The District of Houston presented a new Privacy Management Program (PVP) at its Dec. 3, 2024 regular council meeting.
The program marks the introduction of a structured approach to privacy management within Houston, as it was designed to fulfill requirements of the Freedom of Information and Protection of Privacy Act (FOIPPA), and establishes a framework to protect personal information and ensure compliance with privacy laws in all District operations.
The province first provided direction to public bodies on Feb. 1, 2023 to develop a PMP, and Houston staff have been drawing upon practices from other local governments to shape their own program and streamline its implementation.
The main goal of the PMP is to ensure that public bodies are accountable and transparent in their management of personal information. Public bodies are required to have a fully documented process for responding to privacy complaints and breaches, and must include a process for completing and documenting Privacy Impact Assessments (PIA) and Information Sharing Agreements (ISA).
The PMP initiative is comprehensive, as it was designed to align the District with FOIPPA requirements, while also promoting accountability and transparency. There are five key areas that the program focuses on: policies and procedures, training and awareness, PIAs and ISAs, informing service providers of their privacy obligations, and ongoing monitoring and updates.
Tailored privacy training for staff ensures they understand how to handle personal information appropriately and prevent breaches. Training will be provided during the onboarding process and will be refreshed and updated periodically.
Integrating privacy protections into third-party service provider contracts ensures that all contractors handling personal information meet the same privacy standards as the District, which reduces risks associated with outsourcing and reinforcing accountability.
Using PIAs and ISAs provides a detailed approach to managing privacy risks in new and modified projects, and these tools help ensure compliance with FOIPPA.
The PMP represents an adaptable approach to privacy management and ensures that the District is well-positioned to address any privacy challenges.