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Privacy Law Changes Loom for London - 07 Oct 26
London · October 08, 2026
Good morning. Uh, I've just been advised
that Chair Pelosa uh will be running
late, approximately 10 minutes. Uh, we
do have 30 minutes within the council
procedure bylaw within which to start
the committee meeting. Uh from my
understanding she'll be here uh within
that time. I'll provide any updates uh
should I receive any
good morning. I don't know if you heard
my uh recent announcement regarding Sher
Poza. Um but she is uh running late. Uh
so we will resume as uh or start uh once
she uh gets here. I understand it'll be
approximately 10 minutes.
>> Thank you.
Okay, good every good every that's not
even a sentence. Good afternoon
everyone. Apologies for the delay. This
is the fourth meeting of the audit
committee. The city of London is
situated on the traditional lands of the
Najbeck, Horeson, Lapawok, and
Adawandrin. We honor and respect the
history, languages, and culture of the
diverse indigenous people who call this
territory home. The city of London is
currently home to many First Nation
matey and Inuit today. As
representatives of the people of the
city of London, we are grateful to have
the opportunity to work and live in this
territory. I am joined in chambers by
members of committee being councelor
Cuddi and councelor Pribble. Member
Chima is online and member Stevenson um
has sent her regrets. The city of London
is committed to making every effort to
provide alternate formats of
communication supports for meetings upon
request. To make requests specific to
this meeting, please contact
accessibility at London.ca or
519661-2489
extension2425.
I now look to the committee for
disclosures of pecunary interest. I see
none in chambers. I see none online. We
have no consent items, no scheduled
items. Items for direction we have
three. Item 4.1 is the summary update in
internal audit from MNP.
This is going to be a motion to receive
the report.
Moved by councelor Pribble, seconded by
councelor Cuddy. Um our presenters are
in person today, so turning it over to
them if they would like to give a brief
introduction, then I'll open it up to
questions uh from the floor and online.
And if there's anyone online as well as
part of your presentation, just let me
know. We can certainly go to them as
well. Thank you, Mr. Roco.
>> Thank you through you, Madam Chair. Um,
in front is the in front of you is the
summary update. The only thing I would
just like to take this opportunity to is
as I recognize that this is the um last
meeting in which internal audit will be
presenting to this committee given this
term of council. Just wanted to thank um
the committee uh for its support
throughout our tenure here. Uh and
looking forward to continuing um to
provide um this with the uh uh this this
relationship with the city. Uh and just
best of luck to each of the members in
your future works. Thank you.
>> Thank you. Looking to members of the
committee are online for questions. This
is just the uh summary update. Seeing
none, it would be a vote by hand of all
in favors of receipt.
Motion carries.
>> Thank you. That takes us on to item 4.2
being the internal audit follow-up
activities dashboard also from MNP. This
would also be a motion to receive.
Looking for a mover and councelor Cuddy
seconder and councelor Pribble
as well. Uh turning this over to MNP for
your update.
>> Uh thank you through you madam chair. Um
so of note uh for the committee with
regards to the dashboard within this
previous cycle um there were no
management actions that were were
closed. There are 19 actions that we are
still tracking. As a reminder to the
committee we track items from previous
audits through to their target
completion when they are rated to be of
a high or medium risk. Um so management
based upon our engagement with
management and review of progress uh
continues to uh work on items per their
targeted completion dates and based upon
the updates that we have uh sought from
them. Those targeted completion dates
are still set to be uh still set to be
possible. So there has been no
retargeting during this last cycle.
Thank you.
>> Thank you. Looking online or in chambers
for questions regarding the
activities dashboard.
I will start my speakers list with
councelor privile. Thank you sir chair
to our staff on page six the 0.1 and
point 2 both of them uh update from the
staff that review prior will be done
prior to the next multi-year budget 28
to31 if I look at due date Q4 2027 could
you please be more specific if it's
going to be same process as 4 years ago
then the budget cases they were done in
kind of August September and I just want
to make sure that even though it says
quarter for 2027 that there's going to
be sufficient time to introduce it prior
to the council.
