POLICY - Routine Disclosure - 20221005
100 John West Way
Aurora, Ontario
L4G 6J1
(905) 727-3123
aurora.ca
Town of Aurora
Routine Disclosure Policy
Legislative Services
Contact: Program Manager, Records Management
Approval Authority: CAO
Effective: October 5, 2022
______________________________________________________________________________________
Background
Routine Disclosure of records is a process that supports government transparency.
This policy provides regulations for the Town of Aurora on records that may be released
through this policy and which records must go through the Municipal Freedom of
Information and Protection of Privacy Act (the Act) process.
Objective
Equal access to records and information is essential to government transparency. The
Act requires the Town to put measures into place that provides access to records and
information, as well as protect personal information.
This policy is designed to streamline the Town’s release of records to support the
organization’s operating needs and transparency, without eroding good business
practices or circumventing internal controls and authorities.
Scope
This policy applies to all Town employees, elected officials, students and volunteers,
contractors, subcontractors and third-party providers offering services on behalf of the
Town, who have access to or in the course of their duties handle any records under the
custody and control of the Town.
Definitions
Active Dissemination
The routine or periodic release of government records identified in Appendix “B” in the
absence of a request. These records are classified as public records as per the
Classification and Retention By-law Schedule “A” and can be released by departments
at any time.
Clerk
The Clerk, Deputy Clerk, or their designate of the Town, having all the powers and duties
of the Clerk under the Municipal Act, 2001 and any other Act.
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Confidential Information
Any information that is of a personal nature to Town employees or clients or
information that is not available to the public and that, if disclosed, could result in loss
or damage to the Town, or could give the persons to whom it is disclosed an advantage.
FOI Requests
A written request by a person seeking access to records under Section 17 (1) of the Act
or, an individual seeking access to their own personal information un der Section 37 (1)
of the Act.
Head
The Clerk, as designated by a by-law enacted by Council.
Informal Requests
Written requests which do not require processes outlined in the Act.
Personal Information
Recorded information about an identifiable individual, including:
• Information relating to the race, national or ethnic origin, colour, religion, age, sex,
sexual orientation or martial or family status;
• Information relating to the education or the medical, psychiatric, psychological,
criminal or employment history;
• Information relating to financial transactions in which an individual has been
involved;
• Any identifying number, symbol or other particular assigned;
• The address, telephone number, fingerprints or blood type;
• The personal opinions or views of an individual except if they relate to another
individual;
• Correspondence sent to an institution by an individual that is implicitly or
explicitly of a private or confidential nature, and replies to that correspondence
that would reveal the contents of the original correspondence; and
• An individual’s name if it appears with other personal information relating to an
individual or where the disclosure of the name would reveal other personal
information.
“Personal Information” does not include information about i ndividuals acting in
their business or professional capacity such as their name, title, work address,
work telephone number or email address.
Redact
Concealing sensitive information prior to publication or release.
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Routine Disclosure
The automatic release of certain records identified in Appendix “A” in response to
requests made informally and not through FOI requests.
Third-party Information
Personal information of a person; or scientific, technical, commercial, financial, or
labour relations information supplied by someone other than the requestor or the Town.
Policy
This policy applies to any and all records created, maintained, managed and/or under
the custody and control of the Town, regardless of medium and/or format that the
record is contained in (i.e. paper, electronic, e-mail, microfiche, tape).
This policy also applies to any collection, use and / or disclosure of any personal
information by the Town.
This policy does not apply to records or information subject to any exemptions as per
the Act.
It is the Town’s responsibility to ensure that there is no unwarranted collection, use or
disclosure of personal information.
Key principles of the Act include:
• That the majority of information held by public institutions should be publicly
accessible.
• That only under specific limited circumstances, as described in the Act, should
information be withheld from the public.
• That all personal information, and otherwise confidential information held by
public institutions, should be protected from unwarranted disclosure.
• Those individuals who provide personal information to public institutions have a
right at any time to view and/or correct this information.
Records containing personal information will not be disclosed to anyone other than the
individual to whom the information pertains to, unless: the personal information is
redacted first; or its release is authorized by a policy, by-law or legislation.
Records listed in Appendix “A” will only be disclosed through this policy and will not be
released through an FOI request. The fees to be applied to records being released
through this policy are the same as those associated with FOI requests and are located
in the Fees and Charges By-law. There are several exceptions to the fees, also listed in
the Fees and Charges By-law.
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The following documents have fixed rates:
• Plot, Engineering Drawings
• Property Information Request
• Tax and Water/Wastewater Certificate
Documents being released without fixed rates will follow the rates Freedom of
Information (F.O.I.) or Routine Disclosure rates in the Fees and Charges By-law.
Responsibilities
Employees
• Shall be aware of and comply with this policy and any procedures with regard to
releasing of any records.
• Shall assist the public with informal requests for records.
• Shall consult with their supervisor/manager/director or the Clerk when there are
uncertainties about disclosure and/or dissemination.
• Shall ensure that all personal information is protected as per the Act.
• Shall notify their managers/supervisors immediately of any breach of privacy.
Management
• Ensure all employees are aware of this policy and that it is accessible in a
location easily accessed by employees.
• Shall assist the public with informal requests and active dissemination of
records.
• Shall consult with their director or the Clerk when there are uncertainties about
disclosure and/or dissemination.
• Shall ensure that personal information is protected and is not released outside of
the Act.
• Shall inform their director and the Clerk immediately of any breach of privacy.
• Apply progressive disciplinary action for breach of policy and the Act where
deemed necessary.
Directors and CAO
• Shall oversee the routine disclosure and active dissemination of records
associated with their departments.
