Angry in the Great White North

The website WorkingFamilies.ca is a website designed to help the Dalton McGuinty's Liberals win in Ontario in the upcoming election.

That is not really in doubt, based on a June 15 column in the Toronto Star:

In the 2003 provincial election campaign, the most effective television ads were not sponsored by any of the political parties.

Rather, they were the "Not this time, Ernie" ads featuring unflattering photos of then-premier Ernie Eves, which were paid for by a coalition of unions calling themselves "working families."

The ads not only tore a strip off Eves; they also allowed Dalton McGuinty and the Liberals to take the high road with a positive campaign, in the knowledge that the dirty work was being done for them by the coalition.

Now we are in a new election cycle, with the vote scheduled for Oct. 10, and the working families coalition is re-forming. It is expected to get the go- ahead at a meeting next week.

Among the participating unions are the building trades, teachers, and Canadian Auto Workers (CAW). The firefighters have also been approached but have not committed to joining the coalition.

All have reasons to be thankful to the governing Liberals for either increasing spending in their area or changing laws and regulations to their liking.

To help pull together the working family ads, the coalition has hired Arrow Communications, which is headed by Marcel Wieder, a Liberal party insider. The coalition is also talking to Pollara, a market research firm, about doing some polling. Pollara's CEO is Don Guy, the Liberals' campaign director.

But the ads will be designed to educate the public on the issues, said Dillon. "We won't be telling anybody they should vote this way or that way."

Nor did the "Not this time, Ernie" ads in 2003. But the underlying message was clear: dump the Conservative government of the day.

Clearly the site has an agenda, and clearly they are trying to influence the election.

Well, guess what? There's nothing wrong with that.

Unless there is a direct link to the Liberal Party...then there would be a problem.

Is there such a link? I don't know of one (clearly there are some shared resources, like Pollara, but that is a step away from saying the Liberals are running WorkingFamilies.ca). But here is something that makes me nervous. Check out the privacy policy:

Consent:
Working Families will not collect or use personal information without first obtaining appropriate consent.

I notice that "share" is not on the list, just "collect" and "use". Maybe sharing is the same as using legally, but I doubt it. Legal statements are always explicit and list every possible variation in order to avoid ambiguity. If sharing is not explicitly prohibited, then it is not prohibited, in my view.

So I went ahead and registered, providing my name, my year of birth, and my blogging address, as requested. Nothing on the registration page said anything about consent. When I hit "Submit", I got this message:

Thanks for registering with us. Stay tuned for more details.

In my email box came the class "Click this link to activate" confirmation, which I clicked, and which took me to the WorkingFamilies.ca home page, instead of a landing page for new registrants explaining what the rewards of registration were.

Poor design, in my view. Worse than that, nothing appeared in the registration process that discussed what the information might be used for.

Back to the privacy policy:

Working Families will retain and store personal information in secure fashion, and will restrict its access to only those authorized persons who require the information for approved purposes. Working Families has taken measures to ensure the security of personal information by limiting access to personal information, by ensuring reasonable security of physical premises, and by adopting security systems to preserve the integrity of electronic information databases.

Authorized persons? Who exactly?

Approved purposes? What purposes are those?

Nothing on the site enumerates exactly what is approved and who is authorized. Moreover, nothing in the privacy policy explicitly excludes third-parties as potentially being authorized to see the information. The only mention of third parties is to say the data won't be sold to third parties after the election:

Where personal information is no longer required, Working Families will permanently dispose of the personal information so it does not come to the attention of third parties (for instance, by shredding paper documents and/or deleting electronic document files).

Can an authorized person be the Ontario Liberal Party communications group? The privacy policy doesn't even explain how someone can become authorized and who evaluates a purpose to determine if it is worthy of approval.

Would someone whose purpose is to defeat the Progressive Conservatives win approval from WorkingFamilies.ca and so gain access to the data?

Who answers these questions?

Questions or concerns regarding the protection of personal information should be directed to the Personal Information Administrator, and should be made in writing setting out sufficient information to permit her to investigate and respond. The Administrator will respond to questions or concerns in writing within fourteen days (14) days.

No mailing address is provided for the Personal Information Administrator. In fact, the only contact information for the entire site is the "Contact Us" link which is an email link to info@workingfamilies.ca. I can't find a mailing address anywhere on the WorkingFamilies.ca site to which to send a written complaint for the Personal Information Administrator to investigate.

So if I had an issue with regards to my personal information, and wanted to contact the Personal Information Administrator in writing as required by the privacy policy, I'd be in a bind.

The average visitor would be stuck at this point. I know how to look at the registration information, but that doesn't help. The address provided at 65 International Boulevard in Etobicoke is for the Provincial Building and Construction Trades Council of Ontario, presumably of the unions behind the site (though this particular organization does not appear on the sponsors list). Would a letter addressed to the Personal Information Administrator sent to this address reach the right person? Would I be told if it did or did not? Or would I wait two or three weeks, and then determine that the resounding silence was evidence that this was not the right address.

Who knows?

And given the cheek-to-jowl relationship between WorkingFamilies.ca and the Ontario Liberal Party, I think a tighter privacy policy and a very explicit and limited list of authorized persons and approved purposes would be a very good idea.

In the mean time, I've sent an email to the contact address asking for a mailing address. I'll let you know what I find out.