In response to recommendations made by the Information and Privacy Commissioner, Ontario, Canada (IPC) in Privacy Complaint Report MC16-4 dated March 15, 2018 the following updates are being made to the Student Photography process:
- Parents/Guardians shall have the ability to “opt-out” of receiving photograph packages of marketing/ ordering materials if they so choose.
- Parents/Guardians shall also have the ability to “request that the vendor destroy the information so long as it does not interfere with the Board’s administrative requirements”.
- The Photographer Download file from Trillium will no longer include the OEN in an effort to reduce the amount of personal information disclosed to the vendor.
For the first and second bullets, it being recommended that the vendors include this in their typical “Picture Day is Coming” flyers so parents/guardians will be aware of the ability to opt out of receiving marketing material and have their child/ward’s personal information securely destroyed/deleted from the vendor’s records in advance of the typical one-year destruction date as long as the Board’s administrative requirements have been met.
In addition, the Board has posted a Notice of Collection on its external website advising of the purpose of collection of information through the student photography process, and all photographers of record will be required to sign off on a new central service agreement that will tighten up data and privacy protection and secure destruction of personal information.
Notice of Collection: School Photography
Student photographs are collected under the authority sections 58.5(1), 170(1), 265(1), and 11(3) of Regulation 298 of the Education Act, R.S.O. 1990, c.E.2, as amended and retained in accordance with the Municipal Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. M. 56.
This information is used and disclosed for administration purposes which include: student safety, student identification, school security, office index cards, medical information reports and yearbooks. In addition, proof of photographs are made available for purchase.
If you have any questions about the collection of student photographs, please contact the office administrator at your local school.