Privacy Policy

The English version of this policy is the official version; translations are provided for convenience only.

Data Protection and Privacy Policy

Know Your Vote T.O. / Celebrate Democracy 2026

Version 2026-2

Project Data Collection Contact: Chris Ellis, Project Lead — info@knowyourvote.to

What is this?

This is the Data Protection and Privacy Policy for Know Your Vote T.O. / Celebrate Democracy 2026 (“the project”). It explains how the project team will collect, use, manage, and protect personal information gathered from users of knowyourvote.to and through the Celebrate Democracy programming.

The Know Your Vote T.O. / Celebrate Democracy project is generally consistent with TPL’s online privacy and access to information policy, available here.

New for 2026: This project now includes the Celebrate Democracy programming component alongside the Know Your Vote T.O. voter information website. When needed this policy has been updated to reflect this.

Who is MASS LBP?

MASS LBP is a small Canadian firm that works with government and public organizations to design and deliver engagement processes. Our mission is to ensure the involvement of regular people in developing policies and decisions that can affect their lives. MASS LBP also works with public institutions to develop programs and activities that support civic engagement and democratic participation.

MASS LBP has been commissioned to develop and deliver knowyourvote.to and the Celebrate Democracy programming on behalf of the Toronto Public Library.

Visit our website: www.masslbp.com

How will participant data and information be used?

All tools and services used to support this project are carefully chosen to protect users. The project team will ask for as little information as possible while still ensuring a good user experience and project success.

The project team has created ways for users to use the website without providing their email or physical address. For example, users can identify their municipal ward by clicking their location on a map, without entering any address information.

The project team will use users’ information for the following purposes only:

  1. To help users identify which municipal ward they live in so they can find the candidates running in their ward in the 2026 Toronto municipal election;
  2. To send users messages about Know Your Vote T.O. and Celebrate Democracy activities, candidate profile updates, and election information (with their express permission);
  3. To better understand website traffic and user activity so the project team can improve the user experience and promote the site more effectively; and
  4. To evaluate the success of the project and report aggregate findings to Toronto Public Library.

Note: Celebrate Democracy: Users who sign up for email updates may also receive information about Celebrate Democracy programming events at Toronto Public Library branches, including the Fiction Mayor youth civic engagement activity.

Note: Post-project email transition: At the conclusion of the project (December 2026), email subscribers will be offered a separate, optional invitation to sign up for Toronto Public Library’s own email updates. This is a voluntary, secondary step requiring fresh consent. The project’s subscriber list will not be automatically transferred to TPL.

Data Retention and Destruction

Email addresses and names: Permanently deleted by December 31, 2026.

Postal code / address (ward lookup): Not stored by MASS LBP. Transmitted temporarily to the mapping API only.

Non-public candidate contact information: Permanently deleted by December 31, 2026.

All service accounts and CRM data: Decommissioned (data deleted) by December 31, 2026.

Analytics data: Retained for 14 months per Google Analytics minimum retention, consistent with TPL’s existing policy.

Anonymous aggregate data (polling counters, KPI survey totals): May be retained beyond project end in aggregate/anonymized format for evaluation and reporting purposes only.

Project evaluation and reporting: Basic aggregate user trends and anonymized information will be used to report on the project’s success to Toronto Public Library.

MASS LBP will provide written confirmation of data deletion to Toronto Public Library upon completion.

The Project’s Data Protection Principles

  • Any personal information shared through the website is collected under the authority of the Public Libraries Act, sections 20(a) and (d), and in accordance with the provisions of the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).
  • All complaints and privacy inquiries will be responded to promptly and fairly;
  • Personal data will be obtained and used only for the purposes specified at the point of collection;
  • Data will be verified to be adequate, relevant, and limited to what is necessary for its identified purposes;
  • Data will be kept accurate, up-to-date, and fit for its intended purpose;
  • Data will not be kept for longer than is necessary and will be securely destroyed when appropriate;
  • The project team will take all necessary steps to implement appropriate technical and organizational measures to protect against unauthorized or unlawful processing of personal data and against accidental loss, destruction, or damage; and

Primary Data Collection: General Uses

User email address: Used to communicate with users who sign up for project email updates (opt-in only). Used as the primary contact for candidate profile notifications, Celebrate Democracy event invitations, election reminders, and the post-project TPL list invitation.

