Confidentiality and Privacy Policy

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Policy Type: Operational

Policy Title: Confidentiality and Protection of Privacy

Policy Number: OP-03

Policy Approval Date: November 6, 2008 Date of Next Review: March 2026

Board Chair: Date:

The Brighton Public Library recognizes that its patrons’ choice of materials they borrow and websites

they visit is a private matter. The Library will therefore make every reasonable effort to ensure that

personal information about its patrons and their use of Library materials, services and programs remains

confidential.

1. Personal information is defined in Municipal Freedom of Information and Protection of Privacy Act,

R.S.O. 1990, c. M.56 (MFIPPA), in part, as “recorded information about an identifiable individual”.

This could include, in the Library context, information on a user’s borrowing habits, as well as

information related to computer and Internet use.

2. The Library Board ensures that:

a) the Library complies with the spirit, principles and intent of MFIPPA,

b) members of the public have access to information about the operations of the Library and to

their own personal information held by the Library in accordance with the access provisions of

MFIPPA, and

c) the privacy of an individual’s personal information is protected in compliance with the privacy

provisions of MFIPPA.

3. The Library Board is responsible for personal information under its control, designates the Chief

Executive Officer (CEO) as the individual accountable for the organization's compliance with

legislation, and ensures that:

a) The purposes for which personal information is collected shall be identified by the Library at, or

before, the time the information is collected.

b) Consent of the individual is acquired for the disclosure of collection use or personal information.

c) The collection of personal information shall be limited to that which is necessary for the proper

administration of the Library and the provision of Library services and programs.

d) The Library will not retain any personal information related to the items borrowed or requested

by a user, or pertaining to a user’s online activity, longer than is necessary for the provision of

Library services and programs.

e) The Library will not disclose personal information related to a visitor or a Library user to any

third party without obtaining consent to do so, subject to certain exemptions as provided by

MFIPPA. Information will be disclosed:

i. about a person less than sixteen years old, to a parent or guardian of that person,

ii. upon the presentation of a search warrant,

iii. to police in the absence of a search warrant to aid an investigation (at the CEO’s

discretion), or

iv. to the Children’s Aid Society, under the authority of the Child, Youth and Family

Services Act, 2017, S.O. 2017, c. 14, Sched. 1, which states that a person who believes, on

reasonable grounds, that a child under 18 is at risk of harm, has a duty to report this

suspicion to the Children’s Aid Society immediately, directly and on an ongoing basis.

f) Personal information shall be as accurate, complete and up-to-date as is necessary for the

purpose for which it is used.

Brighton Public Library

OP-03 Confidentiality and Protection of Privacy March 26, 2025 Page 2 of 1

g) Personal information shall be protected by security safeguards appropriate to the sensitivity of

the information.

h) Upon request, an individual shall be informed of the existence, use, and disclosure of his or her

personal information, and shall be given access to that information. An individual shall be able

to challenge the accuracy and completeness of the information and have it amended as

appropriate.

i) An individual shall be able to address a challenge concerning compliance with the above

principles to the CEO.