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Appendices
Appendix NCampaign, Private Interest and Municipal Conflict Firewall
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In this chapter
- N.1 Purpose
- N.2 It Applies To
- N.3 It Is Not a Declaration That Conflict Exists in Every Case
- N.4 It Is a System for Determining
- N.5 Statutory Conflict
- N.6 Broader Governance Conflict
- N.7 Appearance of Conflict
- N.8 But Appearance Can Damage
- N.9 Therefore
- N.10 The Three-System Rule
- N.11 Campaign System
- N.12 Private System
- N.13 Municipal System
- N.14 Information Should Not Flow Freely Across Those Boundaries
- N.15 Money Should Not Flow Freely Across Them
- N.16 Staff Should Not Flow Freely Across Them During Work Time
- N.17 Intellectual Property Should Not Flow Across Them Without
- N.18 Public Power Should Never Flow Into Private Advantage
- N.19 Legal Baseline
- N.20 Municipal Conflict of Interest Act
- N.21 This Is Particularly Important Under Strong-Mayor Powers
- N.22 Owen Sound and Strong-Mayor Powers
- N.23 Election-Period Limits
- N.24 Therefore
- N.25 Integrity Commissioner
- N.26 Provincial Accountability Changes
- N.27 Therefore
- N.28 Do Not Build Firewall Around Soon-to-Be-Obsolete Law
- N.29 Current City Code
- N.30 Election Resources
- N.31 Owen Sound Current Election Policy
- N.32 This Appendix Does Not Replace That Policy
- N.33 Legal Advice
- N.34 Do Not Ask Political Staff to Interpret Conflict Law
- N.35 The Firewall Principle
- N.36 This Can Include Removal From
- N.37 Exact Requirements
- N.38 Independent Process
- N.39 Trigger
- N.40 Conflict Firewall Trigger
- N.41 Ownership Percentage
- N.42 Minority Holding
- N.43 Non-Equity Interest
- N.44 Royalty
- N.45 Licence
- N.46 Trademark
- N.47 Domain
- N.48 Future Sale Value
- N.49 Reputation
- N.50 Public Interest Disclosure
- N.51 This Is Proposed Governance Standard
- N.52 Public Disclosure Should Focus On Interests Reasonably Relevant to Municipal Decision-Making
- N.53 Possible Categories
- N.54 Do Not Publish
- N.55 Transparency Should Be Relevant
- N.56 Update
- N.57 Annual Confirmation
- N.58 Clerk / Integrity Review
- N.59 Public Record
- N.60 map.ca
- N.61 RealMap
- N.62 Other Founder-Associated Technology
- N.63 Private Real-Estate Interests
- N.64 Ordinary Profession
- N.65 Broad Class Effects
- N.66 Do Not Over-Recuse
- N.67 Do Not Under-Recuse
- N.68 Recusal Is Not Punishment
- N.69 Disclosure Is First Step
- N.70 Candidate-to-Office Transition
- N.71 Campaign Does Not Become City Department
- N.72 Campaign Staff
- N.73 Campaign Volunteer
- N.74 Donor
- N.75 Endorser
- N.76 Political Opponent
- N.77 Transition Inventory
- N.78 Campaign Laptop
- N.79 City Laptop
- N.80 Private Business Laptop
- N.81 Do Not Merge Drives
- N.82 Campaign Email Account
- N.83 City Email Account
- N.84 Private Business Email
- N.85 No Automatic Forwarding
- N.86 Resident Sends Campaign Idea
- N.87 Municipal Adoption
- N.88 Campaign Contact Consent
- N.89 Municipal Resident Service Contact
- N.90 Campaign Data Separation
- N.91 City Data Separation
- N.92 Private Data Separation
- N.93 Likewise
- N.94 No Informal Database Merge
- N.95 "But It Would Help Residents"
- N.96 Public Purpose
- N.97 Legal Authority
- N.98 Privacy
- N.99 Procurement / Agreement
- N.100 Data Firewall
- N.101 Staff Firewall
- N.102 Not Mayor Personally
- N.103 Not Campaign
- N.104 Not Mayor's Private Company
- N.105 Staff Direction
- N.106 Private Business Request
- N.107 Example
- N.108 Nor
- N.109 Nor
- N.110 Nor
- N.111 Obvious
- N.112 Staff Protection Standard
- N.113 Without Retaliation
- N.114 Escalation
- N.115 Appropriate Route Depends On
- N.116 No Staff Forced to Confront Mayor Alone
- N.117 Written Direction
- N.118 Strong-Mayor Direction
- N.119 Firewall Standard
- N.120 If Conflict Confirmed
- N.121 If Uncertain
- N.122 Staff Should Not Be Penalized for Delay Required by Conflict Review
- N.123 No Performance Review Retaliation
- N.124 No Schedule Retaliation
- N.125 No Promotion Retaliation
- N.126 No Public Shaming
- N.127 Staff Independence
- N.128 Political Authority
- N.129 Procurement Firewall
- N.130 Independent Procurement Owner
- N.131 Possible Owner
- N.132 Procurement Policy
- N.133 Same Rules
- N.134 Also
- N.135 Same Defensible Standard
- N.136 Equality of Process
- N.137 Founder Knowledge
- N.138 That Knowledge Can Be Useful to Public Policy
- N.139 Public Standard
