contain:
- financial;
- personal;
- health;
- legal;
- authentication;
information.
Do not launch lightly.
55.228Municipal Email Provider Question
Before any City-connected permanent email:
Ask whether the municipality should operate:
- identity;
- messaging;
infrastructure at all.
55.229Independent Governance
If such a system ever proceeds:
It should not depend on:
- Mayor;
- founder;
- campaign.
55.230Exit
Residents must be able to:
- export;
- leave.
55.231Domain Control
Long-term public email needs stable:
- domain;
- governance;
- succession.
55.232No Lock-In Through Identity
Do not make email address the key that traps every municipal service into one platform.
55.233Data Locker
A resident-controlled data locker is an idea, not a predetermined project.
55.234Data Locker Decision Gate
Proceed only if:
- clear resident need;
- strong security;
- strong governance;
- portability;
- sustainable operation;
- legal review;
- privacy benefit;
are demonstrated.
55.235Data Locker Can Increase Risk
Centralizing information can create:
- attractive target;
- catastrophic failure mode.
55.236"Resident Controlled" Must Be Real
If the City can access everything automatically:
It is not fully resident-controlled.
55.237No Data Locker by Momentum
The correct decision may be:
do not build it.
55.238Alternative
Teaching residents:
- backups;
- password management;
- document organization;
may achieve more with less risk.
55.239Safe Information
The Safe Information Program should focus on:
- access;
- accuracy;
- privacy;
- resilience;
- independence.
55.240Information Accuracy
Official City information should have:
- owner;
- date;
- source where appropriate.
55.241Stale Page
Old information can be dangerous.
55.242Review Date
High-impact public pages should have periodic review.
55.243External Programs
Housing, business and benefit pages describing other governments should show:
Last verified [date].
55.244No Stale Grant Promise
Remove or archive expired programs.
55.245Current Does Not Mean Permanent
Even current information can change.
55.246Source
Where possible:
Link internally to or identify the authoritative source.
55.247City Interpretation
If the City summarizes another government's program:
Label it as:
- summary.
55.248Formal Rule
Where a legal rule matters:
Point residents to the authoritative legal or regulatory source.
55.249Plain Language
Provide an understandable explanation.
55.250Plain Language Is Not Legal Rewrite
Do not oversimplify until it becomes wrong.
55.251Correction Log
The City should maintain a public Correction Log for material public-information errors.
55.252Correction Fields
Date
Original statement
Corrected information
Reason
Affected page or service
55.253Minor Typo
Not every typo needs the public log.
Use materiality.
55.254Material Error
Examples:
- wrong deadline;
- wrong fee;
- wrong eligibility;
- wrong closure;
- wrong public-safety instruction.
55.255Correct in Place and Record
Do both where appropriate.
55.256No Silent Rewrite of Material Error
If residents may have relied on it:
Make the correction visible.
55.257Correction Is Not Failure Theatre
Government should normalize:
we published this incorrectly and fixed it.
55.258Error Rate
Do not create incentives to hide errors by overemphasizing:
- number of corrections.
Corrections are evidence the process works.
55.259Repeat Error
Repeated error from the same source deserves process review.
55.260Public Information Owner
Every major information page should have an internal owner.
55.261Orphan Page
Old pages without an owner should be:
- assigned;
- archived;
- removed.
55.262Archive
Historical pages should be clearly labelled:
Archived. Not Current.
55.263Search Results
Archived information should not appear indistinguishable from current guidance.
55.264Date Everything Important
Particularly:
- fees;
- deadlines;
- emergency information;
- program eligibility.
55.265Source Date
Where source data is older:
Show it.
55.266Publication Date Is Not Data Date
Distinguish.
55.267Official Versus Informal
A social-media post should not override:
- official City source.
55.268Social Media Correction
If a material wrong post was widely distributed:
Correct there too.
55.269Screenshot Persistence
Deleting a wrong post does not mean residents did not see it.
Publish correction.
55.270Misinformation About City Services
The City may correct false claims about:
- its own services;
- emergencies;
- bylaws;
- deadlines.
55.271No Truth Ministry
The City should not become arbiter of:
- every political claim;
- every opinion;
- every internet argument.
55.272Scope
Correct:
- matters within municipal responsibility;
- material public-safety misinformation;
- material false administrative information.
55.273Opinion
Do not label disagreement:
- misinformation.
55.274Criticism
Not misinformation simply because:
- City believes it is unfair.
55.275Data Interpretation
Residents may interpret the same statistics differently.
Publish:
- definitions;
- source.
55.276Deepfakes and Impersonation
The City may need protocols for false:
- Mayor statements;
- emergency messages;
- City notices.
55.277Verification Page
Maintain a simple official place to verify major:
- alerts;
- notices;
- announcements.
55.278Cryptographic Verification
Could be explored for high-value documents if practical.
Do not complicate ordinary communication unnecessarily.
55.279Official Domains
Residents should know which domains and accounts are official.
55.280Domain Inventory
Maintain control of:
- official domains;
- major social accounts.
55.281Account Succession
Credentials belong to the institution.
Not one employee.
55.282Mayor Account
Official mayoral channels remain municipal records and institutional assets where applicable.
Campaign channels remain separate.
55.283Social Media Archive
Follow applicable record rules.
55.284Deleted Post
Do not assume deletion eliminates record obligations.
55.285Direct Messages
Public business conducted through official social channels may create records.
Use proper systems.
55.286Personal Account
Do not conduct sensitive municipal business through a personal social account when official channels should be used.
55.287Text Messaging
Likewise.
55.288Messaging Apps
Convenience does not eliminate:
- records;
- privacy;
- security;
responsibilities.
55.289Records Management
Privacy and transparency sometimes pull in different directions.
Both must be handled properly.
55.290Public Record Is Not Public Personal Data
A municipal record may exist without every part being:
- publicly disclosed.
55.291Access to Information
Respond under the applicable legal framework.
