As you know, the ACA and AAO have both submitted comments to Ontario's
Ministry of Consumer and Business Services regarding the draft privacy
legislation.  This is to let everyone know that the Archives of Ontario has
not been silent on the matter, but being part of Government, our input is
necessarily of a different nature than that of a national or provincial
organization.

Unlike the federal _Personal Information Protection and Electronic Documents
Act_ which does not apply to the private holdings of the National Archives
of Canada, the provincial legislation is intended to apply to our private
manuscripts.  We have had discussions with the Ministry, and have provided
written comments to them as well.  Our concerns are similar, but not
identical to the ACA's and AAO's.  We have asked for provision for research
agreements (as provided by the counterpart access and privacy legislation
for government records); reduction of time exemptions; explicit permission
to allow transfer of personal information, not just personal health
information, to the Archives of Ontario and other archives; and refinement
of the section on destruction of records to alert organizations to the
potential long-term value of their records.

*************************************************
Carolyn Heald
Team Leader, Policy and Planning
Archives of Ontario
77 Grenville Street, 3rd floor
Toronto, Ontario  M5S 1B3

Phone: (416)327-1539
Fax:  (416)327-1992
e-mail:  [log in to unmask]
website:  http://www.archives.gov.on.ca