Ontario Municipalities Should Exercise Care in
Publishing Personal Information
The Information and Privacy Commissioner of Ontario (IPC) has
published new guidance entitled, Transparency, Privacy and the Internet:
Municipal Balancing Acts. This guidance follows a
complaint by an individual whose personal information was posted to
the Internet (initially, name, address, signature, email and other
personal contact details) by the City of Vaughan without
sufficiently informed consent. Although ultimately the IPC
concluded in Privacy Complaint Report MC 13-67 that there
was statutory authority for posting certain of this information,
the complaint has resulted in the IPC providing guidance to
municipalities on how to better balance making information publicly
available over the Internet and the privacy interests of
The IPC's guidance document recognizes that publication of
personal information to the Internet is qualitatively different
from other methods of making information available to the public.
Responsible municipalities should consider a number of methods to
balance the benefits of this approach to making information
available with the privacy interests of individuals. Some of the
Proactive redaction of unnecessary
Data minimization to reduce the
quantity of information being collected and used in the first
Technical measures to prevent page
indexing so that the records will not be directly searchable
through search engines
Although the guidance is voluntary, it is to be hoped that
municipalities will implement the recommendations of the IPC to
better enhance privacy of Ontarians.
Note: Dentons had the privilege of representing the complainant
in this important case.
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