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250-475-5555

770 Vernon Ave .

Victoria BC VBX 2W7

f. 250-475-5440
saanich.ca

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District of Saanich
Administration

ADMINISTRATION

April 2, 2015

Elizabeth Denham
Information and Privacy Commissioner
For BC
PO Box 9038
Stn Prov. Govt
Victoria, BC V8W 9A4
Dear Ms. Denham :

Re: Investigation Report F15-01

We acknowledge your thorough report concerning the use of employee monitoring software by
the District of Saanich.

District staff have had the opportunity to review your findings and accept that while aspects of
the Spector 360 software program meet the provisions of the Act, some of its elements were
found to be overly intrusive. In addition to assisting the District, your findings will provide policy
guidance for local governments to better understand their obligations with respect to IT security
measures and the need to strike a balance between security and privacy.

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My purpose in writing to you is also to express our concern about how you have chosen to
characterize the District in your March 30, 2015 media release and subsequent media
interviews with respect to its overall privacy management program. You have made the
following statement: "One of the most disappointing findings in my investigation is the District's
near-complete lack of awareness and understanding of the privacy provisions of B.C.'s
Freedom of Information and Protection of Privacy Act. The law has been in place for more than
20 years, yet the District appears to not understand its most basic privacy provisions."

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District staff have already acted on your first two recommendations. The Spector 360 software
was removed from all Saanich computers in January and with the conclusion of your
investigation our staff has now destroyed the data that was collected. We will also be
recommending that Council take action on the remaining three recommendations. Our policies
and employee communication practices will be updated and appropriate controls will be
implemented for IT administration access. Additional resources will be required to move
forward on the final recommendation and we anticipate receiving Council's support in this
regard. With additional resources, staff will be able to implement a more comprehensive privacy
management program, building on our existing processes, education and training .

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We believe your conclusions are only accurate to the limited number of interviews conducted
and the narrow scope of material reviewed for the Spector 360 software program investigation.
Our view on this was provided in our letter to you dated March 28, 2015.

Had we known that you were planning to make a broad statement about our entire program, we
would have recommended additional interviews and questioned why your staff declined an interview
with our Director of Legislative Services. We could have provided your staff with more basic
information such as the elements of our privacy management program, a copy of our information
and privacy manual, or the content of our staff training. We would have been pleased to provide
you examples of where staff has been or is working on privacy impact assessments, and how we
ensure the security of the private information we collect from our employees and our citizens. Your
statement has left many of our staff demoralized and our Council and citizens with questions about
their level of confidence in the programs we deliver.
We looked forward to your guidance on the Spector 360 software program and we readily take
responsibility for our actions. We recognize that due consideration to privacy issues may have
been lacking in this instance, however, that does not mean that we have or are ignoring the
legislation and our responsibilities under it. As is the case with every public body, we have
limited resources and we don't get it right every time.

You have a position of influence and while your intent may have been to link your statement only to
your limited-scope investigation, it has been interpreted in a much broader scope. I am hopeful you
may be able to provide some comment on our perspective.
Sincerely,

c(!l!l ~
Andy Laidlaw
Chief Administrative Officer

Mayor and Councillors

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