New MFIPPA duties start January 1, 2027. Accept a quote by November 30 for delivery by December 21.

The Bill 97 Readiness Pack

Ten documents for January 1, written around your institution

The pack gives a municipality or local board what it needs for the duties that start on January 1, 2027: a way to do privacy impact assessments and one finished assessment, a breach response you can run under pressure, a record of your safeguards, and short briefings for council or your board and for staff. We prepare it from your own forms, notices and practices. A certified privacy professional checks every judgment call. Your head reviews it, changes what they want and signs.

Who does what

Who does what in the pack
TaskWho
Prepare every document from your forms, notices, policies and questionnaire answersMaple Privacy Desk
Check every judgment call before the pack reaches youA certified privacy professional, under a written confidentiality agreement
Confirm the legal authority you cite for each collectionYour solicitor or clerk
Review, change what you want, and signYour head, or the head’s written delegate
Report a breach to the IPC and notify people, when the test is metYour head. We never contact the IPC for you.

The head is council, unless it has named a member or committee by by-law, or for a local board its members, unless they have named one of themselves in writing (MFIPPA s. 3). The head may delegate in writing (s. 49(1)).

Document 1

Privacy impact assessment policy

A short policy your head adopts, so everyone knows when an assessment is needed and how it moves from draft to signature.

The law behind it
MFIPPA s. 28(3), (5) and (6); s. 49(1) for delegation
Who signs
Your head, or the head’s written delegate, adopts it

What it contains

  • When an assessment is needed: before any new collection, and before any significant change to the purpose for which information is used or disclosed. Following the IPC, also when practices change in ways that could increase harm, such as a new platform, a new purpose or a new retention period.
  • A first check of whether a project involves personal information at all, with the conclusion recorded either way, as the IPC recommends.
  • Roles: who leads the project, who prepares the assessment, who reviews it (someone other than the preparer, as the IPC recommends), and who signs.
  • How risks that will not be fully mitigated are accepted, by whom, and how that is recorded.
  • Where signed assessments are kept, and how a request from the IPC for a copy is logged and answered.
  • A review cycle: we suggest at least once a year and after any breach that touches the project.
  • A list of your ongoing collections, ordered so the riskiest are assessed first.

Document 2

Privacy impact assessment template

The template your staff use for every future assessment. It follows the four steps in the IPC’s Planning for Success guide (August 2026), and its core is one section for each of the ten items the Act lists. Each part shows, with a label, what the Act requires, what the IPC recommends, and what we suggest.

The law behind it
MFIPPA s. 28(3) to (6), s. 28(2), s. 29, s. 30, s. 31 and s. 32
Who signs
Each completed assessment: your head or delegate, after a review by someone other than the preparer

What it contains

  • Step 1 check: does the project involve personal information, whose, and the recorded conclusion.
  • Part A, project details: title, department, project lead, assessment lead, version, start date, what is in and out of scope.
  • Part B, project analysis: the team, a checklist of key features (a service provider, storage outside Ontario, cameras or location data, online forms, linked databases, sharing with others) and an information flow table: how each type of information is collected, used, kept, secured, disclosed and disposed of.
  • Part C, the ten required elements: purpose and necessity; legal authority under s. 28(2), s. 31 and s. 32; types and uses; sources and the notice of collection wording; position titles with access; limits; retention under Reg. 823, s. 5; safeguards, with the risks to people using the harms listed in s. 30.1(10); steps to prevent and to mitigate; anything prescribed.
  • Part D, risk table: what could go wrong, who is affected, likelihood, harm, priority and the step that addresses it.
  • Part E, mitigation plan: each step with an owner, whether it is in place before collection, and if not, why and by when, as s. 28(4) requires.
  • Part F, sign-off: prepared by, privacy review, project lead, and the head or delegate with the delegation reference, plus any risks accepted without mitigation.
  • Part G, copies to the IPC: a log of every request under s. 28(6).
  • Part H, review schedule: versions, changes and the next review date.