- N.140 Mayor should not direct:
- N.141 Policy Objective
- N.142 Supplier Selection
- N.143 Separation Is Key
- N.144 Open Standard
- N.145 Then Market Can Respond
- N.146 If Related Platform Wins Fairly
- N.147 But
- N.148 No Presumption
- N.149 Sole Source
- N.150 "Only My Company Can Do It"
- N.151 No Self-Certification
- N.152 Prototype
- N.153 Prototype Does Not Prove
- N.154 Independent Business Case
- N.155 Independent Valuation
- N.156 Valuation Should Consider
- N.157 Development Cost Alone
- N.158 Founder Time
- N.159 Future Potential
- N.160 Public Ownership
- N.161 map.ca Proposal
- N.162 That Principle Should Be Enforced Through Independent Process
- N.163 Public Ownership Means
- N.164 Not
- N.165 Ownership Questions
- N.166 Licence
- N.167 Assignment
- N.168 Open Licence
- N.169 Nonprofit Ownership
- N.170 Municipal Ownership
- N.171 Private Ownership
- N.172 Model Chosen By
- N.173 Not Founder Preference Alone
- N.174 Founder Windfall Test
- N.175 If Yes
- N.176 Even If City Pays Nothing
- N.177 Free Municipal Adoption Can Create Private Value Through
- N.178 Therefore
- N.179 No Promotional Testimonial
- N.180 Municipal Logo
- N.181 Case Study
- N.182 No "Official City Partner"
- N.183 RealMap Firewall
- N.184 Examples
- N.185 Then Ask
- N.186 If RealMap Vanishes
- N.187 Sign Transition
- N.188 No Sign Rule Designed to Force RealMap Usage
- N.189 No RealMap Requirement
- N.190 No RealMap-Linked Permit
- N.191 No RealMap-Linked Municipal Ranking
- N.192 No Municipal Data Feed Reserved Exclusively for RealMap Without Defensible Public Basis
- N.193 Open Data
- N.194 Private Platform Can Use Open Data
- N.195 No Private API Privilege
- N.196 map.ca Firewall
- N.197 Mayor May State Vision
- N.198 Mayor Should Not Determine
- N.199 Independent Architecture Review
- N.200 Independent Privacy Review
- N.201 Independent Cybersecurity Review
- N.202 Accessibility Review
- N.203 Procurement Review
- N.204 Legal Review
- N.205 Financial Review
- N.206 No One Reviewer Selected Solely by Founder
- N.207 Reviewer Independence
- N.208 Reviewer Conflict
- N.209 Review Scope
- N.210 Findings
- N.211 Negative Findings
- N.212 Founder Rebuttal
- N.213 Founder Does Not Approve Final Report
- N.214 Municipal Technology Pilot
- N.215 Pilot Does Not Equal Procurement Award
- N.216 Pilot Does Not Equal Endorsement
- N.217 Pilot Does Not Equal Transfer of Ownership
- N.218 Pilot Result
- N.219 Private Intellectual Property
- N.220 But
- N.221 Municipal IP
- N.222 Current Owen Sound Code
- N.223 New Idea Created in Office
- N.224 Therefore
- N.225 Mayor Sketches Private Invention on Weekend
- N.226 City Employees Develop It During Paid Work
- N.227 City Funds Development
- N.228 Joint Development
- N.229 Do Not Resolve Later From Memory
- N.230 IP Development Notice
- N.231 Pre-Existing IP
- N.232 Otherwise
- N.233 Git Repository
- N.234 Design Files
- N.235 Data Schema
- N.236 Domain
- N.237 Brand
- N.238 Training Materials
- N.239 City-Funded Improvements
- N.240 Public Money
- N.241 Commercialization Rights
- N.242 Revenue Share
- N.243 Open Source
- N.244 Public Domain
- N.245 Municipal Licence
- N.246 Private Retention
- N.247 Founder Royalty
- N.248 Do Not Negotiate Own Royalty With City
- N.249 Independent Negotiation
- N.250 Public Value
- N.251 Private Business Time
- N.252 Mayor Is Not Hourly Employee
- N.253 Therefore "Hours" Are Not Perfect Boundary
- N.254 Municipal Role
- N.255 Private Role
- N.256 Mixed Meeting
- N.257 If Mixed
- N.258 Example
- N.259 Better
- N.260 No Municipal Introduction as Private Sales Leverage
- N.261 Public Office Network
- N.262 Private Business Can Exist
- N.263 Business Card
- N.264 Municipal Email
- N.265 City Letterhead
- N.266 Mayor Title
- N.267 Biography
- N.268 But
- N.269 "Mayor of Owen Sound recommends..."
- N.270 Private Company Website
- N.271 City Website
- N.272 Neutral Public Directory
- N.273 If map.ca / RealMap Appears in Neutral Directory
- N.274 No Featured Placement Because Founder Is Mayor
- N.275 No Exclusion of Competitor
- N.276 Communications Firewall
- N.277 Campaign Communications
- N.278 Private Communications
- N.279 Separate Branding
- N.280 Owen Sound's current election-resource policy prohibits candidate use of City branding, City-funded web properties, City email and voicemail, corporate IT and data, City communications staff and City-created photo or video for campaign purposes.