55.292Open by Default
For non-sensitive public information:
Publish proactively where useful.
55.293Redaction
Protect information that should not be disclosed.
55.294Over-Redaction
Do not hide embarrassing public information merely because disclosure is uncomfortable.
55.295Under-Redaction
Do not expose private residents merely to appear transparent.
55.296Privacy Versus Open Government
The principle is:
Open government should expose government, not unnecessarily expose residents.
55.297Contracts
Publish appropriate public contract information.
55.298Employee Personal Information
Protect appropriately.
55.299Individual Service Request
Do not publish a resident's complaint with identifiable personal details merely to show transparency.
55.300Aggregate Service Data
Usually sufficient.
55.301Open Data
Public data should maximize usefulness while minimizing re-identification risk.
55.302Direct Identifier
Remove where unnecessary.
55.303Indirect Identifier
Be careful.
A dataset with:
- precise location;
- rare category;
- date;
can identify someone even without name.
55.304Small Cell
Suppress or aggregate where appropriate.
55.305Vulnerable Population
Extra caution.
55.306No Vulnerability Map
Do not map:
- isolated seniors;
- low-income households;
- crisis users;
- disabled residents;
- youth at risk;
at household level.
55.307Neighbourhood Aggregation
Can support planning where privacy is protected.
55.308Open Data Review
Before publishing a dataset:
Ask:
Could this reasonably identify a person when combined with other public information?
55.309Mosaic Effect
Multiple harmless datasets can become identifying when combined.
Consider that.
55.310Property Data
Some property information may already be public through lawful systems.
That does not justify publishing every personal detail the City possesses.
55.311RealMap
Any property-information platform must distinguish:
- property facts;
- personal resident information.
55.312Property Is Not Person
Do not turn property information into:
- household behaviour;
- owner profile.
55.313Real Estate Listings
Public listing information should come from:
- authorized;
- voluntary;
- lawful;
sources.
55.314No Resident Behaviour Layer
Do not add:
- complaints;
- political activity;
- service use;
to property profiles.
55.315RealMap Access
Basic browsing should not require:
- identity;
unless necessary for a specific feature.
55.316YouthMap
Maps opportunities.
Not youth.
55.317Seniors Map
Do not create a public map of:
- vulnerable seniors.
55.318Snow Brigade
Assignments can be managed privately.
55.319Safety Maps
Aggregate incidents.
Protect victims.
55.320Infrastructure Map
Public information should exclude:
- sensitive security details.
55.321Indigenous Knowledge
Information shared by Saugeen Ojibway Nation or knowledge holders does not automatically become:
- municipal Open Data.
55.322Consent and Governance
Respect:
- agreed use;
- confidentiality;
- Indigenous data governance expectations.
55.323Archaeology
Sensitive site information may require protection.
55.324No Open Data Absolutism
Some information should remain:
- protected.
55.325Data Classification
Use a practical classification model.
Possible:
Public
Internal
Confidential
Highly Sensitive
Use actual City policy terminology if adopted.
55.326Classification Is Not Secrecy Button
Departments should not label embarrassing material:
- confidential;
without basis.
55.327Sensitive-by-Default Fields
Certain data types deserve stronger controls.
55.328Public-by-Default Fields
Other records should be easier to release proactively.
55.329Classification Review
Old classifications may need review.
55.330AI Inventory
Every material municipal AI system should appear in a public or internal inventory appropriate to risk.
55.331AI Definition
Avoid arguing endlessly about marketing labels.
If software uses automated models to:
- generate;
- classify;
- recommend;
- predict;
in a meaningful municipal process, review it.
55.332AI Use Categories
Possible:
Drafting Assistance
Search
Summarization
Translation
Customer Service
Decision Support
Automation
Image or Video Analysis
55.333High-Impact AI
Systems affecting:
- eligibility;
- enforcement;
- employment;
- safety;
- benefits;
need stronger review.
55.334Low-Risk AI
Drafting a first version of:
- meeting summary;
may be lower risk.
Still requires records and accuracy rules.
55.335AI Input
Staff should know what information can be entered.
55.336Protected Data
Do not enter protected resident data into public consumer AI tools unless:
- approved;
- contractually protected;
- lawful.
55.337Vendor Training
Understand whether vendor may use prompts or outputs for:
- model training;
- product improvement.
55.338Default Assumption
Do not assume:
AI vendor cannot see it.
Verify the contract and architecture.
55.339AI Data Retention
Understand:
- prompt retention;
- logging;
- deletion.
55.340AI Output
Review before using for:
- legal;
- financial;
- safety;
- resident-specific;
decisions.
55.341Human Accountability
There must be a human or authorized institution responsible for the final decision.
55.342No AI Excuse
Do not say:
the algorithm decided.
Government remains accountable.
55.343AI Hallucination
Track material errors where AI was used in public information.
55.344AI Correction
Correct publicly if the error affected residents.
55.345AI Source
For factual municipal answers:
Point to official sources where practical.
55.346AI Records
Determine which AI interactions constitute municipal records under applicable rules.
55.347AI Procurement
Require:
- privacy;
- security;
- accessibility;
- export;
- deletion;
- model-use;
terms.
55.348AI Pilot
Pilot before broad deployment.
55.349AI Stop Condition
Stop if:
- error;
- privacy;
- bias;
- cost;
outweighs value.
55.350AI Is Not Modernization by Itself
A bad process with AI can remain:
- bad.
55.351AI Reduction
Automation may reduce repetitive work.
Measure actual service impact.
55.352No Employee Surveillance AI
Do not use AI to create:
- productivity scores;
- emotion analysis;
- behavioural rankings;
without compelling lawful purpose and governance.
Default should be no.
55.353No Resident Emotion Detection
No.
55.354No Political Sentiment Profiling
No.
55.355Surveillance
Cross-reference Section 51.
55.356Surveillance Inventory
Maintain.
55.357Camera Purpose
Document.
55.358Retention
Document.
55.359Access
Document.