User name: Collected with email opt-in for personalization of communications. Not used for any other purpose.

Ward: Collected with email opt-in to enable ward-specific candidate profile and event communications. Not used for any other purpose.

Postal code / address (ward lookup): Transmitted temporarily to the mapping API to return the user’s ward. Not stored by the project team. Users may alternatively select their ward by clicking on a map, with no address information required.

Anonymous aggregate polling counters (Fiction Mayor / Celebrate Democracy): Aggregate counts of responses to the Fiction Mayor and other Celebrate Democracy polling activities. No individual responses are stored or linked to any user identity. Not personal information.

Website traffic / analytics data: Anonymized traffic and demographic data collected via Google Analytics. Used to understand usage patterns, measure outreach effectiveness, and support project evaluation. Opt-out information is provided in the site footer.

Candidate contact information: Name, email address, mailing address, phone number, organization, and profile status. Collected from publicly available municipal nomination forms at City Hall. Used solely to contact candidates about their profile submissions and to manage the candidate outreach process. Not disclosed outside the MASS LBP project team.

Breach of Data Protection Principles

The project team is responsible and accountable for the protection of users’ data.

  • If MASS LBP or TPL becomes aware of a suspected or actual data compromise or privacy breach, the project team will promptly (within 24 hrs) notify: TPL’s project lead; the Information and Privacy Commissioner of Ontario (www.ipc.on.ca); and affected users.
  • MASS LBP and TPL will track privacy complaints and user inquiries and use this information to amend project systems where relevant, and will monitor for trends that could indicate problems or compromises in systems.
  • Users may submit privacy complaints or inquiries to info@knowyourvote.to. Inquiries will be addressed within 10 business days. Unresolved complaints may be escalated to TPL’s Manager, Policy, Privacy and Records Management, or to the Ontario IPC.

Project Training and Review

  • All project team members will read, understand, and be trained on this policy prior to accessing any personal information;
  • Privacy and data protection obligations will be reviewed with project team members throughout the project; and
  • This policy will be reviewed and updated as needed through the course of the active project. The current version will always be available at knowyourvote.to.

Data Protection Best Practices

  • All collected personal information will be encrypted in transit (HTTPS/TLS) and at rest (AES-256 or equivalent);
  • Any personal information transported via email, USB, or online file sharing will be encrypted and password-protected. Once transported, the files will be deleted from the transfer medium;
  • Administrative access to all project systems requires multi-factor authentication (MFA); and
  • MASS LBP will never collect or store government identification or other highly sensitive data (such as driver’s licences, social insurance numbers, health care numbers, or library card numbers).

Data Location Policy

The following describes the systems and service providers used in this project that may handle personal information, along with their data location and relevant notes. Final vendor selections are pending confirmation prior to launch.

Website Hosting — AWS Canada (ca-central-1)

Purpose: Hosts website code and content database (Payload CMS). No personal information stored in the content database.

Data Location: Canada

Notes: Only website code and public candidate profiles are stored. No user personal information in the content database.

MongoDB — Canada (Montreal)

Purpose: Database service hosting website data —content and candidate profiles— for the Payload CMS-based website. No personal information stored in the content database.

Data Location: Canada (Montreal)

Notes: Only website code and public candidate profiles are stored. No user personal information in the content database.

Ward Lookup Mapping API — Mapbox

Purpose: Receives temporary transmission of postal code / address to return ward information to the user.

