Privacy Protection

Use of Social Media by the Public

Municipal social media accounts are publicly accessible and posts are visible to the public. For your own protection, please do not post any personal information about you or anyone else (including email addresses, mailing addresses and telephone numbers). Personal information posted to Township’s social media accounts may be deleted without notice. 

Use of Social Media by Staff

The exception of photographs, Municipal staff are prohibited from posting or sharing personal information on Municipal social media accounts. Photographs that feature a member of the public may be posted or shared if the person in the photograph has provided written consent or if the photograph was taken at a public event where no expectation of privacy existed.

Authenticating to the Municipal Website Using Social Media

Social media accounts, such as Facebook and LinkedIn, are provided by third parties who have their own terms of use, policies, procedures and privacy policies. When you use your social media accounts to authenticate to a Municipal website, you do so at your own risk.

When you choose to authenticate to the Municipal website using your social media, the Township will be able to see information contained within your public profile. The Township may collect and use the email address and name that is associated with your social media account. The Township will not otherwise use your personal information contained within your public profile (including your contact lists) without your knowledge and consent.

To protect Municipal assets, employees and the public, electronic video surveillance (also known as CCTV or closed circuit television) is used by the Municipality and the environment is designed to promote public safety and security.

How does the System Work?

CCTV cameras record video images of Municipal property 24 hours a day, 365 days a year. The video that is recorded is stored in digital format. Recorded video is used to investigate incidents and as evidence for prosecutions. However, not all cameras are monitored at all times.

Privacy Protection

The Municipality recognizes the need to balance an individual’s right to privacy and the need to ensure safety and security in the community. It has designed its video surveillance program to ensure the benefits of video surveillance outweigh the loss of personal privacy. It does this by employing a number of strategies:

Where feasible, less invasive means such as lighting and increased security patrols are employed in place of CCTV.

CCTV cameras are positioned and screened to ensure that only “mission critical” views are recorded. 

CCTV cameras are limited to spaces where individuals typically have a lower expectation of privacy. CCTV cameras are not installed in spaces where individuals would have a greater expectation of privacy such as washrooms or change rooms.

The retention period for recorded video is strictly limited and destruction of the video records at the end of the retention period is automated.

The program is subject to random compliance audits.

Retention

The video recordings from Municipal facilities are retained for 31 days. 

Disclosure to Law Enforcement

The Municipal discloses video records to law enforcement agencies in Canada upon request, providing the records are used for the purposes of an active law enforcement investigation.

Legal Authority

Personal information collected through the recording of surveillance video is collected under the authority of the Municipal Act and the Occupier's Liability Act.

Drone Cameras

Fire and Emergency Services may drone cameras for the purposes of firefighting, providing paramedical support to large public events or in response to a community emergency. 

Body-Worn Cameras

The Municipality does not, at present, use body-worn cameras.

Video Analytics

Video analytics include tactics such as facial recognition, automated crowd counting, automated object recognition and automated object tracking. The Municipality currently does not employ video analytics.

The Township uses data analytics (also known as business intelligence) to assist with evidence-based decision making. Data analytics are critical to:

• Transparency and objectivity in decision making;
• Efficiency, automation and scalability;
• Powering citizen-centric services; and,
• Digital-first and smart cities initiatives.

When Can the Township Use Your Personal Information?

In general, the Township may only use your personal information if:

• You have consented to its use;
• It is used for the reason for which it was collected (as stated in the notice of collection); and,
• The Township has taken reasonable steps to ensure that it is accurate and up to date.

When Can the Township Disclose Your Personal Information?

The Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) establishes that the Township may only disclose your personal information in the following circumstances:

• You have consented to the disclosure;
• For the purpose for which the personal information was obtained or compiled or for a consistent purpose;
• Where the disclosure is necessary and proper in the discharge of the City’s functions;
• For the purpose of complying with legislation;
• For law enforcement purposes;
• In compelling circumstances affecting the health or safety of an individual;
• In compassionate circumstances, to facilitate contact with the next of kin or a friend of an individual who is injured, ill or deceased;
• To the Information and Privacy Commissioner of Ontario; and,
• To the Government of Canada in order to facilitate the auditing of shared cost programs.

Personal information that has been used or disclosed inappropriately constitutes a privacy breach. Report privacy concerns to clerk@armourtownship.ca 

The Township uses the definition of personal information set out in the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA):

“…personal information” means recorded information about an identifiable individual, including,

• information relating to the race, national or ethnic origin, colour, religion, age, sex, sexual orientation or marital or family status of the individual,
• information relating to the education or the medical, psychiatric, psychological, criminal or employment history of the individual or information relating to financial transactions in which the individual has been involved,
• any identifying number, symbol or other particular assigned to the individual,
• the address, telephone number, fingerprints or blood type of the individual,
• the personal opinions or views of the individual except if they relate to another individual,
• correspondence sent to an institution by the individual that is implicitly or explicitly of a private or confidential nature, and replies to that correspondence that would reveal the contents of the original correspondence,
• the views or opinions of another individual about the individual, and
• the individual’s name if it appears with other personal information relating to the individual or where the disclosure of the name would reveal other personal information about the individual”.