55.360Facial Recognition
No default use.
55.361Licence Plate Recognition
Any use requires:
- lawful purpose;
- privacy;
- retention;
- governance;
review.
55.362Drone
Municipal drone use can support:
- inspection;
- mapping;
- emergency response.
It can also create privacy concerns.
55.363Drone Purpose
Define mission before flight.
55.364No Casual Residential Surveillance
Do not fly simply to:
- inspect resident behaviour.
55.365Incidental Capture
Minimize and handle appropriately.
55.366Body-Worn Cameras
If used by any municipal enforcement function:
Follow the applicable legal and operational governance framework.
Do not duplicate police policy through mayoral direction.
55.367Audio Recording
More intrusive than ordinary visual observation.
Review accordingly.
55.368Meeting Recording
Public Council meetings may appropriately be recorded.
That does not mean every interaction with City staff should be.
55.369Call Recording
If service calls are recorded:
Tell callers as required and define purpose.
55.370Call Analytics
Do not use voice recordings for:
- emotion scoring;
by default.
55.371Biometric Data
High-risk.
55.372Fingerprint
Do not collect for ordinary public service.
55.373Face
Same.
55.374Voiceprint
Same.
55.375Convenience Is Not Enough
Biometrics require a much stronger justification than:
faster login.
55.376Location Data
Precise location can be highly revealing.
55.377City App
Do not request continuous location unless the feature genuinely needs it.
55.378"Always Allow"
Avoid unless essential.
55.379Service Request
A resident may voluntarily mark:
- pothole location.
That does not mean the City needs their movement before or after.
55.380Photo Metadata
Uploaded photos may contain:
- GPS;
- device metadata.
Understand whether the system strips or retains it.
55.381Minimum Needed Location
Use:
- incident location;
rather than:
- resident's live location;
where sufficient.
55.382Parking Apps
If used:
Review:
- location;
- licence plate;
- payment;
- vendor analytics.
55.383Payment Information
The City should not store complete payment-card information unnecessarily.
Use secure payment processors.
55.384Payment Token
Where modern systems allow:
Use safer mechanisms.
55.385Financial Analytics
A municipal payment system does not need to infer:
- household wealth;
- purchase behaviour.
55.386Utility Data
Water or utility usage can reveal:
- occupancy patterns.
Treat appropriately.
55.387No Behavioural Inference
Do not use utility data to infer:
- lifestyle;
- family composition;
without legitimate operational purpose.
55.388Leak Detection
Operational use can be beneficial.
Keep purpose narrow.
55.389Smart Infrastructure
Sensors can improve:
- water;
- traffic;
- facilities.
55.390Sensor Inventory
High-risk sensors should be inventoried.
55.391Sensor Purpose
Define.
55.392Aggregate First
Prefer:
- traffic counts;
over identifiable vehicle tracking where possible.
55.393Smart City
Do not adopt technology because:
smart city
sounds modern.
55.394Public Benefit Test
Every sensor should answer:
What real municipal decision improves because this data exists?
55.395Delete Useless Data
If nobody uses a dataset:
Review whether collection should continue.
55.396Information Debt
Old:
- databases;
- duplicate spreadsheets;
- obsolete records;
create operational debt.
55.397Data Cleanup
Yearly cleanup can reduce:
- risk;
- confusion;
- cost.
55.398Duplicate Data
The same resident information may exist in:
- many systems.
Understand the pattern.
55.399Master Resident Database
Do not create one merely to eliminate duplication.
Centralization can create greater privacy risk.
55.400Federated Approach
Sometimes separate systems with:
- controlled interoperability;
are safer.
Evaluate architecture.
55.401Data Quality
Privacy also means not keeping:
- wrong information;
about someone.
55.402Correction Request
Residents should have an appropriate route to correct personal information where applicable.
55.403Identity Check
Verify sufficiently before changing protected records.
55.404No Impossible Correction
Do not require residents to navigate an obscure legal process for a simple administrative typo where staff can lawfully correct it.
55.405Audit
For material records:
Preserve appropriate history of changes.
55.406Personal Data Accuracy
Do not reuse outdated address or contact information blindly.
55.407Data Source
Know which system is authoritative.
55.408Duplicate Source Conflict
If two systems disagree:
Resolve.
55.409One Source of Truth
Useful for specific data categories.
Not a justification for a universal resident dossier.
55.410Non-Digital Service
Privacy and inclusion intersect.
Residents should not be forced to create digital accounts for every essential service.
55.411Phone
Maintain.
55.412In Person
Maintain where service context requires.
55.413Paper
Maintain where reasonable.
55.414Assisted Digital
Staff can help a resident complete digital process without forcing them to become digitally independent first.
55.415No Penalty for Non-Digital Access
Do not impose an unnecessary higher fee solely because someone:
- called;
- came in.
If cost differences justify a fee structure:
Council should explain it transparently and review accessibility implications.
55.416Digital Convenience
Offer it.
Do not make convenience become compulsion.
55.417Paper Privacy
Paper forms require:
- secure handling.
55.418Phone Privacy
Staff should avoid discussing sensitive details where others can overhear.
55.419Public Counter
Design spaces for reasonable confidentiality.
55.420Translation
Translation services may require third-party access to information.
Use appropriate controls.
55.421AI Translation
Do not feed protected resident information into unapproved translation tools.
55.422Interpreter
Professional interpreters may need confidentiality agreements or professional standards.
55.423Accessibility and Privacy
Accommodation should not require residents to disclose more than necessary.
55.424Open Books and Privacy
Open Books applies to:
- government spending.
It does not mean publishing private residents' information.
55.425Grant Recipients
Public money may justify disclosure about:
- organization;
- amount;
- purpose.
Do not publish unnecessary participant data.
55.426Procurement
Vendor payments can be public.
Employee or customer records remain protected.
55.427Conflict Disclosure
Officials may need to disclose:
- relevant interests.
Do not use privacy as excuse to hide conflicts that law or policy requires to be public.
