1.0  Accountability

The Toronto Transit Commission (“TTC”) is responsible for personal information under its control.  The Coordinator – Records Management/Freedom of Information, Commission Services Department for the TTC (“Coordinator”), 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 Statement/Guideline.

A request to TTC in accordance with MFIPPA shall be:

  1. in writing;
  2. made to the Toronto Transit Commission’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 the Act’s regulations for seeking access to a record (payable to the 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, pension, 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;
  • analyse business results;
  • process payments;
  • administer pension benefits;
  • issue travelling documents;
  • statistical and actuarial purposes;
  • auditing internal procedures; and
  • as required or as otherwise authorized 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 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 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 also give your implied consent to the TTC 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 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 your requests and to provide you benefits.

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 required 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 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 the MFIPPA and section 2.0 above.

7.0 Safeguards

All personal information collected by the TTC 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

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