HOW YOUR INFORMATION
IS HANDLED.
The Campaign collects only the personal information it needs for electoral purposes, and adopts these standards voluntarily to meet the privacy expectations of Brampton electors.
About this Policy
This Privacy Policy (“Policy”) describes how the official campaign of Prabh Gill for Mayor in the City of Brampton’s 2026 general municipal election (the “Campaign”) collects, uses, discloses, retains, disposes of, and safeguards personal information. The election is scheduled for Monday, October 26, 2026, and is administered by the City Clerk of the City of Brampton under the Municipal Elections Act, 1996 (“MEA”) and related provincial legislation.
The Campaign is not an “institution” under the Municipal Freedom of Information and Protection of Privacy Act (“MFIPPA”), and federal private-sector privacy law generally does not apply to municipal campaigning. The Campaign nonetheless adopts the standards in this Policy voluntarily, both to comply with the use restrictions imposed on the voters’ list and to meet the reasonable privacy expectations of Brampton electors.
Scope
This Policy applies to all personal information collected, used or disclosed by the Campaign, the candidate, any auditor or bookkeeper engaged by the campaign, its registered campaign workers, volunteers, contractors, and service providers (collectively, “Campaign Personnel”), in any of the following contexts:
- the Campaign’s website, social media accounts, online forms and email lists;
- door-to-door canvassing, telephone canvassing, text-message canvassing, and event sign-ins;
- use of the voters’ list provided by the City Clerk and any derivative canvassing data;
- processing of campaign contributions, contribution rebate program submissions, and volunteer onboarding; and
- records filed with, or retained for filing with, the City Clerk under the MEA.
Definitions
“Personal Information” means recorded information about an identifiable individual, including the categories listed in section 2(1) of MFIPPA.
“Voters’ List” means the preliminary or final list of 2026 electors for the City of Brampton provided to the Campaign by the City Clerk under the MEA, derived from the Permanent Register of Electors for Ontario.
“Campaign Personnel” has the meaning given in Section 2.
Personal Information the Campaign Collects
The Campaign collects only the Personal Information it needs for electoral purposes. Categories include, but are not limited to:
4.1 Information from the City Clerk
Name, residential address, and other information for individuals on the Voters’ List for the City of Brampton, as provided by the City Clerk.
4.2 Information collected directly from individuals
- Contact details (name, address, email, phone number) provided through, inter alia, sign-up forms (analog or digital), petitions, lawn-sign requests, event registrations, or in-person canvass conversations;
- Information obtained through social media, including individuals’ responses to Campaign social media communications;
- Voter-intent and issue-interest notes recorded by canvassers (i.e., “supportive,” “undecided,” priority issues), associated with a name or address;
- Volunteer information (skills, availability, contact information, etc.);
- Contribution information required by the MEA: full name, address, amount, and date of contribution, and, where applicable, information needed for any applicable municipal contribution rebate program;
- Photos, video and audio of public events where attendees have been notified that recording is taking place.
4.3 Information collected automatically
- Standard web-server log information (IP address, browser type, pages viewed, referrer) when individuals visit the Campaign’s website;
- Cookies and similar technologies, used to remember preferences and measure traffic. Individuals may decline non-essential cookies.
4.4 Information purchased from third-parties
Information purchased from market research firms, or any other vendor, which may contain Personal Information, including contact details (name, address, email, phone number).
4.5 Information in the possession of Campaign Personnel
Information in the possession of Campaign Personnel including, for example, knowledge and/or data gained through previous campaigns.
Purposes for which Personal Information is Used
The Campaign uses Personal Information only for electoral purposes, including:
- identifying and communicating with electors during the 2026 municipal election cycle;
- organizing canvassing, get-out-the-vote efforts, and election-day activities;
- soliciting and recording contributions and processing rebate-eligible contributions;
- recruiting, scheduling and supporting volunteers;
- testing and validating information technology tools, including email or text-messaging platforms and/or voter-contact database;
- preparing campaign communications, including advertising that complies with section 88.3 of the MEA;
- preparing and filing financial statements and supporting records required by the MEA; and
- responding to inquiries, complaints and access requests.
