TTC Privacy Code


Privacy Statement/Guideline-For Toronto Transit Commission

Introduction

TTC is committed to respecting and protecting the privacy and confidentiality of the Personal Information that is entrusted to us.

1.0 Accountability

The TTC is responsible for personal information under its control. The Coordinator – Records Management/Freedom of Information, Commission Services Department has been designated by the TTC as the individual accountable for compliance in accordance with the Municipal Freedom of Information and Protection of Privacy Act (“MFIPPA”) and this Privacy Code.

A request to TTC in accordance with MFIPPA shall be:

  1. in writing;
  2. made to the TTC’s Co-ordinator – Records Management/Freedom of Information; and
  3. provide sufficient detail to enable an experienced employee of the institution, upon a reasonable effort, to identify the record;
  4. at the time of making the request, pay the $5.00 application fee that is prescribed by MFIPPA for seeking access to a record (payable to the TTC or Toronto Transit Commission)

2.0 Purposes

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

  • to communicate with you;
  • assess and process applications for employment, information, injury/damage claims, employee benefits, accident benefits, insurance benefits, and/or sick benefits as applicable;
  • evaluate and administer employment applications, tenders, proposals, contracts, injury/damage claims, pension benefits, accident benefits, insurance benefits, and/or sick benefits if applicable;
  • detection and prevention of fraud;
  • capture injury/witness data;
  • safety and security;
  • analyze business results;
  • process payments;
  • administer pension benefits;
  • issue travelling documents;
  • statistical and actuarial purposes;
  • auditing internal procedures;
  • in a manner consistent with why the personal information was collected;
  • consistent with the TTC Website Terms and Conditions of Use; and
  • as required by similar organizations for the purpose of providing transit services and employment or as otherwise requested by law.

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

3.0 Consent

When you do business with the TTC, the TTC asks that you provide information that it uses in the course of providing various services to you or to help in the investigation of claims. By providing this information you consent to the use of this information in order for the TTC 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;
  4. consent may be given at the time that individuals use a product or service;
  5. use of TTC website (See TTC Website Terms and Conditions of Use).

TTC may collect, use or disclose personal information without your knowledge or consent in accordance with MFIPPA.

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 TTC business. However, the withdrawal of consent may affect the TTC’s ability to respond to your requests and to provide you services.

4.0 Limiting Collection

The collection of personal information by TTC is limited to that which is necessary for the purposes identified in the MFIPPA and in section 2.0 above. All personal information is collected by the TTC 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 permitted by law, including any sections of the MFIPPA relating to the disclosure of personal information. Personal information shall be retained in accordance with applicable TTC record retention by-law 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.

7.0 Safeguards

All personal information collected by the TTC will be protected by using appropriate procedural, electronic, technical and physical safeguards against loss, theft and unauthorized access.

8.0 Openness

The TTC is committed to ensuring that specific information about its policies and practices relating to the management of personal information are provided. For further information, please contact the Toronto Transit Commission Freedom of Information at 416-472-2011.

The information made available includes:

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

9.0 Individual Access

An individual may make a written request for access to his/her personal information in the TTC’s possession. An individual may be required to provide sufficient information to permit the TTC to properly provide an account of the existence, use, and disclosure of personal information. The information provided shall only be used for this purpose. All requests will be handled in accordance with MFIPPA. TTC may charge an individual for providing access to his/her information in accordance with the MFIPPA.

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

10.0 Challenging Compliance

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

Other important information

The TTC Privacy Code should be read in conjunction with the TTC Website Terms of Use.

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