Unlawful

Municipal Freedom of Information and Protection of Privacy Act

Personal information bank index
34 (1) A head shall make available for inspection by the public an index of all personal information banks

Ensure accuracy
(2) The head shall ensure that the index is amended as required to ensure its accuracy. R.S.O. 1990, c. M.56, s. 34.

Inconsistent use or disclosure
35 (1) A head shall attach or link to personal information in a personal information bank,
(a) a record of any use of that personal information for a purpose other than a purpose described in clause 34 (1) (d); and
(b) a record of any disclosure of that personal information to a person other than a person described in clause 34 (1) (e).

Idem
(2) A record of use or disclosure under subsection (1) forms part of the personal information to which it is attached or linked. R.S.O. 1990, c. M.56, s. 35.

SOUTH GLENGARRY CLERK

I can confirm to you that no such link or attachment exists, as the Township does not currently maintain PIB Indexes within the meaning of the Act.

Regards,
Kelli Campeau

Attorney General Ian Scott stated to the standing committee reviewing the bill that lead to the enactment of the Freedom of Information and Protection of Privacy Act:
So there are three standards and, unless you can meet one of those, any collection of personal information is unlawful . . . One of the critical features of this act is that it says, unless you meet one of these three tests, it is unlawful even to collect it.

UNLAWFUL as in OFFENCE (FIPPA s. 61, s. 62 / MFIPPA s. 48, s. 49)