The Campaign does not use personal information for commercial purposes, and does not sell, lease or rent Personal Information.
Use of the Voters’ List
The Campaign treats the Voters’ List as confidential information subject to the use restrictions at subsections 23(7) – (8) of the MEA. Accordingly:
- Voters’ List data is used only for electoral purposes and never for commercial purposes;
- Access is limited to Campaign Personnel who need it to perform a specific election-related task and who have signed an acknowledgement consistent with subsection 23(8) of the MEA;
- Voters’ List data is not posted online, attached to public documents, sent to undisclosed recipients, or transferred outside Canada without the prior approval of the Chief Privacy Officer;
- All copies of the Voters’ List, and any data derived from it, are securely destroyed in accordance with Section 11 of this Policy.
Disclosure of Personal Information
The Campaign discloses Personal Information only:
- to Campaign Personnel who need it for an electoral purpose described in Section 5 of the Policy;
- to the City Clerk, where required by the MEA (for example, in financial statements, contribution records, and supporting documentation);
- to service providers (e.g., website hosts, email or text-messaging platforms, voter-contact databases, accounting and audit professionals) who are bound by written confidentiality and privacy commitments and use the information only on the Campaign’s instructions;
- with the individual’s consent; or
- where required or permitted by law (for example, in response to a court order or a lawful regulatory request).
Filed campaign-finance records, including the names and addresses of contributors of more than $25, become public records held by the City Clerk and are publicly disclosed as required by the MEA.
Electronic Communications
The Campaign sends electronic messages (email, SMS) only to individuals who have consented or whose contact information has been obtained for an electoral purpose described in Section 5.
Although Canada’s Anti-Spam Legislation does not generally apply to non-commercial political messaging, every Campaign electronic message identifies the Campaign, includes accurate sender information, and provides a working unsubscribe mechanism. The Campaign honours unsubscribe requests promptly.
The Campaign does not engage in deceptive or harassing communications and complies with applicable Criminal Code provisions.
Roles, Training and Safeguards
The Campaign voluntarily seeks to align its practices with Elections Ontario’s Guidelines for the Use of Electoral Products, including through appointing a Chief Privacy Officer (the “CPO”) who is responsible for:
- overseeing compliance with this Policy;
- maintaining a register of all copies of the Voters’ List in circulation;
- ensuring that every individual with access to the Voters’ List, or to any other personal information held by the Campaign, signs a written acknowledgement that they have read this Policy and understand the use restrictions;
- coordinating privacy training for Campaign Personnel;
- coordinating response to access requests, correction requests and complaints; and
- responding to privacy breaches.
The Campaign ensures administrative, technical and physical safeguards proportionate to the sensitivity of the personal information held, including:
- access controls and individual user accounts on Campaign systems;
- password-protection for laptops, mobile devices and removable media that contain Personal Information;
- secure passwords for accounts holding Personal Information;
- secure physical storage for paper records (canvass sheets, contribution forms);
- a written agreement with each service provider that handles personal information; and
- reasonable steps to keep personal information accurate and up to date.
Privacy Breach Response
If the Campaign discovers an actual or suspected unauthorized access, loss, theft or disclosure of personal information, the CPO shall endeavour to respond with steps generally consistent with the breach guidance from the Information and Privacy Commissioner of Ontario (IPC):
- immediately contain the breach and limit further access;
- investigate the cause and the categories and number of individuals affected;
- determine whether the breach poses a real risk of significant harm, and if applicable: notify affected individuals; engage Campaign legal counsel; notify the City Clerk; and notify the IPC if applicable and/or appropriate;
- document the incident and remediation steps and update Campaign practices to prevent recurrence.
Retention and Destruction
Personal information is retained only as long as necessary to fulfil the purposes for which it was collected, except where a longer retention period is required by law. In particular:
- Voters’ List data and canvass-derived data are securely destroyed no later than 30 days after the close of polls on October 26, 2026, unless required for a recount, compliance audit, or controverted-election proceeding;
- Campaign-finance records and supporting documentation are retained for the period required under the MEA — until the end of the 2026–2030 council term, currently November 14, 2030 — and then securely destroyed unless the City Clerk requires further retention;
- Volunteer records are destroyed within six months after the election, unless the volunteer has consented to longer retention for future political activity;
- Website log files are retained for no longer than 90 days.