>> Thank you. I'll turn over to our team
recognizing at that point there'll also
be a new term of council and um so Miss
Barbone
>> I can uh pass that over to Cheryl Smith
because the actual response refers to
the um policy work as opposed to the
budget. So Miss Smith will be able to
answer
Thank you and for the chair. As part of
this review, it identified some
opportunities that we had to refine the
community lending community grants
policy. So that policy will come to
council probably in Q2 2027 as we need
the policy finalized. our call for
multi-year funding then opens up the uh
the Q3 or the summer of 2027 and then
any council decisions with respect to
funding of that policy and funding of
the London community grants program will
be part of the next multi-year budget
process but the policy uh to allow us to
continue the community grants program
will come forward in Q2 2027 and the
changes as recommended by the audit will
be incorporated into that policy.
Thank you, councelor Pville.
>> Thank you. And I would imagine that's
for both one and two answer. Correct. I
see not. Thank you very much. No more
questions.
>> Thank you. Looking for further speakers
online or in person.
Okay.
Seeing none, um by a show of hands, all
in favor of receipt.
>> Motion carries.
>> Thank you. This brings us on to item 4.3
being the City of London internal audit
privacy audit. Um I believe MNP has a
specialist online as well for this one.
Uh I'll preface this one uh and we'll
let MNP do it as well that it's a
preparedness audit. Uh and you'll see in
your package a big focus on bill 97 and
where we're at in meeting um regulations
and what's expected ahead. This is also
going to be for receipt. So a receipt to
get it on the floor moved by councelor
Cuddy. seconded by councelor Perbble and
I will turn over to Mr. Rako and your
team to introduce this item for us.
>> Uh thank you uh through you madam chair.
Um and as was already just kind of
highlighted with your preface there. Um
before you is a privacy audit that was
completed during this last cycle. It is
a timely audit and it's viewed as a
little bit of a readiness assessment
that we were able to do um given uh
changes that are pending or actually
changes that have taken place and will
become effective to the uh municipal
freedom of information act um which is
bill 97 as was referenced. Um so with
regards to this an important thing that
hopefully came through within the report
but just as a preface is that when we
look at these the recommendations and
the findings that we have are thinking
towards the effectiveness date that will
be January 1st 2027. Um so this is a
slight departure as you were reading the
report potentially of as management was
putting together their targets for
completion. We usually as would have
seen in the dashboard give a quarter
right quarter 2026 quarter 2027 in order
to complete it but given the um given
the target of effectiveness of January
1st 2027 um management actually gave
very specific dates for effectiveness
which so it's a slight departure in
process but I think an important one
considering the purpose of this audit.
Um the other thing I would just like to
highlight is that uh when you when you
look towards this um within the findings
there were um six findings in total. One
being ranked as a high risk, one being a
medium risk and one being a low risk. If
you look towards those two more uh
material items which are uh the high and
the medium, what they are really focused
on is enhancements that are needed from
the current processes and controls that
are in place within the city's privacy
regime that help to ensure that come
January 1st, 2027, um you will be in
line with the with the recommend uh with
the requirements. Um it there is an
appendix that has uh we included in in
appendix C that highlights the
legislative updates really what a big
departure on this and I I do have
Adriana from u from the firm uh online
to answer any specific questions but in
summary that the update to the act is
much more prescriptive in the things
that a municipality and other local
governments have to do when it comes to
the protection of privacy. Um so while
they were leading practices before in
come January 1st it is much more
prescriptive in the privacy impact
assessments that need to done and it is
much more prescriptive in the
maintenance of an inventory of personal
information and that's what those two
recommend uh those two risk areas and
recommendations look to address. Uh so
thank you.
>> Thank you. Uh so as noted, Adriana's
online as well uh for questions from MNP
uh should we require that starting my
speakers list with councelor Pribble and
then if member Chima has anything as
well a hand will indicate they're on the
speakers list next. So for now I'll
commence with councelor Pribble.
>> Thank you and the chair to our staff. Uh
on page 26 uh the observation number one
the bottom management response states
training will be provided to service
areas etc. Can you please tell me how
long this training will pro about take
and when it will be starting
to staff uh Mr. Sheltus.
>> Thank you. Through the chair. Uh we'll
be providing training documents uh in
December of this year. Uh inerson and um
virtual sessions will begin uh in the
early in the year and they're going to
be continuous. They're going to be
ongoing uh training much like our other
training uh throughout that that area
provided for incoming staff. And then
who it's going to be provided to. We
have a number of service areas that have
identified leads uh for records and
MIFIPA uh pieces that typically deal
with this type of information. That's
who the training would be aimed for.
>> Councelor PL.
>> Okay. Thank you for that. On the
following page, it says target Q1 2027
in place by January 2027. So I just want
to make sure that the other points even
though we have this target, but it says
in place January 1st. So am I is my
understanding correct that it will be
done actually by January 1st
>> Mr. Schultz?