Items a regulation may set are marked, so your staff know to check for new regulations before relying on them.

Document 3

Your first completed assessment

The template filled in for one real collection you choose, so your staff have a finished example to copy and your riskiest collection is covered first.

The law behind it
MFIPPA s. 28(3) and (4)
Who signs
Your head or delegate. Your solicitor or clerk confirms the legal authority line.

Common first choices

  • Municipalities: online recreation or camp registration, which often collects children’s health notes through an outside booking service.
  • Library boards: library card registration, or a room booking or program system run by a vendor.
  • Police service boards: a camera system, or an online reporting or request form.
  • School boards: a registration form, or an education app that can see student information.
  • Conservation authorities: permit applications, or camp and education program registration.
  • Boards of health: a program or course registration outside personal health information.

What we prepare it from

The forms, the system or vendor it runs on, who can see the information, how long it is kept, the vendor contract terms you have, and the legal authority you rely on. We record the authority you cite; we do not conclude whether a collection is lawful. That line is for your solicitor or clerk.

Document 4

Breach response protocol

Who does what in the first hours and days after a suspected breach, set out so a clerk can follow it on a bad day.

The law behind it
MFIPPA s. 30.1; the IPC’s breach guidelines (August 2026)
Who signs
Your head or delegate adopts it

What it contains

  • A roles table with position titles and backups: the breach lead, the head or delegate who determines that a breach occurred and decides the test, the IT lead or provider, and a communications or legal adviser.
  • The IPC’s six steps in order: assess and contain; assess the real risk of significant harm; notify the people affected; report to the IPC; investigate; reduce the risk of future breaches.
  • Containment checklists: getting information back or destroyed with written assurance that no copies were kept, changing passwords, pausing a system or a staff member’s access.
  • Internal targets, which are our suggestion and not legal deadlines: the breach lead and head told the same business day; the decision recorded within 2 business days; any report and notice aimed for within 5 business days of the head’s determination.
  • Who else to consider telling, as the IPC suggests: police, regulators, technology suppliers and the Canadian Centre for Cyber Security.
  • A yearly tabletop exercise, so the protocol is practised before it is needed.

Document 5

Real risk of significant harm decision guide and decision record

The Act’s test turned into a short decision path, with prompts for each legal factor and a form that records the decision and the reasons.

The law behind it
MFIPPA s. 30.1(1), (3), (7) and (10)
Who signs
Each decision record: the head or delegate who made the decision

What it contains

  • A seven-step path: was personal information involved; was it stolen, lost, or used or disclosed without authority while in your custody or control; contain now; work through the factors; decide; check other laws and contracts; record and sign.
  • Worked prompts for sensitivity, probability of misuse and the steps people could take, drawn from the IPC’s guidelines, plus a check of IPC guidance and any prescribed factor.
  • Two illustrations, clearly marked as examples and not rulings.
  • A decision record with about twenty fields: when the breach was found and when the head determined it occurred, what happened (without repeating the personal information), the people and groups affected, containment, the findings on each factor, the decision and reasons, and the dates of any report and notice.
  • A note to assess separately any group in the same incident that faces a different risk.

Document 6

Notice templates

Draft wording for the two things the Act requires when the test is met, so nobody writes them from a blank page under pressure.

The law behind it
MFIPPA s. 30.1(2) and (4); the IPC FAQ and breach guidelines
Who signs
Your head or delegate sends each one

What it contains

  • Report to the IPC: the fields the IPC’s online form asked for on October 13, 2026, including what happened, when and how it was found, the information involved, the number of people, containment, notification, and investigation steps done and planned, with a reminder not to include the personal information itself.
  • Notice to the people affected: the statement that they can complain to the IPC, as the Act requires, plus what the IPC expects: what happened and when, the information involved, what you are doing, steps people can take, a contact at your institution, how to complain and the one-year limit.
  • Direct or indirect notice: the situations in which the IPC’s guidelines say indirect notice, such as a prominent website notice, may be used, and how to make it likely to reach the people affected.

