PRIVACY POLICY

ARABELLA VIDA ELECTION CAMPAIGN 2024

Use of Electoral Products and Voter Information

Scope of Policy

This policy applies to the election campaign for ARABELLA VIDA, INDEPENDENT candidate, for the byelection of Elections Ontario (Milton, Ontario riding) and any person or entity representing or working for this campaign on a paid or unpaid basis with regards to their possession and use of data provided by Elections Ontario in the form of the Permanent Register of Electors for Ontario (PREO) in both digital and physical forms.

Restrictions on Use

The use of PREO data is strictly limited to electoral purposes such as communicating with voters, soliciting campaign support, etc. The data may not be used for commercial or any other purposes.

The campaign's Chief Privacy Officer (CPO) will maintain a list to track the distribution of PREO list products and administer acknowledgement forms to ensure that all who use the data are aware of the restrictions of its use and their responsibility to ensure the secure handling of the data.

Privacy Requirements

Implementation and Enforcement of Privacy Controls

The following security measures ensure that all representatives of Arabella Vida's campaign remain in compliance with the privacy requirements in the Election Act. These measures include safeguards implemented to protect electors' personal information received in printed format and electronically.

 Administrative controls

Access to electors' personal information is only made available to the candidate's entities on a "need to know '' basis to individuals that have been judged by officials to be trustworthy and who have signed the appropriate Non-Disclosure Agreements (NDAs) and Written Acknowledgement. The independent candidate's CPO will oversee the administration of these privacy safeguards and is the person responsible for distributing PREO list products to the candidate's entities.

Technical controls

Any computer or other device used to access PREO list products are password-protected and store the list on encrypted volumes. Removable flash drives, etc. must also be encrypted.

Online campaign systems are password protected and make use of firewalls, SSL encryption, access logs and other industry-standard technologies to minimize the risk of unauthorized individuals accessing electors' personal information.

Physical controls

Computers or other devices used to store elector data are to be always kept in a secure (locked) location and only leave campaign workspaces when necessary. Removable flash drives, etc. when not in use are stored in a locked cabinet or similar secure location.

Disposal Protocol for List Products

Al paper copies of PREO list products will be destroyed via cross-cut shredding at the end of the electoral event. If a paper copy cannot be destroyed securely, it will be returned to Elections Ontario. Al digital copies will be securely destroyed immediately after integrating them into the candidate's database system either through securely wiping the storage media using software designed to erase every bit of data on a device or via physical destruction of the storage medium (i.e. fi stored on a DVD).

The CPO is responsible for collecting and tracking destruction certificates from those that had access to the PREO list products and submitting them to Elections Ontario by the stipulated deadlines.

Training on Privacy Controls

The candidate's staff receive training on the candidate's privacy controls and regulations to ensure awareness and compliance. Training is also made available to volunteers and is apart of the onboarding process for high-level volunteers who may have access to PREP list products in advance of an electoral event.

Breach Management

The candidate's online systems are password protected and make use of firewalls, SSL encryption, access logs and other industry-standard technologies to minimize the risk of unauthorized individuals accessing electors' personal information. User lists are regularly reviewed to ensure that access is restricted to those with proper authorization. Devices containing PREO list products are encrypted and only leave the candidate's workspaces when completely necessary. When not being used these devices are securely stored in a locked location.

In the event of actual or suspected unauthorized access, loss or theft of documents containing elector information, the CPO will work with the candidate's staff to address the situation quickly and thoroughly. Actions taken by the CPO will include notifying Elections Ontario of the breach and of actions being taken to mitigate it, contain the breach and identify its source, mitigate the harm resulting from the breach, fi possible retrieve any documents that were lost or stolen, document the circumstances that led to the incident, review and update policies, processes and procedures to prevent a recurrence, and contact the police or other relevant authorities.

Roles and Responsibilities

Arabella Vida's Chief Privacy Officer is responsible for safeguarding electors' personal information against accidental or unauthorized access and ensuring the secure disclosure, use, modification and disposal of PREO data, including complying with all filing requirements as set out by Elections Ontario. The CPO is also responsible for the overall implementation and enforcement of this privacy policy and ensuring that all who are given access to electors' personal information understand the importance of protecting it.

The candidate, employees, volunteers and other agents of Arabella Vida's campaign are responsible for the safe handling of PREO data to which they are given access. This includes abiding by the privacy best practices and rules set out by Elections Ontario, appropriately and securely storing all data, both in physical and digital forms in accordance with Elections Ontario requirements, reporting any breach or suspected breach to the CPO and ensuring the safe destruction of digital copies after integration of the data and of physical copies at the end of the electoral event.

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This PRIVACY POLICY IS EFFECTIVE as of APRIL 10,2024