- N.281 Extend the Principle Beyond Election Day
- N.282 Mayor Update
- N.283 Mayor Update Should Not Say
- N.284 Public Policy Discussion
- N.285 Founder Product
- N.286 Press Conference
- N.287 City Video
- N.288 City Photographer
- N.289 City Social Media
- N.290 Campaign Can Share City Post
- N.291 But City Should Not tailor post to:
- N.292 Official Mayor Social Account
- N.293 Personal Political Account
- N.294 Campaign Account
- N.295 Do Not Quietly Convert Campaign Account Into Official City Account
- N.296 Followers
- N.297 City Account
- N.298 Passwords
- N.299 Account Survives Mayor
- N.300 Official Website
- N.301 Mayor Domain
- N.302 City Domain
- N.303 map.ca Domain
- N.304 Do Not Blur
- N.305 City Events
- N.306 Owen Sound's present policy permits campaign-related facility use under ordinary rental or licence terms and standard fees while prohibiting other improper use of municipal resources.
- N.307 Equal Terms
- N.308 Incumbent
- N.309 Challenger
- N.310 Private Company
- N.311 No Free Room Because Mayor Owns Company
- N.312 No Hidden Staff Support
- N.313 City Event Sponsorship
- N.314 Better Default
- N.315 Why
- N.316 Donation
- N.317 "Free Gift"
- N.318 Gifts and Hospitality
- N.319 This Appendix Adds Founder-Specific Rule
- N.320 Mayor-Owned Company Gift to City
- N.321 Free Software Licence
- N.322 Free Equipment
- N.323 Free Consulting
- N.324 Free Hosting
- N.325 Free Trial
- N.326 "No Cost"
- N.327 Political Gifts
- N.328 Campaign Donation
- N.329 Procurement Donor Firewall
- N.330 Donor Identity
- N.331 Unless Legal Conflict Requires
- N.332 No Donor Blacklist Either
- N.333 Campaign Contribution Rules
- N.334 Private Corporations and Campaigns
- N.335 Third-Party Advertising
- N.336 Therefore
- N.337 If a Related Corporation Contemplates Election Advertising
- N.338 Do Not Coordinate Through Back Channel
- N.339 Private Company Employees
- N.340 Employment Pressure
- N.341 Voluntary Political Activity
- N.342 Business Customer List
- N.343 Conversely
- N.344 "Same People"
- N.345 City Officials and Private Employees
- N.346 Private employee should not direct City staff
- N.347 City staff should not direct private company
- N.348 Private Employee at City Meeting
- N.349 Mayor's Private Advisor
- N.350 Campaign Advisor
- N.351 If Appointed to City Job
- N.352 No Automatic Job
- N.353 No Automatic Consulting Contract
- N.354 No Automatic Board Appointment
- N.355 Appointments
- N.356 Campaign Loyalty
- N.357 Political Opponent
- N.358 Staff Hiring
- N.359 Strong-Mayor Powers
- N.360 Personnel Firewall
- N.361 Campaign Staff Candidate
- N.362 But Relationship
- N.363 Independent HR Input
- N.364 No Fictitious Competition
- N.365 No Political Loyalty Requirement for Professional Staff
- N.366 City Manager
- N.367 Not campaign.
- N.368 Political Office Staff
- N.369 Do Not Invent Unfunded Mayor's Private Office
- N.370 Family and Related Persons
- N.371 Therefore
- N.372 Governance Standard
- N.373 Family Business
- N.374 Family Employment
- N.375 Family Property
- N.376 Ordinary Citywide Benefit
- N.377 Do Not Treat Every General Policy as Family Conflict
- N.378 But
- N.379 Related Company
- N.380 Ownership Disclosure
- N.381 No Hidden Beneficial Interest
- N.382 Private Meetings
- N.383 Meeting Itself Is Not Improper
- N.384 But
- N.385 Municipal Meeting Register
- N.386 Proposed Fields
- N.387 Do Not Publish
- N.388 Private-Business Meeting
- N.389 If Person Meets Mayor Because of Office
- N.390 If They Also Want Private Product
- N.391 Say
- N.392 Lobbying
- N.393 No Founder Exemption
- N.394 No Opponent Penalty
- N.395 Access
- N.396 But
- N.397 Listening Is Not Procurement
- N.398 Meeting Is Not Commitment
- N.399 "Send it to staff"
- N.400 But
- N.401 No "I Already Promised Them"
- N.402 Developer Meeting
- N.403 Investor Meeting
- N.404 Community Organization
- N.405 Open Door
- N.406 Favouritism
- N.407 Private Real-Estate Work
- N.408 City Development Information
- N.409 Upcoming Municipal Land Sale
- N.410 Confidential zoning discussion
- N.411 Infrastructure timing
- N.412 Development lead
- N.413 Resident property issue
- N.414 City Introduces Business
- N.415 Private Brokerage Client
- N.416 No Fast Lane
- N.417 No Slow Lane for Competitor
- N.418 Planning Staff
- N.419 Mayor Can Advocate for Better System
- N.420 Not Queue-Jump for Specific Client
- N.421 Private Property Owned by Mayor
- N.422 Permit
- N.423 Inspection
- N.424 Tax
- N.425 Enforcement
- N.426 No Special Access
- N.427 No Special Punishment
- N.428 Firewalls Protect Mayor Too
- N.429 Complaint