55.428Privacy Is Not Secrecy
Important distinction.
55.429Secrecy Is Not Privacy
Another important distinction.
55.430Privacy Protects People
Transparency exposes:
- government decisions;
- public money;
- authority.
55.431Security
Privacy requires good cybersecurity.
55.432Cybersecurity Scorecard
Cross-reference Digital Sovereignty.
Use high-level measures.
55.433Patch Status
For critical systems:
Track high-risk unsupported systems.
55.434Unsupported Software
High concern.
55.435End-of-Life System
Needs remediation plan.
55.436Backups
Test.
55.437Restore Test
A backup that cannot be restored is:
- not reliable backup.
55.438Ransomware
Prepare.
55.439Offline or Segmented Backup
Where appropriate.
55.440Incident Plan
Maintain.
55.441Tabletop Exercise
Test.
55.442Vendor Breach
Contracts should require timely notification.
55.443Supply Chain
A software vendor's breach can become:
- City breach.
55.444Cyber Insurance
If held:
Understand requirements and exclusions.
55.445Insurance Is Not Security
No.
55.446Phishing
Train staff.
55.447Training Click Rate
Use cautiously.
Do not publicly shame employees.
55.448Simulated Phishing
Can help.
Do not turn it into punitive surveillance.
55.449Report Button
Make suspicious-message reporting easy.
55.450Cyber Culture
Early reporting matters more than embarrassment.
55.451Public Cyber Claims
Do not say:
unhackable.
No system is.
55.452Resilience
The realistic goal is:
- prevent;
- detect;
- contain;
- recover.
55.453Privacy Scorecard Table
A headline table could use:
| Measure | Baseline | Current | Target / Standard | Trend | Status | Owner |
Possible rows:
- high-risk systems inventoried;
- privacy reviews;
- material privacy incidents;
- unresolved incidents;
- access reviews;
- vendor reviews;
- data-sharing reviews;
- public Wi-Fi privacy status;
- AI systems reviewed;
- corrections published;
- data export tests;
- non-digital access.
55.454Data Inventory Table
| System | Personal Data | Vendor | Retention Defined | Export Tested | Last Review |
Public version may summarize sensitive systems.
55.455Privacy Incident Table
| Measure | Current Year | Previous Year | Trend |
Possible:
- material incidents;
- unresolved incidents;
- repeat-cause incidents.
Do not publish exploitable details.
55.456Vendor Table
| Measure | Current |
Possible:
- high-risk vendors;
- contracts with deletion terms;
- contracts with tested export;
- pending renewals requiring review.
55.457Public Information Table
| Measure | Current | Trend |
Possible:
- material corrections;
- stale pages retired;
- external-program pages verified;
- high-impact information pages with owners.
55.458Public Wi-Fi Table
| Measure | Current |
Possible:
- active locations;
- uptime;
- sessions;
- privacy review date;
- unnecessary analytics disabled.
55.459Device Reuse Table
| Measure | Current |
Possible:
- devices received;
- securely wiped;
- redistributed;
- securely recycled;
- privacy incidents.
55.460AI Table
| System | Purpose | Risk Level | Protected Data? | Human Review | Last Review |
Public version can omit sensitive security detail.
55.461Data Sharing Table
| Partner Type | Purpose | Agreement Reviewed | Data Minimized | Next Review |
55.462Traffic Lights
Green
Current controls meet the adopted standard.
Amber
Material remediation or review required.
Red
Significant unresolved privacy or information risk.
Grey
Not yet assessed or insufficient evidence.
55.463Green Is Not "No Risk"
It means:
- current standard met.
55.464Red Is Not Automatic Public Disclosure of Technical Details
Report the risk responsibly.
55.465Grey Is Better Than False Assurance
If a legacy system has never been properly reviewed:
Use:
Grey: assessment required.
55.466Anti-Gaming Rule One
Do not count systems inventoried as systems secured.
55.467Anti-Gaming Rule Two
Do not count privacy policies written as privacy risks resolved.
55.468Anti-Gaming Rule Three
Do not count training completed as privacy incidents prevented.
55.469Anti-Gaming Rule Four
Do not lower reported breach numbers by discouraging internal reporting.
55.470Anti-Gaming Rule Five
Do not classify a material privacy breach as:
- minor IT issue;
to protect statistics.
55.471Anti-Gaming Rule Six
Do not classify a service outage as personal-data breach if no evidence supports it.
Accuracy works both ways.
55.472Anti-Gaming Rule Seven
Do not count vendor policy language as proof of vendor deletion.
55.473Anti-Gaming Rule Eight
Do not count a successful one-time export as permanent vendor independence if the format is unusable.
55.474Anti-Gaming Rule Nine
Do not call public Wi-Fi anonymous if persistent device tracking remains enabled.
55.475Anti-Gaming Rule Ten
Do not call a device securely reused without documented data wiping.
55.476Anti-Gaming Rule Eleven
Do not call website tracking minimal while third-party advertising scripts remain embedded.
55.477Anti-Gaming Rule Twelve
Do not count cookie consent as proof that unnecessary tracking is acceptable.
55.478Anti-Gaming Rule Thirteen
Do not call AI anonymous if prompts contain identifiable resident information.
55.479Anti-Gaming Rule Fourteen
Do not call a dataset anonymous merely because names were removed.
55.480Anti-Gaming Rule Fifteen
Do not publish granular information that allows easy re-identification.
55.481Anti-Gaming Rule Sixteen
Do not call deleted data gone if the vendor contract permits indefinite retention.
55.482Anti-Gaming Rule Seventeen
Do not count archived stale pages as current information.
55.483Anti-Gaming Rule Eighteen
Do not silently correct material errors without recording them.
55.484Anti-Gaming Rule Nineteen
Do not use privacy as an excuse to hide:
- contracts;
- public spending;
- conflicts;
that should lawfully be public.
