MC17-32

The Office of the Information and Privacy Commissioner of Ontario received a complaint alleging that the Halton Regional Police Services Board (the police)’s online application process for a police record check, which involves a third party company, collects and uses applicants’ personal information contrary to the Municipal Freedom of Information and Protection of Privacy Act (the Act).
In this Report, I conclude that the police’s retention and use of applicants’ information is, respectively, in accordance with sections 30(1) and 31 of the Act. I also conclude that the police have reasonable measures in place to protect the information, as required by section 3(1) of Regulation 823. However, I find that the police’s collection of the information and notice of the collection is not, respectively, in accordance with sections 28(2) and 29(2) of the Act. In response to this finding, the police have agreed to implement my recommendations to address this concern.