Document 7

Breach log

One record of every incident, with a column for the ones reported to the IPC, set up in the categories the IPC counts so the yearly report takes minutes.

The law behind it
MFIPPA s. 30.1(8) and (9); s. 26(2)(c.1)
Who keeps it
The breach lead named in your protocol

What it contains

  • Columns for the date found, the head’s determination, category and sub-type, the number of people and their band, whether the test was met, report and notice dates, status, and a link to the decision record.
  • The categories and bands the IPC used on October 13, 2026: stolen, lost, used without authority or disclosed without authority, each with sub-types; people affected in bands of 1, 2 to 10, 11 to 50, 51 to 100 and over 100.
  • A note that only breaches reported under s. 30.1(1) go in the yearly count, while every incident is still recorded.

Document 8

Safeguards policy and register

A short policy statement your head can adopt and a register of 23 common safeguards, each with an owner by position title, a status, the evidence that it works and review dates. Regulation 823 already asks for measures to be “defined, documented and put in place”; the register is one way to show the documented part.

The law behind it
MFIPPA s. 30(5), s. 4.1, s. 30(1) and (4); Reg. 823, ss. 2, 3 and 5
Who signs
Your head or delegate adopts the policy; each row has an owner

The policy in eight points

Purpose, scope (all formats, including spoken information and information a service provider holds for you), need to know, documented measures, accountability, staff duties, service provider terms, and review.

The 23 starter safeguards

Starter register: you add your own rows and fill in owner, status and evidence
IDSafeguardBasis
A-01Privacy lead named; head’s duties delegated in writing where neededs. 49(1); IPC guidelines 6.1
A-02Privacy and security training at hiring and yearly, including phishingIPC guidelines 6.1
A-03Confidentiality undertaking signed yearly; disciplinary measures statedIPC guidelines 6.1
A-04Access by role on a need-to-know basis; removed on departure or role changeReg. 823, s. 3(2)
A-05Personal information inventory kept currentIPC guidelines 6.1
A-06Retention schedule applied; disposal recorded without personal informations. 30(1), (4); Reg. 823, s. 5
A-07Breach response protocol with a contact list, practised yearlyIPC guidelines
A-08Service provider contracts with privacy terms and a duty to report breaches immediatelyIPC guidelines 3 and 6.1
A-09Assessment before any new collection; update before a significant change of purposes. 28(3), (5)
A-10Identity check before releasing a person’s own informationReg. 823, s. 2(1), (3)
T-01Multi-factor sign-in on email, remote access and systems with personal informationIPC guidelines 6.1
T-02Updates applied promptly; unsupported systems retiredIPC guidelines 6.1
T-03Encryption on laptops, phones and portable storageIPC guidelines 6.1
T-04Endpoint protection and regular vulnerability scansIPC guidelines 6.1
T-05Backups with tested restores, one copy kept separateIPC guidelines 6.1; Reg. 823, s. 3(3)
T-06Access logging, with periodic review of who viewed recordsIPC guidelines 6.1; PIA guide
T-07Safer sending: check recipients, secure links, no personal information in subject linesOur suggestion
P-01Locked cabinets or rooms for paper records; keys and codes controlledReg. 823, s. 3(1)
P-02Clean desk and screen lock; counter screens out of public viewOur suggestion
P-03Secure shredding with certificates; devices wiped or destroyedPIA guide, Appendix C
P-04Restricted access to server, network and records roomsReg. 823, s. 3(1)
P-05Records storage protected from fire, water and pestsReg. 823, s. 3(3); s. 4.1
P-06Rules for taking records or devices off siteOur suggestion

The register feeds element 8 of every assessment, which lists the register IDs that apply, and step 5 of the breach protocol, which uses it as the checklist when you investigate what failed.