- N.430 Campaign Branding
- N.431 City Strategic Plan
- N.432 Campaign Policy
- N.433 But It Must Go Through
- N.434 "It Was My Platform"
- N.435 Election Mandate
- N.436 But
- N.437 City Communications
- N.438 Credit
- N.439 But Public Asset Belongs to
- N.440 Public Playbook
- N.441 No Hidden Founder Licence
- N.442 Campaign Photos
- N.443 City Photos
- N.444 Personal Photo
- N.445 Publicly Available City Fact
- N.446 City Staff Draft
- N.447 Campaign Fact Check
- N.448 City Correction
- N.449 Incumbent Criticism
- N.450 Staff Can Correct False Statement About City Operations
- N.451 Not Personal Attack
- N.452 Press Office Firewall
- N.453 Reporter Asks About City Policy
- N.454 Reporter Asks Why Candidate Deserves Re-Election
- N.455 Reporter Asks About Private Company
- N.456 Mixed Question
- N.457 Contact Channels
- N.458 No Staff Answering Campaign Phone
- N.459 No Campaign Volunteer Answering City Phone
- N.460 Municipal Newsletter
- N.461 No "Vote for"
- N.462 No Subtle Incumbent Promotion
- N.463 Official Achievements
- N.464 Election Does Not Shut Down Government
- N.465 Distinction
- N.466 Election-Year Work
- N.467 Do Not Stop Infrastructure Repair Because Election
- N.468 Do Not Accelerate Ribbon Cutting Because Election
- N.469 Do Not Delay Bad News Until After Election
- N.470 Do Not Rush Good News Before Verification
- N.471 Strong-Mayor Election Transition
- N.472 Election Transition Checklist
- N.473 Candidate Incumbency
- N.474 Challenger Equality
- N.475 City Election Information
- N.476 Current Candidate Information
- N.477 Keep That Principle
- N.478 Third-Party Groups
- N.479 Candidate
- N.480 Private Business Advocacy
- N.481 No Corporate Back Door
- N.482 Donations and Sponsorships During Election Year
- N.483 Municipal Sponsor
- N.484 Private Founder Company Sponsor
- N.485 City-Funded Event
- N.486 Candidate Debate
- N.487 Equal Invitation Rules
- N.488 City Facility
- N.489 Campaign Event
- N.490 Municipal Equipment
- N.491 Municipal Vehicle
- N.492 City Uniform
- N.493 Public Asset
- N.494 Campaign Sign
- N.495 Real-Estate Sign Reform
- N.496 Policy Independence
- N.497 Private-to-Public Asset Transfer
- N.498 Why
- N.499 Donation Does Not Cure Conflict
- N.500 $1 Sale
- N.501 $0 Licence
- N.502 Independent Acceptance Review
- N.503 Questions
- N.504 No Ceremonial Donation
- N.505 Transfer Before Adoption
- N.506 But
- N.507 Founder Retained Royalty
- N.508 Founder Retained Control Right
- N.509 Founder Retained Veto
- N.510 Founder Retained Exclusive Commercialization
- N.511 Public Ownership Claim
- N.512 No "Community-Owned" Marketing
- N.513 Independent Nonprofit
- N.514 Founder Appoints Majority Forever
- N.515 Founder Veto
- N.516 Board Filled With Campaign Team
- N.517 Governance Independence Test
- N.518 Public Benefit Corporation / Nonprofit
- N.519 Governance Substance
- N.520 Data and Private Platforms
- N.521 Public Data
- N.522 Protected Data
- N.523 Early Access
- N.524 Embargoed Data
- N.525 Draft City Data
- N.526 Resident Feedback
- N.527 Business Registration Data
- N.528 Tender Information
- N.529 Upcoming Land Decision
- N.530 Confidential Development Information
- N.531 Municipal Analytics
- N.532 AI Training
- N.533 Public Open Data
- N.534 Private Platform User Data
- N.535 "Helpful Insight"
- N.536 Aggregate Public Insight
- N.537 Personal Data
- N.538 Data Sharing Agreement
- N.539 Independent Need
- N.540 MFIPPA
- N.541 Campaign List
- N.542 Data Minimization
- N.543 Records
- N.544 But
- N.545 Conflict File
- N.546 Privileged Advice
- N.547 Public Explanation
- N.548 Recusal Record
- N.549 Current Owen Sound Practice
- N.550 Additional Founder-Sensitive Register
- N.551 Do Not Publish
- N.552 Public Should Know
- N.553 Conflict Does Not Require Project Disappearance
- N.554 Sometimes
- N.555 Sometimes
- N.556 Sometimes
- N.557 Sometimes
- N.558 Sometimes
- N.559 Then
- N.560 Conflict Risk Levels
- N.561 This Is Governance Tool
- N.562 Statutory Conflict Still Determined Under Law
- N.563 Level 0
- N.564 Level 1
- N.565 Level 2
- N.566 Level 3
- N.567 Level 4
- N.568 Do Not Self-Assign Lower Level
- N.569 Independent File Owner
- N.570 Mayor Should Not Receive Confidential Updates
- N.571 Public Information
- N.572 No Informal Text Messages
- N.573 No "Just Curious"
- N.574 No Proxy Influence
- N.575 MCIA Head-of-Council Rule
- N.576 Recusal Scope
- N.577 Do Not Invent Rule
- N.578 Integrity Commissioner Advice
- N.579 Advice Before Decision
- N.580 Written Advice
- N.581 Facts Supplied
- N.582 Do Not Omit
- N.583 Advice Can Become Stale
- N.584 Re-ask.