55.485Anti-Gaming Rule Twenty
Do not use transparency as an excuse to expose residents unnecessarily.
55.486Anti-Gaming Rule Twenty-One
Do not count public social-media followers as informed residents.
55.487Anti-Gaming Rule Twenty-Two
Do not count email subscribers as unique residents without evidence.
55.488Anti-Gaming Rule Twenty-Three
Do not count AI answers generated as questions resolved.
55.489Anti-Gaming Rule Twenty-Four
Do not count surveillance equipment installed as privacy management completed.
55.490Anti-Gaming Rule Twenty-Five
Do not change incident-severity definitions before an election to reduce reported privacy failures.
55.491Election-Year Integrity
Privacy failures remain reportable during:
- campaign season.
55.492No Data Access Expansion for Campaign
Do not give elected officials broader resident-data access because:
- they are campaigning;
- they want to "understand constituents."
55.493No Campaign Export
Municipal:
- email lists;
- recreation lists;
- business contacts;
- youth contacts;
- service-request data;
do not migrate to campaigns.
55.494Campaign Data Goes the Other Direction Too
Campaign-collected resident information should not be imported into municipal systems after election.
55.495Resident Consent to Campaign Is Not Consent to City
Separate organizations.
55.496City Consent Is Not Campaign Consent
Same.
55.497Official Account Transition
After an election:
Transfer official municipal accounts institutionally.
55.498Campaign Account
Remains separate.
55.499No Data Purge Before Transition
Do not delete municipal records because:
- administration is changing.
Follow records rules.
55.500No Data Hoarding After Leaving Office
Former officials do not retain personal copies of municipal resident databases.
55.501Baseline
Year One should establish:
- system inventory;
- data inventory;
- vendor inventory;
- data-sharing inventory;
- retention baseline;
- access baseline;
- Wi-Fi privacy review;
- AI inventory;
- surveillance inventory;
- information-correction process.
55.502Unknown Baseline
Where information has not previously been organized:
Say:
Not previously measured consistently.
55.503Do Not Pretend Legacy Systems Are Known
Unknown:
- vendor access;
- retention;
- export;
should be documented as unknown until verified.
55.504Year One Objective
Know:
- what is collected;
- where it is;
- why it exists;
- who can access it.
55.505Year Two Objective
Reduce unnecessary:
- collection;
- access;
- tracking;
- vendor risk.
55.506Year Three Objective
Migrate or remediate the highest-risk:
- legacy;
- locked-in;
systems.
55.507Year Four Objective
Leave the next Council:
- documented;
- portable;
- governed;
municipal information systems.
55.508Four-Year Core Measures
Strong candidates:
- high-risk systems inventoried;
- systems with documented purpose;
- systems with retention rules;
- access reviews completed;
- high-risk vendor contracts remediated;
- material privacy incidents;
- repeat incident causes;
- data-sharing arrangements reviewed;
- unnecessary datasets eliminated;
- public Wi-Fi analytics minimized;
- device reuse securely completed;
- AI systems governed;
- public information corrections;
- stale information retired;
- data export tests passed;
- non-digital service maintained.
55.509Do Not Set "Zero Privacy Incidents" as Only Goal
A zero count can encourage:
- underreporting.
Better goal:
reduce preventable incidents, detect quickly, report honestly and correct root causes.
55.510Serious Incident Goal
Aim for:
- no avoidable high-severity exposure.
But report reality honestly.
55.511Incident Trend
Use multi-year context.
55.512New Reporting System
If incidents rise after reporting improves:
Explain that possibility.
55.513Four-Year Privacy and Information Audit
At term end publish:
Systems inventoried
Personal-data systems
High-risk systems
Vendor access
Retention improvements
Data deleted or reduced
Access reviews
Privacy incidents
Repeat causes
Data-sharing reviews
Public Wi-Fi privacy
Device reuse
AI governance
Surveillance governance
Public-information corrections
Stale information retired
Non-digital access
Export and vendor exit
Major unresolved risks
55.514Name the Biggest Privacy Improvement
Use evidence.
55.515Name the Biggest Privacy Failure
Use evidence.
55.516Name the Highest-Risk Legacy System
At a safe level.
55.517Name the Biggest Unnecessary Dataset Removed
If appropriate.
55.518Name the Most Important Retention Reform
55.519Name the Most Important Vendor Exit Improvement
55.520Name a Vendor Relationship That Remains Too Dependent
If one does.
55.521Name the Most Important Public-Wi-Fi Privacy Improvement
55.522Name the Device-Reuse Result
55.523Name the Most Important AI Governance Decision
55.524Name an AI Use That Was Stopped
If evidence showed:
- low value;
- unacceptable risk.
55.525Name the Most Important Information Correction
Government should be willing to show it.
55.526Name the Most Persistent Stale-Information Problem
55.527Name the Largest Privacy Liability Handed to the Next Council
55.528Collection Test
Ask:
Are we collecting only what the service actually requires?
55.529Purpose Test
Ask:
Can we explain why each significant personal dataset exists?
55.530Retention Test
Ask:
Are we deleting information when its lawful purpose ends?
55.531Access Test
Ask:
Can only appropriate people access the information?
55.532Vendor Test
Ask:
Do we know which vendors can access resident data and what they do with it?
55.533Exit Test
Ask:
Can the City leave the vendor and take its records with it?
55.534Sharing Test
Ask:
Are we sharing only what the partner actually needs?
55.535Wi-Fi Test
Ask:
Can a resident use public Wi-Fi without becoming a movement or marketing profile?
55.536Device Test
Ask:
Can donated devices be reused without exposing either the donor's or recipient's private information?
55.537AI Test
Ask:
Are staff using AI without quietly sending protected resident data into systems we do not control?
55.538Surveillance Test
Ask:
Can the City justify every significant surveillance system it operates?
55.539Open Data Test
Ask:
Does public data expose government performance without unnecessarily exposing residents?
55.540Information Accuracy Test
Ask:
Can a resident tell when important City information was last verified?