Data Location: USA

Notes: Address and IP data are transmitted during API lookup. IP data deleted within 30 days by the provider (some providers delete immediately after the call). No personal information stored. Users may alternatively use the map-click ward lookup with no address entry required.

Email / CRM Platform — Brevo / EU-hosted

Purpose: Stores opt-in subscriber records (name, email, ward) and manages candidate outreach CRM data.

Data Location: European Union

Notes: Must be Canadian-hosted or EU-hosted (GDPR). US-based storage of identifiable personal information is avoided. Contractual data protection terms required. Vendor to be confirmed prior to launch.

Analytics Platform — Google Analytics

Purpose: Collects anonymized website traffic and demographic data for program evaluation.

Data Location: USA

Notes: Data is anonymized per Google Analytics settings. No individually identifiable records retained. Consistent with TPL’s existing Google Analytics policy. Opt-out information provided in site footer. Canadian-hosted alternative under evaluation.

Corporate Services (email, general work materials storage, etc.) — Google Workspace

Purpose: Password-protected online hosting used for short-term storage of non-sensitive MASS LBP operational and project management information.

Data Location: Canada / USA

Notes: No user personal information stored here. Project management and internal communications only.

MASS LBP Office (408 Ontario Street, Toronto)

Purpose: Physical location for secure storage of any paper records.

Data Location: Canada

Notes: Protected by an alarm system. Sensitive data stored in a locked fire safe. Paper records printed only when immediately needed and shredded on-site using a cross-cut DIN P-4 shredder. Shredding materials mixed before disposal.

Staff Computers

Purpose: Project team member computers used for day-to-day project work.

Data Location: Canada

Notes: Sensitive data stored in AES-256 encrypted partitions, opened only when required and closed when not in use.

Zero Sharing of Personal Information with Third Parties

  • All personal information is collected solely for the purposes of this project as described in this policy;
  • Aggregate, de-personalized information is reported to Toronto Public Library for project evaluation purposes; and,
  • No personal data is shared, sold, rented, or transferred to any third party outside of the service provider relationships described in the Data Location table above.

Your Rights

Users have the following rights with respect to their personal information held by this project:

Unsubscribe from emails: You can unsubscribe from project email communications at any time using the unsubscribe link in any email, or by contacting the project team at info@knowyourvote.to

Request access to your personal information: You may request access to the personal information we hold about you by contacting info@knowyourvote.to. We will respond within the timeframe required by MFIPPA s. 36. Formal MFIPPA access requests may also be directed to Toronto Public Library’s Manager, Policy, Privacy and Records Management.

Request correction of your personal information: You may request that inaccurate personal information be corrected by contacting info@knowyourvote.to.

Request deletion of your personal information: You may request deletion of your personal information at any time before December 31, 2026, by contacting info@knowyourvote.to. All personal information will be permanently deleted by December 31, 2026 regardless.

Use the website without providing personal information: You can find your ward using the map-click tool without entering any address information. You can browse candidate profiles and Celebrate Democracy content without signing up for email updates.

Opt out of analytics tracking: Information about how to opt out of Google Analytics can be found here: https://support.google.com/analytics/answer/181881?hl=en

Note: Given that all personal information will be permanently deleted by December 31, 2026, access or correction requests received after that date cannot be fulfilled for individual records.

Version 2026-2 | Know Your Vote T.O. / Celebrate Democracy | Toronto Public Library & MASS LBP

[This document may be translated into other languages using automated tools (such as Google Translate) for accessibility and convenience. These translations are provided as a courtesy and may not be exact. The English version is the official and authoritative text and shall govern in the event of any discrepancy or conflict.][Ce document peut être traduit dans d'autres langues à l'aide d'outils automatisés (comme Google Traduction) à des fins d'accessibilité et de commodité. Ces traductions sont fournies à titre de courtoisie et peuvent ne pas être exactes. La version anglaise constitue le texte officiel et faisant autorité et prévaudra en cas de divergence ou de conflit.]