TOWNSHIP OF ESQUIMALT STAFF REPORT
MEETING DATE: November 3, 2025 Report No. ADM-25-058
TO: Council
FROM: Deb Hopkins, Director of Corporate Services
SUBJECT: Policy ADMIN-84 Privacy
RECOMMENDATION:
Recommendation
That Council approve Policy ADMIN-84 Privacy.
Body
EXECUTIVE SUMMARY:
Staff are working to modernize Esquimalt's Privacy Management Program (PMP) to ensure the Township's continued compliance with its legislative and regulatory obligations. During staff's review of current policies and practices, staff noted the absence of a policy that establishes procedures for the appropriate collection, use, disclosure, access, storage, retention, and disposal of personal information in accordance with the Freedom of Information and Protection of Privacy Act, other statutes, and fair information practices. As a result, Policy ADMIN-84 Privacy is presented for Council's consideration.
BACKGROUND:
In 2021, section 36.2 of the Freedom of Information and Protection of Privacy Act (FIPPA) was updated directing FOI Heads of all public bodies to develop a Privacy Management Program (PMP) effective February 1, 2023. Under FIPPA, all local governments are designated as public bodies. Within the regulation it was noted that requirements for a PMP were not intended to be burdensome and may comprise pre-existing policies and practices and it is assumed that this is how former staff initially proceeded. However, monitoring and updating of the program is required to ensure the PMP remains appropriate to the activities of the public body and in compliance with FIPPA. As a result of staff review and analysis, several necessary changes were identified.
As part of the PMP review and modernization work underway, staff are developing a suite of policies that outline Township responsibilities and procedures required to comply with the established regulatory framework around access to records and protection of privacy. The program consists of an evolving set of p...
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