55.541Correction Test
Ask:
When government is wrong, can residents see that it corrected itself?
55.542Non-Digital Test
Ask:
Can residents still obtain essential municipal service without creating an unnecessary digital profile?
55.543Campaign Test
Ask:
Could any candidate use municipal data to gain a political advantage?
The answer should be:
No.
55.544Rights Test
Ask:
Does the information system respect privacy, expression, conscience, due process and equal treatment?
55.545Resilience Test
Ask:
If the vendor, Internet connection or cloud service disappeared tomorrow, could the City continue essential service and recover its information?
55.546Independence Test
Ask:
Does the City control its data, domains, credentials and institutional accounts?
55.547Institution Test
Ask:
Would the information system operate safely if a completely different Mayor took office tomorrow?
It must.
55.548What Success Looks Like
Privacy and information success does not mean:
- City collects no data;
- no records are ever retained;
- everything is anonymous;
- everything is public;
- all systems are Canadian;
- every AI tool is banned;
- no camera ever exists.
Success means:
- the City knows what information it holds;
- collections have real purposes;
- unnecessary fields disappear;
- retention is intentional;
- old data is deleted appropriately;
- access follows roles;
- vendors are visible;
- sharing is controlled;
- public Wi-Fi provides access without becoming tracking infrastructure;
- reused devices are securely wiped;
- AI is governed;
- surveillance has defined purpose;
- public information is current;
- material mistakes are corrected openly;
- Open Data exposes government rather than vulnerable residents;
- non-digital access remains;
- the City can export its records and leave its vendors;
- campaign and municipal data remain completely separate.
55.549What Failure Looks Like
Failure includes:
- collecting information because software has a field for it;
- keeping personal data forever;
- former staff retaining access;
- vendors accessing data nobody at City Hall knew they could see;
- requiring universal digital identities for ordinary civic life;
- combining unrelated services into resident profiles;
- collecting political opinion through municipal systems;
- tracking public Wi-Fi devices across locations;
- using recycled phones without secure wiping;
- installing advertising trackers on City websites;
- accepting cookie banners as privacy strategy;
- feeding protected resident information into unapproved AI;
- allowing biometric features through software updates without public review;
- publishing vulnerable-person maps in the name of Open Data;
- hiding government spending behind inappropriate privacy claims;
- publishing residents' personal information in the name of transparency;
- silently changing material public information after errors;
- leaving expired benefit and grant programs online;
- making essential information app-only;
- allowing campaign data and municipal data to mix;
- discovering at contract termination that the City cannot export its own records.
55.550The Privacy and Information Scorecard Commitment
Owen Sound should commit to:
Know what information the City collects, where it is stored and why it exists.
Treat municipal information as both a public asset and a potential liability.
Maintain an inventory of significant information systems.
Include informal high-risk spreadsheets and shadow databases where appropriate.
Give every significant personal-information collection a specific purpose.
Do not collect information merely because it might be useful one day.
Limit information reuse to legitimate and lawful purposes.
Never convert municipal service data into campaign data.
Never give incumbents privileged resident-data access for political targeting.
Collect the least information reasonably necessary for the service.
Review major forms field by field.
Clearly distinguish required and optional information.
Do not collect exact birthdates, home addresses, telephone numbers, identification or banking information when less information will serve the purpose.
Use stronger safeguards for health, financial and information involving minors.
Collect accommodation needs rather than unnecessary diagnoses wherever possible.
Do not collect political or religious opinion through ordinary municipal service.
Do not turn civic participation into ideology profiling.
Apply the principle: Verify person. Protect opinion.
Maintain lawful and operational retention rules.
Do not keep information forever merely because digital storage is inexpensive.
Separate long-term archival records from active production databases where appropriate.
Delete or securely dispose of records when their lawful purpose ends.
Require vendors to address data return and deletion.
Understand how backups affect deletion.
Securely destroy obsolete physical and digital media.
Treat paper privacy as seriously as digital privacy.
Apply least-privilege access to personal information.
Review access when employees change roles.
Remove access promptly when staff, contractors or students leave.
Limit vendor support access.
Avoid shared privileged passwords.
Maintain appropriate access logs for sensitive systems.
Use access logs for security and accountability rather than unnecessary employee surveillance.
Use authentication proportionate to the service.
Do not require high-level identity verification for low-risk public information.
Allow anonymous browsing of ordinary public information.
Do not impose a universal municipal digital identity on ordinary civic life.
Do not create a single resident profile connecting unrelated municipal activities merely for convenience.
Never create resident, behavioural, civic-engagement or good-citizen scores.
Maintain an inventory of major data-sharing arrangements.
Share the minimum necessary information with other governments and partners.
Understand partner retention, reuse and subcontractor access.
Review where major City data is hosted and processed.
Treat Canadian hosting as one resilience and jurisdiction factor, not proof of security by itself.
Ask of every important system: who controls the data, who can access it, and can we leave?
Require important vendors to address ownership, access, security, breach, export, deletion, subcontractors and termination.
Keep City records under practical City control.
Test data export before a contract ends.
Do not accept screenshots or unusable proprietary files as meaningful portability.
Include migration and conversion costs in complete vendor cost.
Review vendor exit capability before contract renewal.
Perform appropriate privacy-impact review before high-risk systems are deployed.
Treat surveillance, biometrics, high-impact AI, location tracking and cross-department profiling as high-risk triggers.
Use Privacy by Design and ask whether the same outcome can be achieved with less data.
Use minimum collection and minimum sharing as default settings where possible.
Do not misuse vague consent when the City is actually exercising statutory authority.
Make optional consent understandable and separate from unrelated essential service.
Provide accurate privacy notices.
Do not make promises about absolute confidentiality that the law does not support.
Track material privacy incidents.
Distinguish privacy incidents from cybersecurity outages.
Contain, investigate, correct and report incidents according to applicable obligations.
Do not hide privacy failures for political reasons.
