Privacy Policy

CITY OF DELTA - PRIVACY MANAGEMENT POLICY

Approved by the City Clerk/FOI and Privacy Head: Michelle Jansson, CMC
Administrative Policy Effective: February 3, 2025

PURPOSE

Section 36.2 of Freedom of Information and Protection of Privacy Act (FOIPPA) requires the head of a public body to develop a privacy management program for the public body and to do so in accordance with the directions of the minister responsible for FOIPPA.

This Privacy Management Program (PMP) is designed to provide City employees and the public with an overview of the Freedom of Information and Protection of Privacy Act (“Act”) and its application at the City of Delta.

SCOPE

The Privacy Management Program (PMP) applies to all City of Delta employees, Council members, volunteers, and contracted service providers, who shall comply with all duties and obligations set out in FOIPPA. To the extent that any portion of this Policy conflicts, or can be interpreted to conflict, with any provision of FOIPPA, the provision of FOIPPA will apply.

The Freedom of Information and Protection of Privacy Actclearly states that unauthorized collection, use and disclosure of personal information is prohibited. An employee, officer or director of a public body or associate of a service provider must not collect, use or disclose personal information except as authorized by this Act.

CONTACT

The City Clerk is designated as the Head and may be contacted by email at cityclerk@delta.ca or 604-946-3220.

POLICY:

1. Purpose for which personal information may be collected:
   • The City of Delta may collect personal information only if the information relates directly to and is necessary for a program or activity, as stated under section 26(c) of FOIPPA.
   • The individual the information is about must provide consent in the prescribed manner of how we collect the personal information.
   • The individual whom we collect the personal information must be informed about the purpose for collecting, the legal authority for collecting it, and the contact information of City of Delta’s FOI and Privacy Head.
   • The City of Delta will add a privacy disclaimer to all forms and correspondence, both paper and electronic, that collects personal information. By having this privacy disclaimer, individuals whom personal information is collected, is already a form of consent (implied consent).
     
     
2. Protection of personal information
   • City of Delta must protect personal information in its custody or under its control by making reasonable security arrangements against unauthorized collection, use, disclosure, and disposition.
   • City of Delta’s “Privacy Management Policy” states that:
     • Section 69(5.3) of FOIPPA requires that public bodies, that is City of Delta, must conduct a privacy impact assessment (PIA) and must do so in accordance with the directions of the minister of the Office of Information and Privacy Commissioner of BC (OIPC-BC).
     • The City Clerk is responsible for reviewing and approving recommended preventative measures on assessed potential privacy risks and impacts to ensure protection of Personal Information that is collected, used and shared.
       
       
3. Retention of personal information
   • The city of Delta must ensure that the personal information is retained for at least one year and stored securely in accordance with the City’s:
     • Corporate Records Management Program Bylaw No. 6502, 2006 and
     • City of Delta Freedom of Information and Protection of Privacy Bylaw No. 8408, 2024.
       
       
4. Use of personal information
   • Collected personal information shall only be used for the purpose for which the information was obtained to and consistent with the purpose.
   • Collected personal information must not be used for another set of engagement activities.
     
     
5. Access
   • Individuals may also ask for an explanation of how their Personal Information was used or disclosed, as well as correction of errors or omissions of their Personal Information. 
   • The City of Delta has created a process in providing access to City records, where there is a method of accessing records through the City’s website referencing City of Delta Freedom of Information and Protection of Privacy Bylaw No. 8408, 2024:
     • Routine Channels
     • Formal FOI Requests
       
       
6.  Disclosure
   • The City of Delta may disclose Personal Information to third parties when authorized under Freedom of Information and Protection of Privacy Act (FOIPPA). Disclosure of Personal Information without an individual's consent is limited to the circumstances specified under Section 33(2) to (9) of FOIPPA.
     
     
7. Security for Privacy
   • Personal Information is protected by physical, technical and organizational security measures that prevent unauthorized access, collection, use, disclosure, copying, modification and disposal of personal information. 
   • Computer access is restricted only to city staff with City issued login credentials that have complex passwords with multi-factor authentication (MFA).  
   • Physical files are secured under lock and key, along with City issued key-card access to enter staff-only rooms.

PIVACY DISCLAIMER

“Personal information is collected by the City of Delta under the authority of Section 26(c) of the Freedom of Information and Protection of Privacy Act (FIPPA) and will be used to administer activities that are published and accessed via LET’S TALK DELTA software application with the City of Delta. If you have any questions about the collection of this personal information, please contact one of the following options:”