- N.585 Provincial Reform
- N.586 Gifts and Benefits
- N.587 Conference
- N.588 Vendor-Paid Travel
- N.589 City-Paid Official Travel
- N.590 Private-Company-Paid Travel
- N.591 Mixed Trip
- N.592 No City Paying Private Sales Trip
- N.593 No Private Company Paying Municipal Procurement Trip
- N.594 Travel Log
- N.595 Expense
- N.596 Private Meeting During Official Trip
- N.597 City Staff
- N.598 Private Staff
- N.599 Conference Booth
- N.600 Title Usage
- N.601 Private Investment
- N.602 But
- N.603 Confidential Information
- N.604 Land Purchase
- N.605 If City planning confidentially affects parcel
- N.606 Business Purchase
- N.607 Technology Company Investment
- N.608 Former Private Activity
- N.609 Prior Proposal to City
- N.610 Prior Negotiation
- N.611 Prior Licence
- N.612 Prior Relationship With Vendor
- N.613 Historic Business Dispute
- N.614 Does Not automatically require:
- N.615 Seek advice.
- N.616 Staff Personal Interests
- N.617 Employee Ethics
- N.618 Procurement Staff
- N.619 Developer Relationship
- N.620 Vendor Family Member
- N.621 No Mayor Exception
- N.622 Council-Wide Standard
- N.623 But Founder-Specific Rules
- N.624 Public Cannot Be Asked to Pretend That Overlap Does Not Exist
- N.625 Better
- N.626 Complaint Process
- N.627 Different Complaints
- N.628 Integrity Commissioner
- N.629 Clerk
- N.630 Procurement
- N.631 Privacy
- N.632 Employee Ethics
- N.633 No One Giant Political Complaints Office
- N.634 Route Correctly
- N.635 Whistleblower Protection
- N.636 Without Retaliation
- N.637 Anonymous Reporting
- N.638 But
- N.639 Good-Faith Complaint
- N.640 Malicious Complaint
- N.641 Criticism
- N.642 Investigation
- N.643 Mayor Should Not Select Investigator
- N.644 Mayor Should Not Set Scope
- N.645 Mayor Should Not Receive Draft for Approval
- N.646 Mayor Can Respond to Allegation
- N.647 Procedural Fairness
- N.648 Public Result
- N.649 No Trial by Social Media
- N.650 No Political Exoneration by Self-Statement
- N.651 Evidence
- N.652 Correction
- N.653 If breach found:
- N.654 Remediation
- N.655 Procurement Remedy
- N.656 Data Remedy
- N.657 Communication Remedy
- N.658 Resource Misuse
- N.659 Campaign Finance
- N.660 Compliance Audit
- N.661 This Is Separate From Municipal Ethics Complaint
- N.662 Do Not Mix
- N.663 Specificity
- N.664 Post-Election Transition
- N.665 Campaign Wind-Down
- N.666 Campaign Treasurer / Records
- N.667 City Finance
- N.668 No City Staff Preparing Campaign Financial Statement
- N.669 No City Auditor Doing Campaign Return as City work
- N.670 Campaign Debt
- N.671 Campaign Surplus
- N.672 Inauguration
- N.673 Campaign Celebration
- N.674 Keep Costs Separate
- N.675 Transition Team
- N.676 Background Briefings
- N.677 Incoming Mayor
- N.678 Private Advisors
- N.679 NDA
- N.680 Municipal Appointment
- N.681 First 24 Hours in Office
- N.682 Campaign Phone
- N.683 City Phone
- N.684 Contact Forwarding
- N.685 Residents Will Keep Using Campaign Contact
- N.686 Response
- N.687 Do Not Build Municipal record inside campaign inbox
- N.688 If substantive City matter arrives there
- N.689 Preserve record as required.