Destruction is carried out by secure deletion (for electronic records) or cross-cut shredding or equivalent (for paper records).
Access and Correction
Individuals may request access to the Personal Information the Campaign holds about them, and may request correction of inaccurate information, by contacting the CPO using the details in Section 14. The Campaign will endeavour to respond within 30 days, subject to limited exceptions where disclosure is restricted by law (for example, where it would reveal the Personal Information of another person).
Requests for access to City of Brampton records about an individual that are held by the City Clerk, including the Voters’ List, should be made to the City under MFIPPA.
Individuals who have a concern about a response from the Campaign and/or the City Clerk’s handling of Personal Information in connection with the election, may contact the Information and Privacy Commissioner of Ontario.
Children and Minors
The Campaign does not knowingly collect personal information from individuals under 14 years of age except where a parent or guardian has consented (e.g., a youth volunteer program).
Contact and Complaints
Questions under this Policy may be directed to:
Chief Privacy Officer
Prabh Gill Campaign
Campaign Office: 2 Automatic Road, Unit 112, Brampton, ON, L6S 6K8
Phone: (905) 872-7000
Email: elect@prabhsgill.ca
Changes to this Policy
The Campaign may update this Policy to reflect changes in law, City of Brampton practice, or Campaign operations.
The current version, with its effective date, is published on the Campaign’s website.
NOTES
- Municipal Elections Act, 1996, S.O. 1996, c. 32, Sched. (the “MEA”). The City of Brampton administers the election under the MEA and the Municipal Act, 2001, S.O. 2001, c. 25.
- Election Act, R.S.O. 1990, c. E.6, ss. 17.1–17.6. Since January 1, 2024, Elections Ontario provides preliminary lists of electors derived from the Permanent Register of Electors for Ontario to municipalities for use in municipal elections.
- Municipal Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. M.56 (“MFIPPA”). MFIPPA applies to the City of Brampton and the City Clerk in their conduct of the election, but does not directly bind candidates or their campaigns.
- Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (“PIPEDA”). PIPEDA generally does not apply to municipal election campaigns because campaigning is not a “commercial activity” within the meaning of the Act.
- Election Act, s. 17.4.
- City of Brampton election information, accessed via brampton.ca; the voters’ list itself is a public document under the MEA, but candidates remain subject to use restrictions at ss. 23(7)–(8).
- MEA, s. 88.32 and s. 88.33; and the records-management practices of the City Clerk in respect of filed documents under MFIPPA.
- Canada’s Anti-Spam Legislation, S.C. 2010, c. 23 (“CASL”). CASL applies to commercial electronic messages, but the Campaign applies CASL-style consent, identification and unsubscribe practices to all its electronic communications as a matter of good practice.
- Elections Ontario, Guidelines for the Use of Electoral Products, Ontario Gazette, Vol. 156, Issue 50 (December 16, 2023), Appendix A (minimum criteria for privacy policies) and the requirement to designate a Chief Privacy Officer.
- See the Information and Privacy Commissioner of Ontario (“IPC”), Privacy Breach Protocol: Guidelines for Government Organizations (2019), and IPC, Privacy Breaches: Guidelines for Public Sector Organizations (2018).
- MEA, s. 88.34 (record retention by candidates); candidates must retain campaign records until the end of the council term (i.e., November 14, 2030 for the 2026–2030 term) or as otherwise required by the City Clerk.
- Contact information for the IPC: 2 Bloor Street East, Suite 1400, Toronto, Ontario, M4W 1A8; 1-800-387-0073; info@ipc.on.ca; ipc.on.ca.
CONTACT THE PRABH GILL CAMPAIGN
Chief Privacy Officer, Prabh Gill Campaign — 2 Automatic Road, Unit 112, Brampton, ON, L6S 6K8. Phone: (905) 872-7000. Email: elect@prabhsgill.ca