1. Update: Privacy Issues
Karyn Hogan Region of Peel
MWA Fall Workshop 2016

2. Outline Background Electronics Used Tires Conclusions
MWA Fall Workshop 2016

3. Background IFO contracts: Municipal concerns:
Source documentation re: obligated materials
Municipal concerns:
Privacy
Operations
MWA Fall Workshop 2016

4. Electronics
IFO contracts (i.e. Generator Standard) & program requirements re: Processor Incentive Program:
Contracts with Processors, not municipalities
Processors did not communicate update in timely manner for municipalities to comply/discuss with Councils
Generator Standard:
Site requirements
Source documentation
Issue:
Exclusions for municipalities (ECAs)
Sept 1st deadline (extension) + payments
MWA Fall Workshop 2016

5. Electronics
Processors intimated that existing documentation was not adequate and that Generators would be required to collect personal information from each resident delivering electronics to municipal depots
Privacy concerns (releasing personal information to third parties)
Operational concerns (queues due to length of time to gather personal information and release + impacts on customer satisfaction)
Issue: contractual component + obligated materials (OES) Non-Ontario WEEE + Best Practices
MWA Fall Workshop 2016

6. Electronics Letter to WDO Aug. 23rd Meeting @ WDO Sept. 27th OES:
Draft and circulate language to be added to the Generator Standard to clarify the documentation municipalities are expected to provide the program to support their claims
MWA Fall Workshop 2016

7. Conclusion: Electronics
With respect to Municipalities, existing ECA and residency requirements are sufficient to validate the material is Ontario sourced and collection of personal information is not required. 
For the submission of claims for all generators, including Municipalities, OES will continue to require scale tickets to validate weights for bulk collected material.  Scale tickets must be from the originating site or any third party scale if the originating sites does not have a scale.
Draft language, approved by WDO
Nov. 30 deadline for municipalities to sign
MWA Fall Workshop 2016

8. Requirements of Registered Collectors:
Used Tires
Requirements of Registered Collectors:
Name, telephone number, quantities & types of tires, date
Municipal concerns:
Privacy concerns (releasing personal information to third parties)
Operational concerns (queues due to length of time to gather personal information and release + impacts on customer satisfaction)
Requirements since 2014 – muni objections
Purpose: fraud prevention
License plate numbers – not req’d, collected by municipalities
MWA Fall Workshop 2016

9. Used Tires Letter to WDO Aug. 23rd Meeting @ WDO Sept. 27th OTS:
Number of tires collected by municipalities: unreasonable, unaccountable
Municipalities forego incentive payment + free pick up (no log)
OTS inconsistent re: muni collection + payments (current) + present claims on hold + sudden enforcement of clause
No variation in municipally collected tonnes
MWA Fall Workshop 2016

10. Used Tires Municipalities:
Collect information on which sites have weigh scales
OTS:
Provide information on amount being withheld
Provide list of municipalities with questionable variances/potential over-reporting
Outcome from Sept. 27th WDO
MWA Fall Workshop 2016

11. Letter to OTS Chair Oct. 12th
Used Tires
Letter to OTS Chair Oct. 12th
No specifics re: fraud at municipal sites to date
Privacy contraventions (MFIPPA), i.e. remove
Potential methods to address OTS concerns
Payment to municipalities
Municipal Legal Counsel: collecting information is a contravention of the Municipal Freedom of Information and Protection of Privacy Act
Potential methods:
Reconciliation of scale tickets or unit counts between municipal collection sites & OTS haulers contracts
Durham Region: Pilot
Payment:
MWA Fall Workshop 2016

12. Letter from OTS Chair Oct. 19th
Used Tires
Letter from OTS Chair Oct. 19th
Collection network
Environmental benefits
Accuracy of claims
Municipalities continue to work with OTS via Executive Director
Collection network: tire sales, garages, etc. vs. municipalities
EBs: illegal dumping reduced
AofC: fraud prevention
MWA Fall Workshop 2016

13. Conclusion: Used Tires
Nothing confirmed to date re:
Pilot
Municipal information re: claims
Next meeting
MWA Fall Workshop 2016

14. Questions? Karyn Hogan karyn.hogan@peelregion.ca
ext. 4379
MWA Fall Workshop 2016