1.0  Accountability

For the purposes of this Privacy Statement/Guideline, Toronto Transit Commission affiliates shall mean the following entities:

  • Toronto Coach Terminal Inc.;
  • Toronto Transit Infrastructure Limited;
  • TTC Insurance Company Limited;
  • TTC Pension Fund Society;
  • TTC Sick Benefits Association

Hereinafter referred to collectively as “TTC affiliates”, “Toronto Transit Commission affiliates” or “we”.

Toronto Transit Commission affiliates are responsible for personal information under their control.  The Coordinator – Records Management/Freedom of Information, Commission Services Department for the TTC (“Coordinator”), has been designated by each of the TTC affiliates as the individual accountable for compliance in accordance with PIPEDA and this Privacy Statement/Guideline.

A request to any one of the TTC affiliates in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) shall be:

  1. in writing;
  2. made to the Toronto Transit Commission’s Co-ordinator – Records Management/Freedom of Information; and
  3. specify the information that is requested and the authority (i.e. PIPEDA) in which the information is being requested.

2.0   Purposes

TTC affiliates will use personal information that is collected for the following purposes:

  • to communicate with you;
  • assess and process your application for pension, accident benefits, insurance benefits and/or sick benefits, as applicable;
  • evaluate and administer claims for pension benefits, accident benefits, insurance benefits and/or sick benefits;
  • detection and prevention of fraud;
  • capture injury/witness data;
  • analyse business results;
  • process payments;
  • administer pension benefits and/or insurance benefits;
  • issue travelling documents;
  • statistical and actuarial purposes;
  • auditing internal procedures; and
  • as required or as otherwise authorized by law;

If any TTC affiliate requires personal information for any other purpose, save and except for as stated in 2.0 above, we will ask for and obtain verbal or written proof of your expressed consent before using it.

3.0 Consent

A person may provide consent in different ways for the collection, use or disclosure of personal information. When you do business with a TTC affiliate, we ask that you provide information that we use in the course of providing various services to you or to help in the investigation of claims.  By providing this information, you also give your implied consent to the TTC affiliates and the Toronto Transit Commission to use this information to provide you with various services and/or evaluate applications for various benefits.

Individuals can give consent in many ways. For example:

  1. an application form may be used to seek consent, collect information, and inform the individual of the use that will be made of the information. By completing and signing the form, the individual is giving consent to the collection and the specified uses;
  2. a check off box may be used to allow individuals to request that their names and addresses not be given to other organizations. Individuals who do not check the box are assumed to consent to the transfer of this information to third parties;
  3. consent may be given orally when information is collected over the telephone; or
  4. consent may be given at the time that individuals use a product or service. 

TTC affiliates may collect, use or disclose personal information without your knowledge or consent in certain circumstances, including detection and/or prevention of fraud.

You may withdraw your consent at any time, subject to legal or contractual restrictions and the requirement to maintain the integrity of the statistics and data necessary to carry on our business.  However, the withdrawal of consent may affect our ability to respond your requests and to provide you benefits.

4.0 Limiting Collection

The collection of personal information by TTC affiliates is limited to that which is necessary for the purposes identified in section 2.0 above. All personal information is collected by TTC affiliates in a fair and lawful manner.

5.0 Limiting Use, Disclosure, and Retention

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained in accordance with applicable Toronto Transit Commission retention by-laws or as long as necessary for the fulfilment of those purposes.

6.0 Accuracy

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used as set out in section 2.0 above.

7.0 Safeguards

All personal information collected by TTC affiliates will be protected by using appropriate safeguards against loss, theft and unauthorized access, disclosure, copying, use or modification. The methods of protection may include:

  1. physical measures, for example, locked filing cabinets and restricted access to offices;
  2. organizational measures, for example, security clearances and limiting access on a "need-to-know" basis; and
  3. technological measures, for example, the use of passwords and encryption. 

8.0 Openness

TTC affiliates are committed to ensuring that specific information about their policies and practices relating to the management of personal information are provided. For further information, please contact the Toronto Transit Commission Co-ordinator – Records Management/Freedom of Information at 416-393-3934.

The information made available includes:

  1. the name or title, and the address, of the person who is accountable for the TTC affiliates policies and practices and to whom complaints or inquiries can be forwarded;
  2. the means of gaining access to personal information held by any of the TTC affiliates;
  3. a description of the type of personal information held by any of the TTC affiliates, including a general account of its use;
  4. a copy of any brochures or other information that explain any of the TTC affiliates policies, standards, or codes; and
  5. what personal information is made available to other TTC affiliates and the Toronto Transit Commission (e.g., subsidiaries). 

9.0  Individual Access

An individual may make a written request for access to his/her personal information in any of the TTC affiliates possession. An individual may be required to provide sufficient information to permit the TTC affiliate to properly provide an account of the existence, use, and disclosure of personal information. The information provided shall only be used for this purpose. We will attempt to respond to any request within 30 days of receiving such a request.  We may charge an individual for providing access to his/her information, but only after first advising the individual of the approximate cost.

If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, the TTC affiliate shall amend the information as required. Depending upon the nature of the information challenged, amendment involves the correction, deletion, or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.

10.0 Challenging Compliance

If an individual believes that a TTC affiliate is not complying with the principles set out in PIPEDA, please contact the Toronto Transit Commission’s Co-ordinator – Records Management/Freedom of Information, who will investigate an individual’s concerns.  All TTC affiliates will investigate all complaints. If a complaint is found to be justified, the TTC affiliate shall take appropriate measures, including, if necessary, amending its policies and practices.