>> Yes there's wording there where it
speaks to an MNP tracking and that's
what Mr. Rocker was talking about the Q1
but you'll note in the brackets in place
by January 1st 2027 that's what the
legislation speaks to is a coming into
force state. So those pieces the
legislative required pieces will be in
place by that date. Councelor Pval,
>> thank you for that. On page 28,
management response at the bottom bullet
point, actively working on creating a
corporatewide view. Does this view
include the five bullet points in
recommendation by MNP?
>> Mr. Schultz,
>> thank you through the chair. Yes,
>> councelor Privile.
>> That was a quick answer.
Uh, now question to MNP on page 30. your
two recommendations, how will they fully
address the observations on the next
page? Because when I read throughout the
document your recommendations, they
address three observations. This one, I
wasn't really sure. If you can please
clarify that.
>> Can you answer that, Mr. Reco?
>> Uh through you, Madam Chair, and thank
you for the question. Uh and it's a it's
an interesting one when you take a look
at it. So what that um item is
particularly looking at is the um the
the city has um information that is
contained in several different systems
in in uh hard copy, soft copy, so on so
forth. Uh what this was looking at
particularly is that there is that
limited oversight, centralized
oversight, right? When we do not have
things particularly within SharePoint.
Uh and that's what that was that was
looking towards understanding and
appreciating that the city is already
doing several things to look towards
better consolidation putting things
within SharePoint which is a system that
allows for better management and
tracking of this information. Um
understanding that that is still
something that the city will work
towards. Um what we wanted to highlight
within the recommendations is that while
that good work still needs to continue
there are other things that we can do.
Can we take a riskbased approach even
while that SharePoint progression is
taking place, but can we take a
risk-based approach to understand where
the high-risisk areas are that maybe
need to be prioritized a little bit
more? And then as to management's
comments with regards to training,
continue with training and awareness to
folks that even though we're continuing
that migration towards SharePoint, this
has to we have to be mindful of this
that it's outside of that system. So I
would love to um say to you towards the
question that you know we can snap our
fingers and move everything towards a
centralized repository system such as
SharePoint but we wanted to put these
recommendations forward recognizing that
that good work is still continuing. In
the meantime, we need to make sure that
we're taking a risk-based approach to
compliance and continuing with ongoing
dialogue with risk owners, right, that
own this information or that oversee
this information to continue to be
mindful of it until we get to that place
on the hill where SharePoint manages
everything.
>> Approval.
>> Okay, thank you for that answer. And I
have last question which I actually
would like to it's going to I will
address it to our staff but I would like
a feedback from MNP as well. uh on page
32 uh the observation for 90 95% of
their time processing access requests
and we have Adobe Acrobat platform uh
Camtasia Excel programming
it doesn't seem to me efficient
effective and very open to errors which
was included actually in the report
target Q3 2027
why so long and continue this way till
that time could this time frame be
shortened And so we actually get on the
better, more effective, more efficient
path.
>> Mr. Schultz,
>> thank you through the chair. So on page
32, uh the middle of the page, it uh
speaks to the 95% of the time processing
and the processing part of it is more
than a simple workflow of an intake of a
document or request. There's uh
redactions that are required. And you'll
note that one of the uh platforms we use
is Camtasia. That is for video uh
redaction. Uh for the Adobe Acrobat,
that would be for other types of
redactions. Typically, the workflow or
FOI systems that um we're aware of, uh
they deal with workflows for managing
the the timing of uh intakes, uh trigger
points. Uh we already have a robust uh
system for that. Um but we are certainly
uh uh as we've indicated in our response
going to be looking at that software
which there is a cost to um to um either
supplement or replace our existing
workflow. But on the other pieces of
processing related to redaction or video
pieces which are part of their their uh
work um that's something that we would u
not want to be relying entirely on
technology. For example, we would not
want to rely entirely on AI assisted
reduction without a human uh check on
that. Uh we take that very seriously the
redactions and the protection of
privacy. Uh so we would want staff to be
looking at that and that may speak to
the efficiency part of it. So we want to
make sure that we get this right and
that's why the timing is the Q3. There's
a cost component, there's an integration
with our uh systems and currently what
we're doing works and we know that it
works. Could there be an efficiency
perhaps? But we would need to review
that after looking at the FOI software.
Thank you.
>> Council approval.