Document 9

Personal information inventory

One list of what your institution collects and where it goes. It is the starting point for every assessment and the first thing you need when something goes wrong.

The law behind it
MFIPPA s. 28(3), s. 30(1); the IPC’s breach guidelines, section 6.1
Who keeps it
Your privacy lead, with each department

What it contains

  • Each collection: forms, programs, cameras and systems, online and on paper.
  • For each: the department that owns it, where the information is kept, who can see it, how long it is kept under your retention by-law, and which outside service holds it.
  • Whether an assessment exists, and the order in which the rest should be done.

Document 10

Council or board briefing, and a staff briefing

Two short documents so the people who need to know, know.

Council or board
One page: what changed on January 1, what your institution has done, and what council or the board needs to know, such as who the head is and which duties are delegated.
Staff
A short note for front-line staff: what a breach looks like, to tell the breach lead at once and not try to fix it alone, and the everyday habits that prevent the common ones.

Look inside the pack

The opening page of three core documents, as they stand today. In the pack, each is completed for your institution.

  • Privacy impact assessment

    Privacy impact assessment template

    Template, draft v0.1, October 2026. Not legal advice.

    About this template

    From January 1, 2027, Ontario’s Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) requires municipal institutions to prepare a written privacy impact assessment (PIA) before collecting personal information (section 28(3)). This template helps a municipality, school board, police service board, library board or other MFIPPA institution do that without in-house privacy staff. It is built around the four steps in the Information and Privacy Commissioner of Ontario’s guide, Planning for Success (August 2026): preliminary analysis, project analysis, privacy analysis and PIA report. At its core is one section for each of the ten items the Act says an assessment must contain, with plain questions to answer under each.

    Full document in the pack

  • Breach decision guide

    Real risk of significant harm decision guide

    Template, draft v0.1, October 2026. Not legal advice.

    About this guide

    From January 1, 2027, the head of every Ontario municipal institution must report certain privacy breaches to the Information and Privacy Commissioner of Ontario (IPC) and notify the people affected, under section 30.1 of MFIPPA. The test is whether it is reasonable in the circumstances to believe there is a real risk of significant harm, often shortened to RROSH. This guide turns that test into a short decision path a clerk can follow under pressure, built around the six response steps in the IPC’s Privacy Breaches: Guidelines for Public Sector Organizations (August 2026).

    Full document in the pack

  • Safeguards

    Safeguards policy summary and register

    Template, draft v0.1, October 2026. Not legal advice.

    About this register

    From January 1, 2027, section 30(5) of MFIPPA requires the head of every municipal institution to take reasonable steps to protect personal information against theft, loss and unauthorized use or disclosure, and to protect records against unauthorized copying, modification or disposal. Older security rules in Regulation 823 already require documented measures against unauthorized access and damage, and access limited to staff who need a record for their duties. This register gives a small institution one place to show what it does.

    Full document in the pack

What you get

  • All ten documents, written for your institution, in editable files you keep and own once paid for.
  • A review by a certified privacy professional of every judgment call, before the pack reaches you.
  • Corrections at no charge if you tell us within 10 business days of delivery that anything is wrong or missing.
  • A free fix if the IPC finds a document we prepared is missing content the Act requires, for a reason inside our scope.
  • Updates at no charge if a regulation changes what the documents must say before we deliver.

What is not included

  • Legal opinions, including whether a statute authorizes a collection.
  • Signing, adopting or filing anything for you.
  • Contacting the IPC for you, then or later.
  • Technical testing of your systems. The register records the safeguards you have; it does not test them.
  • PHIPA documents for personal health information. See boards of health.

Start with a free check, or ask for a quote

Email your institution’s name to:

We reply within 2 business days. Please do not send personal information about residents or staff. We do not need it.

What to put in your email

  • Your institution’s name.
  • Your name and role, so we know who the check or quote is for.

That is all we need. We find your public forms and privacy pages ourselves.