Do not release unverified breach information that creates additional harm.
Track repeat incident causes and correct systems, not merely individual mistakes.
Encourage staff to report privacy mistakes quickly.
Do not punish good-faith early reporting.
Design communication systems to reduce predictable human error.
Use proper bulk-mail and secure-document practices.
Review document metadata when it creates disclosure risk.
Use public Wi-Fi as an access service rather than a resident-tracking system.
Do not create persistent device or movement profiles through public Wi-Fi.
Disable unnecessary location and marketing analytics.
Do not require marketing consent to access taxpayer-supported Wi-Fi.
Do not collect an email address for Wi-Fi unless there is a real need.
Publish understandable Wi-Fi security information.
Measure public Wi-Fi uptime, coverage and complete cost.
Do not equate devices or sessions with unique residents.
Do not use Wi-Fi analytics as a substitute for foot-traffic measurement.
Treat public Wi-Fi and universal broadband as separate policy questions.
Require evidence of a real access, affordability or resilience problem before considering municipal broadband infrastructure.
Do not create household poverty maps to justify connectivity programs.
Collect minimal information from residents receiving connectivity support.
Avoid duplicating income verification where another lawful program already establishes eligibility.
Do not create a permanent poverty database.
Securely wipe every reused phone or device before redistribution.
Never transfer donor data to recipients or recipient data to donors.
Do not redistribute devices that cannot be reliably wiped.
Remove SIM cards, memory cards, account locks and old personal data appropriately.
Do not place hidden City tracking software on reused devices.
Make any remote-support capability transparent.
Verify emergency-calling claims before promoting reused phones as safety tools.
Track device receipt, wiping, redistribution and secure recycling.
Protect the identity of device recipients.
Review the municipal website for unnecessary analytics and third-party trackers.
Prefer aggregate page-use information over individual behavioural tracking.
Avoid advertising trackers on municipal websites unless an exceptional public case exists.
Review third-party videos, maps and social embeds for data leakage.
Do not treat a cookie banner as a substitute for minimizing tracking.
Avoid consent interfaces designed to manipulate residents into accepting unnecessary tracking.
Treat municipal website search terms and abandoned forms as potentially sensitive data.
Avoid invasive session-replay technology without compelling justification.
Do not install campaign-style social-media tracking pixels on City websites.
Keep newsletter lists out of campaigns.
Use community-calendar data only for the calendar's legitimate purpose.
Do not collect attendee identities merely because an event is publicly listed.
Apply the full privacy, procurement, conflict and portability standard to map.ca or any other proposed civic platform.
Give Mayor-associated technology more independent scrutiny, not less.
Define public standards before choosing the platform.
Do not force residents to create accounts to browse ordinary public information.
Treat any permanent public-email concept as high-risk infrastructure requiring independent governance, cybersecurity, privacy, portability and funding review.
Do not build municipal identity around one email provider.
Do not create a Data Locker merely because centralization sounds convenient.
Require a compelling resident need, strong governance, security, portability and public benefit before any Data Locker proceeds.
Recognize that centralizing resident records can increase catastrophic risk.
Allow the responsible decision to be not to build it.
Use Safe Information to improve access, accuracy, privacy, resilience and independence.
Give important public-information pages a responsible owner.
Date high-impact information.
Show when external programs were last verified.
Remove or archive expired grants, loans and benefits promptly.
Distinguish City summaries from authoritative outside sources.
Use plain language without changing the actual legal meaning.
Maintain a public Correction Log for material City information errors.
Correct important errors where residents actually encountered them, including social media where appropriate.
Do not silently rewrite material errors residents may have relied upon.
Normalize public correction rather than hiding mistakes.
Review repeated information errors for root causes.
Assign or retire orphaned public web pages.
Clearly label archived information as not current.
Distinguish publication date from underlying data date.
Use official channels as the authoritative municipal source.
Correct false information about City services and material emergency matters without trying to become an arbiter of every political disagreement.
Never label ordinary criticism or policy disagreement misinformation merely because City Hall dislikes it.
Maintain a simple official verification location for major alerts and notices.
Protect official domains, accounts and credentials as institutional assets.
Do not let official digital accounts depend on one employee's personal credentials.
Keep official mayoral channels separate from campaign channels.
Treat public business conducted through social media, text or messaging tools according to applicable records and privacy obligations.
Do not hide public business in personal accounts.
Remember that open government should expose government, not unnecessarily expose residents.
Publish public records proactively where appropriate while protecting private information.
Do not use privacy as an excuse to conceal public contracts, spending or lawful conflict disclosures.
Do not use transparency as an excuse to publish resident complaints, health information or other protected details.
Review Open Data for re-identification risk.
Recognize that names are not the only identifiers.
Suppress or aggregate small cells where needed.
Never publish household-level maps of vulnerable residents.
Consider the mosaic effect when several datasets can be combined.
Keep property information separate from household behavioural profiles.
Apply strong privacy standards to RealMap and any property-information platform.
Never add residents' complaints, politics or unrelated service use to public property profiles.
Keep YouthMap focused on opportunities rather than young people.
Do not create public maps of vulnerable seniors.
Protect sensitive infrastructure and archaeological information where appropriate.
Respect Indigenous knowledge and agreed information governance rather than assuming all information received by the City becomes Open Data.
Use practical information classifications without turning "confidential" into a shield against public accountability.
Maintain an inventory of material AI use.
Review AI systems according to what they actually do rather than vendor marketing labels.
Apply stronger governance to AI affecting eligibility, enforcement, employment, benefits or safety.
Tell staff what information may and may not be entered into AI systems.
Do not place protected resident information into unapproved public AI services.
Understand whether AI vendors retain or train on municipal prompts and outputs.
Do not assume vendor privacy protections, verify them.
Require human accountability for significant municipal decisions.
Never tell a resident that "the algorithm decided."
Correct material AI-generated public misinformation openly.
Determine appropriate records treatment for municipal AI use.