• Shall ensure all divisions within their departments maintain compliance with
respect to privacy as set out in the Act, and ensure all personal information is
managed and protected.
• Shall consult wit h the Clerk when there are uncertainties about disclosure and/or
dissemination.
• Shall communicate to the Clerk if there has been a breach of privacy.
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• Shall apply appropriate progressive disciplinary action for breach of policy and
the Act where deemed necessary.
Town Clerk
• Shall administer all aspects of this policy and procedures to ensure the Act is
adhered to.
• Shall update appendixes and procedures as required.
• Shall monitor compliance with the policy and procedure.
• Shall decide whether to approve a wa iver of fees associated with access to any
records.
• Shall provide guidance as to the process to submit a formal FOI request.
• Shall ensure FOI’s are process as the delegated authority of the Head under the
Act.
• Shall provide notice to any affected person if their privacy was breached and will
ensure that a copy of the notice is attached to the file from where the original
records are housed according to the Classification and Retention By-law.
• Shall notify the Information and Privacy Commissioner’s (IPC) office of any
breach of personal information as per the Act.
Monitoring and Compliance
Non-compliance with this policy – whether intentional or deliberate – will constitute a
violation. Consequences of noncompliance can include informal follow-ups and
requests, external audits or formal direction on corrective measures.
References
• Confidentiality Policy
• Corporate use of Social Media by Employees Policy
• Records and Information Management Policy
Review Timeline
This policy will be reviewed 2 years after the initial approval date.
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Procedure for Routine Disclosure
Updated October 5, 2022
Steps
Routine Disclosure
1. Requests for Town records by the public will be accepted verbally, in writing, or
electronically.
2. The Town will review the request with the requestor and Appendix “A” will be
used to determine whether the requested records can be released through
routine disclosure.
• If the information or record being requested does not exist, no further action
will be taken.
• If the request cannot be processed through routine disclosure or active
dissemination, the request must go through the FOI process via the Clerk’s
office.
3. The Town will charge the requestor the appropriate fee as outline in the Fees and
Charges By-law and release the records to the requestor.
Active Dissemination
• Records identified in Appendix “B” that can be released through active
dissemination shall be released at the discretion of management or as required
by legislation.
• Records may be released through social media, physical or digital means as
required, or in accordance with best practices by the appropriate department.
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Appendix A
Record Series to be Released Through Routine Disclosure
• Access to Information & Personal Information Protection – Compliance Reports
• Air Photography
• Air Pollution & Control
• Building Permits*
• By-laws
• Classification & Retention By-law
• Committee of Adjustment (CoA)
• Committees Appointed – Meeting Management
• Committees Appointed – Meeting Management Council / Committee Audio &
Visual
• Council Agendas and Minutes
• Debt
• Drinking Water Quality Management System (DWQMS)
• Environmental Applications & Approvals
• Environmental Assessments
• Environmental Monitoring & Control
• Financial Information Return (FIR) & Municipal Performance Management
Program (MPMP) Reporting
• Financial Statements & Auditor’s Reports
• Fleet / Vehicle History & Maintenance Records for Fleet
• Hardware & Software Manuals / Instructions / Operating Procedures
• Heritage Resources
• Inactive Achievement / Recognition Awards
• Inactive Maps
• Inactive Media Coverage about the Town of Aurora
• Inactive Presentation & Speeches
• Inactive Recreation Pool Water Testing
• Inspections – Building*
• Job Descriptions
• Long Range Capital Plan Approved – Final
• Master Plans
• Municipal Election Administrative Records*
• Municipal Election Records – Campaign Finance
• Noise Pollution & Control
• OMB Decisions
• Organization Design
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• Pesticide / Herbicide Application
• Planning Applications*
• Policies, Procedures, Standards and Guidelines
• Property Reference File (Residential & Non-Residential)*
• Property Tax: Charity & Vacancy Rebates
• Road & Linear Asset Design Planning / Reconstruction
• Staff Reports to Council
• Strategic & Administrative Plans
• Street Names & Numbers
• Training Opportunities – External
• Transportation Studies
• Tree Inspections
• Utility Location Records
• Weather Monitoring
• Web / Social Media Analytics
• Weed Control
* Personal Information cannot be released unless it belongs to the person who has made the request and
photo identification has been checked.
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Appendix B
Record Series to be Released Through Active Dissemination
• Achievement / Recognition Awards
• Air Photography
• By-laws
• Cash Receipts1
• Committee of Adjustment (CoA)
• Committees Appointed – Meeting Management
• Council / Committee Audio & Visual
• Council Agendas and Minutes
• Election Records – Voters / Poll Lists2
• External Website Content Management
• Hazardous Materials
• Heritage Resources
• Job Descriptions
• Long Range Capital Plan – Approved – Final
• Maps
• Master Plans
• Media Coverage about the Town of Aurora
• Municipal Election Records – Campaign Finance
• Organization Design
• Pesticide / Herbicide Application
• Photographs – Town of Aurora Event3
• Presentations & Speeches
• Promotional, Publication Material & Information Packages Production &
Distribution
• Property Assessment Rolls4
• Property Tax Assessments, Levy Adjustments & Appeals3
• Public Notices
• Recreation Pool Water Testing
• Recreational Program Records3
• Staff Reports to Council5
• Strategic & Administrative Plans
• Street Names & Numbers
• Templates & Forms – Blanks
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1. These records are only to be released to the person that made a payment and can provide proof
of their transaction.
2. The Voters’ List is available per the Municipal Elections Act.
3. Personal information must be redacted and cannot be released.
4. These records m ay only be viewed at Town Hall and can not be photocopied or photographed .
5. Closed session staff reports cannot be released.