- N.690 First 30 Days
- N.691 First 30-Day Actions
- N.692 First 30 Days
- N.693 No Assumption of Adoption
- N.694 First 30 Days
- N.695 Freeze Does Not Mean Reject
- N.696 First 60 Days
- N.697 Protocol Should Define
- N.698 First 60 Days
- N.699 First 60 Days
- N.700 First 60 Days
- N.701 First 60 Days
- N.702 First 100 Days
- N.703 Review Is Not Adoption
- N.704 First 100 Days
- N.705 First 100 Days
- N.706 Year One
- N.707 Year One
- N.708 Year One
- N.709 If Gates Fail
- N.710 No Sunk-Cost Argument
- N.711 Year Two
- N.712 Questions
- N.713 Fix Weakness
- N.714 Year Two
- N.715 Year Three
- N.716 Ask
- N.717 If No
- N.718 Governance Should Protect Against
- N.719 Year Three
- N.720 If municipal dependence remains on founder-controlled asset
- N.721 Year Four
- N.722 Do Not Relax Because Record Is Good
- N.723 Election-Year Review
- N.724 Incumbent Candidate
- N.725 But
- N.726 Government Continues
- N.727 Private Businesses Continue
- N.728 Three Systems
- N.729 Four-Year Audit
- N.730 Audit Should Answer
- N.731 Do Not Publish Protected Details
- N.732 Public Audit
- N.733 Name map.ca Outcome
- N.734 Name RealMap Outcome
- N.735 Possible Outcomes
- N.736 No Face-Saving Category
- N.737 Name Any Related Procurement
- N.738 Show Result
- N.739 Name Any Related IP Transfer
- N.740 State consideration
- N.741 Name Any Private Benefit Safeguard
- N.742 Name Any Firewall Failure
- N.743 Name Remediation
- N.744 Election-Year Resource Review
- N.745 Handoff
- N.746 No Conflict Surprise
- N.747 Or
- N.748 Or
- N.749 Or
- N.750 Or
- N.751 Or
- N.752 Or
- N.753 Or
- N.754 Or
- N.755 Anti-Gaming Rule One
- N.756 Rule Two
- N.757 Rule Three
- N.758 Rule Four
- N.759 Rule Five
- N.760 Rule Six
- N.761 Rule Seven
- N.762 Rule Eight
- N.763 Rule Nine
- N.764 Rule Ten
- N.765 Rule Eleven
- N.766 Rule Twelve
- N.767 Rule Thirteen
- N.768 Rule Fourteen
- N.769 Rule Fifteen
- N.770 Rule Sixteen
- N.771 Rule Seventeen
- N.772 Rule Eighteen
- N.773 Rule Nineteen
- N.774 Rule Twenty
- N.775 Rule Twenty-One
- N.776 Rule Twenty-Two
- N.777 Rule Twenty-Three
- N.778 Rule Twenty-Four
- N.779 Rule Twenty-Five
- N.780 Rule Twenty-Six
- N.781 Rule Twenty-Seven
- N.782 Rule Twenty-Eight
- N.783 Rule Twenty-Nine
- N.784 Rule Thirty
- N.785 Rule Thirty-One
- N.786 Rule Thirty-Two
- N.787 Rule Thirty-Three
- N.788 Rule Thirty-Four
- N.789 Rule Thirty-Five
- N.790 Rule Thirty-Six
- N.791 Rule Thirty-Seven
- N.792 Rule Thirty-Eight
- N.793 Rule Thirty-Nine
- N.794 Rule Forty
- N.795 Rule Forty-One
- N.796 Rule Forty-Two
- N.797 Rule Forty-Three
- N.798 Rule Forty-Four
- N.799 Rule Forty-Five
- N.800 Rule Forty-Six
- N.801 Rule Forty-Seven
- N.802 Rule Forty-Eight
- N.803 Rule Forty-Nine
- N.804 Rule Fifty
- N.805 Rule Fifty-One
- N.806 Rule Fifty-Two
- N.807 Rule Fifty-Three
- N.808 Rule Fifty-Four
- N.809 Rule Fifty-Five
- N.810 Rule Fifty-Six
- N.811 Rule Fifty-Seven
- N.812 Rule Fifty-Eight
- N.813 Rule Fifty-Nine
- N.814 Rule Sixty
- N.815 Rule Sixty-One
- N.816 Rule Sixty-Two
- N.817 Rule Sixty-Three
- N.818 Rule Sixty-Four
- N.819 Rule Sixty-Five
- N.820 Rule Sixty-Six
- N.821 Rule Sixty-Seven
- N.822 Rule Sixty-Eight
- N.823 Rule Sixty-Nine
- N.824 Rule Seventy
- N.825 Rule Seventy-One
- N.826 Rule Seventy-Two
- N.827 Rule Seventy-Three
- N.828 Rule Seventy-Four
- N.829 Rule Seventy-Five
- N.830 Rule Seventy-Six
- N.831 Rule Seventy-Seven
- N.832 Rule Seventy-Eight
- N.833 Rule Seventy-Nine
- N.834 Rule Eighty
- N.835 The Three-System Test
- N.836 The Authority Test
- N.837 The Private-Benefit Test
- N.838 The Appearance Test
- N.839 The Disclosure Test
- N.840 The Recusal Test
- N.841 The Influence Test
- N.842 The Staff Test
- N.843 The Procurement Test
- N.844 The Founder Test
- N.845 The Reverse-Founder Test
- N.846 The Public-Ownership Test
- N.847 The Windfall Test
- N.848 The Data Test
- N.849 The Consent Test
- N.850 The Staff-Resource Test
- N.851 The Time Test
- N.852 The Account Test
- N.853 The Communications Test
- N.854 The Title Test
- N.855 The Gift Test
- N.856 The Appointment Test
- N.857 The Donor Test
- N.858 The Opponent Test
- N.859 The Confidentiality Test
- N.860 The IP Test
- N.861 The Valuation Test
- N.862 The Free Test
- N.863 The Exit Test
- N.864 The Future-Mayor Test
- N.865 The Staff-Safety Test
- N.866 The Public Test
- N.867 The Evidence Test
- N.868 The Conflict Firewall Commitment
Public office must never become a private distribution channel, procurement advantage, data source or ownership shortcut
A person can be several things at once.