Include privacy, security, accessibility, retention, deletion, export and model-use terms in relevant AI procurement.
Pilot AI before broad high-impact deployment.
Stop AI systems whose cost, error, privacy or bias risk outweighs their benefit.
Do not confuse adding AI with modernizing a bad process.
Do not use AI to create employee emotion, productivity or behavioural scores by default.
Never use municipal AI for resident political-sentiment profiling.
Maintain surveillance purpose, retention and access rules.
Do not introduce facial recognition by default.
Require separate high-threshold review for biometrics and other highly intrusive identification technology.
Do not allow surveillance capabilities to appear quietly through vendor software updates.
Review automated licence-plate, drone, body-camera and audio systems according to actual municipal authority and risk.
Do not use drones for casual residential surveillance.
Do not use voice or emotion analytics merely because the software can.
Treat biometric convenience claims as insufficient justification for biometric collection.
Collect precise location only when the service actually needs it.
Do not request continuous device location for a one-time service report.
Review location metadata contained in uploaded photos.
Use incident location rather than resident live location where that is sufficient.
Review parking, utility and smart-infrastructure data for unnecessary behavioural inference.
Do not use utility consumption to build lifestyle profiles.
Use infrastructure sensors only when the data supports a real municipal decision.
Do not install technology merely to appear like a smart city.
Delete datasets that no longer have sufficient value or legal purpose.
Treat duplicate spreadsheets and obsolete databases as information debt.
Do not solve duplication automatically by building one giant resident database.
Consider federated systems where they better protect privacy and resilience.
Give residents an appropriate route to correct inaccurate personal information.
Make simple administrative corrections simple where lawful.
Know which system is authoritative for important data.
Resolve conflicting duplicate records.
Do not mistake a specific authoritative dataset for a justification to create a universal resident dossier.
Maintain phone, paper and in-person alternatives where appropriate for essential municipal services.
Offer digital convenience without making it compulsory.
Do not penalize non-digital residents without a clear lawful and public rationale.
Protect paper, telephone and public-counter privacy too.
Review privacy when translation or interpretation services require third-party access.
Do not send protected information into unapproved AI translation tools.
Keep Open Books focused on government money rather than residents' personal information.
Treat public grant and procurement information transparently while protecting participant and employee privacy.
Do not confuse privacy with secrecy or secrecy with privacy.
Use cybersecurity as a foundation for privacy.
Identify unsupported and end-of-life systems.
Maintain and test backups.
Test restoration rather than merely confirming that backup files exist.
Maintain ransomware and cyber-incident plans.
Require relevant vendors to report breaches promptly.
Recognize that vendor security failures can become City failures.
Do not treat cyber insurance as a replacement for cybersecurity.
Train staff against phishing without turning training into public employee shaming.
Make suspicious-message reporting easy.
Never describe a municipal system as unhackable.
Aim to prevent, detect, contain and recover.
Publish Privacy, Vendor, Incident, Wi-Fi, Device Reuse, AI, Data Sharing and Public Information Scorecard tables.
Use Green, Amber, Red and Grey with clear published definitions.
Never call a system secure merely because it is inventoried.
Never count policies written as risks resolved.
Never count training as incidents prevented.
Never discourage incident reporting to improve the score.
Never misclassify privacy or cybersecurity events to make the statistics look better.
Never accept vendor contractual language as proof that data was actually deleted.
Never call public Wi-Fi privacy-preserving while persistent tracking remains enabled.
Never redistribute devices without documented secure wiping.
Never call a dataset anonymous merely because names were removed.
Never use privacy to hide public accountability.
Never use transparency to expose private residents.
Never count AI responses generated as municipal problems solved.
Never change privacy incident definitions before an election.
Keep privacy reporting active through the election year.
Never export municipal resident data into campaign systems.
Never import campaign resident profiles into municipal systems.
Treat campaign and municipal consent as completely separate.
Transfer official accounts and credentials institutionally after elections.
Do not destroy public records before a political transition.
Do not allow departing officials to retain copies of municipal resident datasets.
Use Year One to understand what information exists and who can access it.
Use Year Two to reduce unnecessary collection, access, tracking and vendor exposure.
Use Year Three to remediate high-risk legacy and locked-in systems.
Use Year Four to leave the next Council a documented, portable and governed information environment.
Publish the full Four-Year Privacy and Information Audit.
Name the biggest privacy improvement.
Name the biggest privacy failure.
Name the highest-risk legacy system.
Name unnecessary datasets that were removed.
Name the most important retention reform.
Name the strongest vendor-exit improvement and any remaining dependency.
Name the Public Wi-Fi privacy result.
Name the Device Reuse privacy result.
Name the most important AI governance decision and any AI system that was stopped.
Name the most important public-information correction.
Name the most persistent stale-information problem.
Name the largest privacy liability being handed to the next Council.
Judge the final record by whether Owen Sound became better informed without becoming more intrusive.
A strong Privacy and Information Scorecard should allow a resident to ask:
Why does the City need this information?
Do I really need to provide it?
Who can see it?
How long will it exist?
Does a private vendor have access?
Can that vendor use it for anything else?
Can the City take its data back?
Can I use the service without being tracked?
Can I use public Wi-Fi without creating a movement profile?
Was this donated phone actually wiped?
Is an AI system reading my information?
Is a camera identifying me?
Can I get the service without a smartphone?
Is this public information still current?
When was it verified?
What happens when City Hall publishes something wrong?
And the City should be able to answer those questions without:
- jargon;
- secrecy;
- guessing.
Privacy does not require weak government.
It requires disciplined government.
Open government does not require exposing residents.
It requires exposing:
- decisions;
- money;
- authority;
- results.
Information technology should not make residents surrender more of themselves simply because computers make collection easy.
Collect less. Explain why. Protect what remains. Delete what is no longer needed. Control vendor access. Keep public information current. Correct mistakes openly. Preserve non-digital choice. Use technology to serve residents, not to profile them.