Information about an individual in a business, professional or official capacity is not considered to be personal information. This includes information about a business carried out in a home.

Collection of Personal Information

We only collect your personal information through the Township’s website or mobile applications when you voluntarily provide it to us. This includes when you:

• Participate in an online forum, poll or survey;

• Fill in a feedback or contact form;
• Request further information about a specific topic;
• Send us an email; or,
• Create a user profile for online services.

The collection, use and disclosure of personal information is limited to information critical to providing Municipal services.

You will be provided with a notice of collection before any personal information is collected through our websites or mobile applications. If you choose not to provide personal information online, you can contact the Township by telephone, fax, mail or in person. (Not all options may be available in every situation).

Use of Personal Information

Whenever the Township collects your personal information, it will be used in accordance with the consent you have provided to deliver the services you have requested.

User Profiles

When you register for a web or mobile account, your personal information will be used to build your user profile. Your user profile helps the Township to understand your preferences and helps us to deliver services in a way that is relevant to you. Your user profile may grow as you consent to providing additional personal information to facilitate various online services and/or transactions.

Sharing or Disclosing Your Personal Information

Your personal information will not be disclosed except to authorized personnel (which may include elected officials, managers, employees, volunteers, contractors and vendors) for the purpose of addressing your feedback and/or to provide you with services you have registered for or otherwise requested.

We do not trade, rent or sell your information to any outside company or organization. We will not reveal specific information about you to unaffiliated third parties for their independent use, except if required to do so by law.

Transactions Where Your Personal Information Enters a System of Record

The Township has a number of applications and databases that are required to administer services. Information that is provided to us online through our website(s) may be processed and stored in a separate, secured database.

Tracking Your Website Visit

When you visit armourtownship.ca, the web server automatically collects a limited amount of information related to your visit such as your Internet Protocol (IP) address, the type of browser used, the date and time of your visit, and the IP address locations to which you linked during your visit to our site. This information is used for statistical analysis, evaluation of the effectiveness our website, and to plan for future services.

We Use Analytics and Cookies

Analytics is a web tool used to analyze website traffic. All data provided by to the Township is anonymized (i.e. it is not possible to identify any particular individual website user from the data provided). The data provided by the website administrator helps the Township to understand:

• How typical users navigate to the website;
• The typical demographics of website users (specifically age, gender and interests); and,
• How the website is typically used (specifically time spent on the website, pages visited, how users navigate through the website).

Analytics uses cookies, which are temporary files that may be placed on your hard drive while you visit the website. The Township also uses cookies to optimize the browsing experience collecting statistical information such as network speed, device type, browser type, and screen size. Cookies are used to track how visitors use armourtownship.ca, but the Township does not store personal information through cookies, nor does the Township collect personal information from you without your knowledge as you browse this website.

The Township may use cookies for claim based authentication after you choose to register and sign in to a user account you have created with the Township, but that cookie will be encrypted and will comply with strict security and encryption standards.

Authenticating to the City Website Using Social Media

Social media accounts, such as Facebook and LinkedIn, are provided by third parties who have their own terms of use, policies, procedures and privacy policies. When you use your social media accounts to authenticate to a Township website, you do so at your own risk.

Online Transactions

You can pay for some Municipal Services (e.g. recreation programs & property taxes) on the Township’s website. We do not process any payment transaction on the Township’s infrastructure; we redirect it to our transaction processor vendor who is compliant with the Payment Card Industry (PCI) Data Security Standard (DSS).

These transactions are done through SSL-encrypted technology. This means that your payment is transmitted to us securely. We do not retain your credit card or payment information.

Third Party Vendors

The Township of Armour uses third party vendors to provide it with technology infrastructure, systems and software to operate its website and to provide services to residents. Where personal information is disclosed to vendors, the Township requires the vendors to use your personal information in accordance with their policies and procedures.

Changes to Practices

As technology evolves, Township practices and procedures related to privacy protection may change. Check back routinely to be sure you have the latest information.

In order to provide the programs and services you depend on; the Township often needs to collect and use your personal information.

The Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) establishes that the Township must give notice when your personal information is collected. The notice of collection must state:

• The legal authority for the collection of personal information;
• The reason for the collection of personal information and how the personal information will be used; and,
• Who to contact for more information on the collection and use of the personal information.

 Notice can be provided in a variety of formats including statements on printed forms, on websites and web applications, in recordings, and on signage at facilities.