Sample, fictional data

What a free readiness check looks like

After you email us your institution’s name, you receive a short PDF like the one below, built only from your own public website. The township, its website and every finding on this page are made up to show the format.

Municipal Privacy Desk

Free readiness check: Township of Example

Sample
Fictional

Prepared for
Clerk, Township of Example (fictional)
Website reviewed
www.township.example (fictional)
What we looked at
14 online forms, the “Access and Privacy” page and the website privacy statement. Public pages only.
Date
Sample only, not a real review

Summary Sample

We found five things worth fixing before January 1, 2027. Two of them are already required today and are quick to fix.

Findings at a glance (fictional)
#FindingWhen to act
19 of 14 online forms are missing part or all of the notice of collectionNow
2The privacy page describes rules that changed on July 1, 2026Now
3Camp registration collects children’s health details through an outside booking serviceBefore Jan. 1, 2027
4No breach contact or protocol is visibleBefore Jan. 1, 2027
5The newsletter sign-up asks for more than it needsWhen convenient

Findings Sample

FictionalFinding 1 · Act now, already required

9 of 14 online forms are missing part or all of the notice of collection

What we found

Five forms carry a complete notice. Nine are missing at least one of the three required parts.

Notice of collection on each online form (fictional)
FormLegal authorityPurposeContact
Camp and program registrationNoYesNo
Burn permit requestNoNoNo
Facility rental requestNoYesPartly
Newsletter sign-upNoNoNo
Report a road problemNoNoNo
Contact the townshipNoNoPartly
Volunteer applicationNoYesNo
Special event permitYesYesNo
Lottery licence applicationNoYesPartly
Dog licence applicationYesYesYes
Building permit applicationYesYesYes
Marriage licence appointmentYesYesYes
Access to information requestYesYesYes
Employment applicationYesYesYes

“Partly” means the form gives an email address but not the title, business address and phone number of someone who can answer questions.

Why it matters
This is not new. MFIPPA already requires every collection to tell people the legal authority, the main purpose, and the title, business address and phone number of someone who can answer questions (MFIPPA s. 29(2) on e-Laws). A missing notice is the easiest gap for anyone to see.
What to do
Add one standard notice to each form. For example:

Personal information on this form is collected under the authority of [by-law or statute] and will be used to [purpose]. Questions about this collection can be directed to the [title], Township of Example, [business address], [business phone].

FictionalFinding 2 · Act now

The privacy page describes rules that changed on July 1, 2026

What we found
The “Access and Privacy” page, last updated in 2019, says access requests are answered within 30 days and directs residents to a directory of personal information banks.
Why it matters
Since July 1, 2026, institutions generally have 45 business days to respond, and the requirement to keep personal information banks has been removed, although the IPC still encourages a published index (IPC table of changes). An out-of-date page sets the wrong expectations for residents.
What to do
Update the response time, decide whether to keep the index, and add a “last reviewed” date to the page.
FictionalFinding 3 · Before January 1, 2027

Camp registration collects children’s health details through an outside booking service

What we found
The summer camp registration asks for each child’s allergies, medical conditions and medications. The form is run by an outside booking service. We found no public information on how that data is protected or where it is stored. Assessments do not have to be published, so you may already have one.
Why it matters
From January 1, 2027, a written privacy impact assessment is required before collecting personal information. It must cover who can access the information, the safeguards and how long it is kept (MFIPPA s. 28(3) on e-Laws). Children’s health details held by a vendor are exactly the kind of information where a breach could create a real risk of significant harm.
What to do
Make this your first assessment. Check what the vendor contract says about where data is stored, who can see it and how fast the vendor must tell you about a breach.
FictionalFinding 4 · Before January 1, 2027

No breach contact or protocol is visible

What we found
No page tells residents how to report a privacy concern or a suspected breach, and there is no privacy contact other than the general clerk’s office email. A breach protocol does not have to be published, so you may already have one internally.
Why it matters
From January 1, 2027, a breach that creates a real risk of significant harm must be reported to the IPC and the people affected must be notified, as soon as feasible (MFIPPA s. 30.1 on e-Laws). Staff need to know in advance who decides, and how.
What to do
Adopt a breach protocol with a short decision guide, name who decides, start a breach log, and add a “report a privacy concern” line to the privacy page.
FictionalFinding 5 · When convenient

The newsletter sign-up asks for more than it needs

What we found
The newsletter form asks for date of birth and home address. Only an email address is needed to send a newsletter.
Why it matters
The Act allows a collection only when it is authorized by statute, used for law enforcement, or necessary to a lawfully authorized activity (MFIPPA s. 28(2) on e-Laws). Every extra field is more to protect and more to cover in an assessment.
What to do
Remove the date of birth and address fields.

What this check does not cover Sample

  • Internal policies, systems and paper records.
  • Vendor contracts, and whether assessments already exist internally.
  • Security testing of any system.
  • Whether a statute or by-law authorizes each collection. That is a question for your solicitor.

Next steps Sample

Findings 1, 2 and 5 are quick wins your staff can fix this month. We are happy to answer questions about this check at no cost.

If you would like help with the rest, the Bill 97 Readiness Pack covers findings 3 and 4 and the documents behind them: assessment policy and template, a first completed assessment, breach protocol and decision guide, notice templates, breach log, safeguards register, personal information inventory and briefings. One fixed price, published on our home page, delivered in about 3 weeks.

Prepared by Municipal Privacy Desk, operated by 1414618 B.C. Ltd., Vancouver, British Columbia. Based only on public web pages. Practical guidance, not an audit and not a legal opinion.

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What to put in your email

  • Your institution’s name.
  • Your name and role, so we know who the PDF is for.

Please do not send personal information about residents or staff. We do not need it.