They can be:
- a resident;
- a business owner;
- an inventor;
- a property owner;
- a candidate;
- a volunteer;
- an elected official.
Those roles are lawful.
The danger begins when the boundaries between them become:
- unclear;
- informal;
- convenient;
- selectively ignored.
A good idea does not become municipal property because:
- the Mayor invented it.
A private company does not become the City's preferred supplier because:
- its founder holds public office.
A campaign mailing list does not become:
- a municipal resident database.
A City resident database does not become:
- a campaign list.
A municipal employee does not become:
- campaign staff.
A City communications channel does not become:
- incumbent advertising.
A Mayor's meeting does not become:
- a sales call for a private company.
A public procurement does not become:
- a method for transferring public value into a related private interest.
And a private platform should never acquire legitimacy through:
Mayor says the City should use it.
The standard should be stronger than:
I know I can be fair.
The better standard is:
The process should remain fair even if everyone assumes I might not be.
That is the purpose of a firewall.
The governing principle is:
Public office must never become a private distribution channel, procurement advantage, data source or ownership shortcut.
A second principle follows:
Disclosure is important, but disclosure alone is not a cure for conflict.
A third principle is:
Where the Mayor has a private interest, the Mayor should not control the municipal process used to evaluate that interest.
A fourth principle is:
Campaign, private business and municipal government must remain three separate systems.
And a fifth principle is:
The stronger the private connection, the stronger the independent safeguard.
N.1Purpose
This appendix establishes a practical firewall among:
Campaign Activity
Private Interests
Municipal Government
N.2It Applies To
- Mayor;
- Council;
- political campaign organizations;
- businesses owned or controlled by elected officials;
- related private platforms;
- private intellectual property;
- municipal staff;
- contractors;
- procurement;
- data;
- communications;
- events;
- municipal assets;
- public funds.
N.3It Is Not a Declaration That Conflict Exists in Every Case
No.
N.4It Is a System for Determining
- when conflict exists;
- when conflict may reasonably appear to exist;
- when enhanced safeguards are prudent.
N.5Statutory Conflict
Must be handled according to:
- current Ontario law.
N.6Broader Governance Conflict
May require safeguards even where:
- statutory pecuniary-interest rules do not provide the entire answer.
N.7Appearance of Conflict
Does not automatically establish:
- wrongdoing.
N.8But Appearance Can Damage
- public confidence;
- procurement credibility;
- staff independence.
N.9Therefore
Design process so public does not need to rely solely on:
Trust me.
N.10The Three-System Rule
Maintain three institutionally separate environments:
Campaign
Private
Municipal
N.11Campaign System
Contains:
- campaign volunteers;
- campaign donors;
- campaign website;
- canvassing;
- campaign email;
- campaign social media;
- campaign research;
- campaign contact lists;
- election advertising.
N.12Private System
Contains:
- private businesses;
- clients;
- intellectual property;
- investments;
- private employees;
- private domains;
- customer data;
- commercial opportunities.
N.13Municipal System
Contains:
- City staff;
- municipal email;
- municipal records;
- resident service data;
- procurement;
- public property;
- municipal communications;
- City websites;
- municipal powers;
- municipal contracts.
N.14Information Should Not Flow Freely Across Those Boundaries
No.
N.15Money Should Not Flow Freely Across Them
No.
N.16Staff Should Not Flow Freely Across Them During Work Time
No.
N.17Intellectual Property Should Not Flow Across Them Without
- authority;
- valuation;
- agreement;
- independent review.
N.18Public Power Should Never Flow Into Private Advantage
Core principle.
N.19Legal Baseline
The firewall must operate in addition to, and not instead of:
- Municipal Conflict of Interest Act;
- Municipal Act;
- Municipal Elections Act;
- MFIPPA;
- applicable City policies;
- procurement law;
- other applicable law.
N.20Municipal Conflict of Interest Act
Ontario's current Municipal Conflict of Interest Act addresses direct and indirect pecuniary interests and sets duties for members. It also contains specific rules for a head of council who has a pecuniary interest in a matter involving specified head-of-council powers, including written disclosure and restrictions on using the power or attempting to influence the municipal decision.
N.21This Is Particularly Important Under Strong-Mayor Powers
Because the head of council may have statutory powers that are:
- separate from ordinary Council voting.
N.22Owen Sound and Strong-Mayor Powers
Owen Sound is currently designated under Ontario's strong-mayor framework. The current regulation also requires written records of certain mayoral directions to municipal employees and, subject to MFIPPA, public availability of specified written records.
N.23Election-Period Limits
Ontario also amended the strong-mayor regulation in June 2026 to limit certain head-of-council powers during the election transition once specified electoral conditions are known, including certain powers involving the CAO, organizational structure and specified property or expenditure proposals.
N.24Therefore
The firewall must cover:
- Council votes;
- mayoral decisions;
- mayoral directions;
- staffing decisions;
- organizational decisions;
- budget decisions;
- procurement influence.
N.25Integrity Commissioner
Owen Sound currently provides access to an Integrity Commissioner and maintains a registry relating to written declarations of pecuniary interest.