>> Okay, I'll just leave it. Oh, actually
do you I I did want to get because MMP
is this was actually from their
observations. So if you can comment on
that including the timeline Q3 2027.
>> Mr. Reco.
>> Uh thank you through the chair. I'll
actually so I would be speaking out of
turn with regards to this one. I would
just ask my colleague Adriana who this
is her world uh so she heads up the
firm's privacy uh practice so I would
just ask her Adriana do you have any
comments on uh councelor Pribble's uh
question
>> sure uh thank you for the question uh
just to answer that um uh that question
regarding our view so as uh as we uh
completed the assessment uh we we
concluded that the activities are
happening so this is something that will
be an enhancement to the to the
processes and uh uh what we notice when
this legislation is implemented usually
this type of requests increase in
number. So uh the the reason for looking
into having products that can um make it
more efficient is to ensure that there
is um there there is enough time to to
address these requests in the future.
But we recognize that the processes that
are in place today are working properly.
>> Thank you councelor Pville.
Just a followup if I can get a
confirmation that if we already know
certain details regarding what's going
to come in 1 of January 2027,
do we currently fulfill the requirements
the way we are doing it now or would it
make more sense to speed up and
to speed up the IT part? Should we start
new year already on the new platform?
>> Okay, I'll start with Mr. Schultz and
then Adrienne can certainly add in
anything.
>> Thank you through the chair. So, uh, uh,
as indicated by MNP, this would be an
enhancement. So, the question as I
understand it is legislative compliance.
We would be legislatively compliant by
January 1st, 2027 as is.
>> Adriana, a comment on that? Yeah, I I
concur. The the processes today meet the
legislative requirement.
>> Thank you, councelor Privile.
>> No more questions, just a comment. If
there's always an opportunity to do it
potentially sooner, I think it's better
if there is a enhancement in plants
anyways. So, if there's an opportunity
to do it earlier, I think it would be
beneficial. Thank you.
>> Thank you. I do have a question but
looking to other members of the
committee first in chambers or online
with Mr. Chima.
Okay. Um if you allow me to ask direct
from the chair just realizing this
report outlines uh staff timelines um
for training resources and some
potential technology investment.
Does staff have access to those things
in that monetary potential monetary
budget at their disposal to fully
implement what they deem required?
>> Thank you uh madam chair. So for the FOI
software uh we are aware that there's a
cost. We have not got precise uh
quotations or costing uh from uh FOI
software specialist specialty uh
providers. uh we don't anticipate that
it would be exorbitant but there will be
a cost so hopeful that we can uh manage
that within our existing budget envelope
as far as uh staff components and uh uh
the comment by M&P that likely there
will be or there potentially could be an
increase in in work uh we're already
experiencing that as are many
municipalities across the province in a
growing number of MIP requests and
growing complexity of those MIPER
requests We are trying to manage as best
as we can uh within existing budgets to
uh provide staff levels that can
accommodate increased workflows but
should there be an additional
requirement obviously we would need to
go through the appropriate processes to
request uh additional budget.
>> Thank you. as uh
bill 97 uh comes into effect, if you
could just remind me, did the government
allow any funding to municipalities to
help with the costs of increased
technology and uh staff increased
workflow?
>> Madam Chair, not that I'm aware of.
>> Thank you. I'm sure if something comes
available uh council be informed at the
earliest opportunity as we absorb uh
these cost pressures as well. Looking to
committee for further questions or
comments as this is a move to receipt. I
see nothing online. I see nothing in
chambers. A show of hands of all in
favor of receipt of 4.3.
>> Motion carried.
>> Thank you. Deferred matters and
additional business. I'm not aware of
any. So just looking quickly to
community and online. Seeing none, I
will concur that this is our last
meeting of the audit committee um for
this term of council. The next scheduled
date for the audit committee is December
9th for the new term.
The advertisement for the chartered
accountant position on the audit
committee has been posted and is open
until November 4th for anyone who would
like to apply. And I want to just take
this opportunity to also extend
gratitude to member Chima for serving uh
for this entire term of council with us
again and the knowledge and the
questions that he's brought to the
table. So thank you for that.
We have no confidential items that would
leave us with adjournment. I have a
mover and councelor Cuddy a seconder and
councelor Pribble. This would be a show
of hands and thank you to MNP uh and all
those who supported this committee
throughout this term.
You've made it to the end and a show of
hands of a German of this meeting.
>> Motion carried.
>> Thank you everyone and I wish you a
wonderful and productive day.