The London Youth Advisory Council (LYAC) is a federally supported not-for-profit community organization with a volunteer board of directors and professional staff whose purpose is to support young people in political engagement and community work. The council is composed of 15 young people between the ages of 15 and 25 who are elected by the community in yearly elections. The LYAC also conducts research projects with young people in an effort to better understand the needs of young people and to amplify their voices.
1.0 Identifying Purposes: Why Are We Collecting Personal Information?
We collect personal information in a number of contexts. First, as part of our annual elections, we ask voters to provide certain information so that we can verify their eligibility to vote in a particular ward. Second, we collect information when an individual applies to be a candidate in our elections so that we can verify their eligibility to participate and communicate with them. Third, we collect information from focus groups participants and interviewees in the course of the discussion, interview, or focus group.
2.0 Consent: How and When?
Express, written consent will be obtained before or at the time personal information is collected, and the purpose(s) for the collection, use or disclosure of the personal information will be provided to the individual at that time. Express consent will also be obtained if, or when, a new use is identified.
3.0 Limiting Collection, Use, Disclosure and Retention
Collection of Personal Information
Personal information collected by the LYAC will be used only for the purposes identified at the time and as outlined in this policy. Information is collected either for the purposes of verifying votes in our elections process, as part of candidate applications for youth councillors, or as part of focus groups (see more in Retention of Personal Information, below).
Use of Personal Information
Personal information will be used for only those purposes to which the individual has consented with the following exceptions (as permitted under PIPEDA):
The LYAC will use personal information without the individual’s consent, where:
- the LYAC has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
- an emergency exists that threatens an individual’s life, health or security;
- the information is for statistical study or research;
- the information is publicly available;
- the use is clearly in the individual’s interest, and consent is not available in a timely way; and,
- knowledge and consent would compromise the availability or accuracy of the information
Disclosure and Transfer of Personal Information
Personal information will be disclosed only to those LYAC employees, contractors, and Board Directors that need to know the information for in order to complete their work.
Personal information will be disclosed to third parties with the individual’s knowledge and consent.
PIPEDA permits the disclosure of personal information to third parties without an individual’s knowledge and consent, to:
- a lawyer representing the LYAC;
- comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction;
- a law enforcement agency in the process of a civil or criminal investigation;
- a government agency or department requesting the information; or,
- as required by law.
Retention of Personal Information
Vote Verification: Once ballots are recorded (only name and confirmation of ward) and verified, paper ballots are destroyed (shredded). Once we’ve run verification process (check for duplicate votes, etc.), all information is de-identified/made anonymous or deleted entirely. We keep track of some data for statistical purposes, including the number of voters per ward, age range in the election, total voters, and gender of voters. We track this information for evaluation purposes in order to understand how our outreach working, whether we seeing an increase in voters, how a lower voting age impacts voter turnout, and how our voting pool reflects the broader demographics of the city.
Candidate Applications: Personal information gathered through candidate applications is used to verify the applicant’s eligibility to run in the election, and to contact them to provide more information. After the close of elections (usually in May, but subject to change), applications will be deemed inactive. Information will be retained for 6 months and then anonymized, unless the applicant chooses to receive emails from us. In that case, only their first and last name and email address will be retained.
Focus Group and Interviews: we will retain all consent forms for 1 year after the date of the focus group, at which point the forms will be destroyed, except where the individual provides consent to receive emails from us. Information from focus groups and interviews is anonymized before publication. Notes that identify the names of participants will be anonymized or destroyed if it is not possible to adequately anonymize them. Publications may identify any organizations that partnered on the project.
4.0 Protecting Personal Information
Organizational Safeguards: Access to personal information will be limited to those individuals involved in verifying votes and responsible for communicating with community members who have consented to receive our emails. No one is permitted to copy or retain any personal information on voters, and all individuals will receive training both on complying with PIPEDA and CASL.
Physical Safeguards: Files are stored in locked filing cabinets when not in use. As stated in section 3.0, personal information no longer required is shredded prior to disposal.
6.0 Accuracy and Access
An individual who wishes to review or verify what personal information is held by the LYAC, or to whom the information has been disclosed (as permitted by the Act), may make the request for access, in writing, to the Executive Director. Upon verification of the individual’s identity, the Executive Director will respond within 60 days.
If the individual finds that the information held by the LYAC is inaccurate or incomplete, upon the individual providing documentary evidence to verify the correct information, the LYAC will correct the information promptly.
Any concern about the LYAC’s personal information handling practises, can be expressed,in writing, and directed to the LYAC’s Executive Director. Once the individual’s identity is verified, the Executive Director, together with the Board of Directors, will investigate the complaint and provide a written report of the investigation’s findings to the individual.
Where the Executive Director and Board of Directors makes a determination that the individual’s complaint is founded, they will take the necessary steps to correct the offending information handling practice and/or revise the LYAC’s privacy policies and procedures.
Where the Executive Director determines that the individual’s complaint is not well founded, the individual will be notified in writing.
If the individual is dissatisfied with the finding and corresponding action taken, the individual may bring a complaint to the Federal Privacy Commissioner at the address below:
The Privacy Commissioner of Canada Email address: www.privcom.gc.ca.
112 Kent Street, Ottawa,
Ontario K1A 1H3
Questions and Complaints
Any questions regarding this policy may be directed to the Executive Director. Requests for access to information, or to make a complaint, are to be made in writing and sent to the Executive Director at the address below:
London Youth Advisory Council
184 Horton Street East