N.26Provincial Accountability Changes
Ontario enacted the Municipal Accountability Act, 2026, which would significantly change the provincial code-of-conduct and Integrity Commissioner framework when the relevant provisions are brought into force. As of August 2026, the current Municipal Act still identifies those Schedule 2 amendments as not yet in force.
N.27Therefore
This appendix should be:
reverified at the beginning of the new Council term.
N.28Do Not Build Firewall Around Soon-to-Be-Obsolete Law
Correct.
N.29Current City Code
Owen Sound's presently published Council code includes specific sections addressing conflicts, gifts and hospitality, use of City resources, election campaigns, improper influence and business relations. Its resource provisions also state that members are not to use City resources for personal purposes and address personal financial gain from City-developed intellectual property.
N.30Election Resources
The Municipal Elections Act requires municipalities and local boards to establish rules and procedures concerning use of municipal or board resources during regular election campaign periods.
N.31Owen Sound Current Election Policy
Owen Sound's 2026 Use of Municipal Resources for Elections Policy states that municipal resources are to be used impartially and not to support or oppose candidates or campaigns. Its detailed restrictions cover City branding, City-funded websites, municipal email and voicemail, corporate IT and data, staff campaign assistance, City-created photographs and video, and campaign displays on City property, while permitting ordinary facility rentals under standard terms.
N.32This Appendix Does Not Replace That Policy
It strengthens the long-term:
- governance;
- transition;
- private-interest;
firewall.
N.33Legal Advice
Where application is uncertain:
Use:
- Integrity Commissioner;
- Clerk;
- qualified legal counsel;
as appropriate.
N.34Do Not Ask Political Staff to Interpret Conflict Law
No.
N.35The Firewall Principle
When a public decision could produce a material private benefit for the Mayor or a related private interest:
remove the Mayor from control over the evaluation path to the extent required by law and prudent governance.
N.36This Can Include Removal From
- initiating staff direction;
- drafting specifications;
- selecting reviewers;
- negotiating;
- evaluating;
- receiving confidential bid information;
- influencing recommendations.
N.37Exact Requirements
Depend on:
- applicable law;
- facts;
- decision.
N.38Independent Process
Should not depend on Mayor deciding:
when independence is necessary.
N.39Trigger
Established in advance.
N.40Conflict Firewall Trigger
Enhanced safeguards should be considered when municipal action could materially affect:
- company owned by Mayor;
- company controlled by Mayor;
- business partner;
- significant investment;
- private intellectual property;
- related domain;
- private licence;
- related real property;
- close family financial interest where legally relevant.
N.41Ownership Percentage
Do not rely on arbitrary percentage alone.
N.42Minority Holding
Can still create:
- pecuniary interest.
N.43Non-Equity Interest
Can still create:
- benefit.
N.44Royalty
Can create interest.
N.45Licence
Can create interest.
N.46Trademark
Can create interest.
N.47Domain
Can create interest.
N.48Future Sale Value
Can create interest.
N.49Reputation
Can create governance concern even where no statutory pecuniary interest exists.
N.50Public Interest Disclosure
Upon assuming office, the Mayor should establish a proactive:
Public Interest Disclosure
subject to legal and privacy review.
N.51This Is Proposed Governance Standard
Not a claim that current Ontario law requires publication of every:
- private interest.
N.52Public Disclosure Should Focus On Interests Reasonably Relevant to Municipal Decision-Making
Not:
- personal intrusion.
N.53Possible Categories
Significant Business Ownership
Directorships
Partnerships
Founder Roles
Material Municipal-Sector Intellectual Property
Companies Potentially Seeking City Business
Related Real Property Where Municipal Decisions May Materially Affect It
N.54Do Not Publish
- bank account balances;
- unrelated customer lists;
- confidential family information;
- private trade secrets;
without legal reason.
N.55Transparency Should Be Relevant
Not voyeuristic.
N.56Update
If material interest changes:
Update.
N.57Annual Confirmation
Useful.
N.58Clerk / Integrity Review
Could advise on:
- appropriate disclosure.
N.59Public Record
Should identify:
nature of potentially relevant interest
without unnecessarily publishing:
- commercially sensitive details.
N.60map.ca
Should be expressly included.
N.61RealMap
Should be expressly included.
N.62Other Founder-Associated Technology
Include if municipal relevance develops.
N.63Private Real-Estate Interests
Consider disclosure where:
- municipal decision creates specific pecuniary issue.
N.64Ordinary Profession
Being:
- realtor;
- business owner;
- landlord;
does not automatically require withdrawal from every matter affecting that sector.
N.65Broad Class Effects
Conflict law contains:
- definitions;
- exceptions;
- factual tests.
Use legal advice.
N.66Do Not Over-Recuse
Public officials still need to:
- govern.
N.67Do Not Under-Recuse
Private benefit still matters.
N.68Recusal Is Not Punishment
It protects:
- official;
- Council;
- staff;
- public.
N.69Disclosure Is First Step
Not always:
- last step.
N.70Candidate-to-Office Transition
Election victory should trigger a formal:
Campaign-to-Government Transition Protocol.
N.71Campaign Does Not Become City Department
No.
N.72Campaign Staff
Do not automatically become:
- City employees.
N.73Campaign Volunteer
No automatic:
- appointment;
- contract;
- committee seat.
N.74Donor
No automatic:
- access;
- appointment;
- procurement advantage.
N.75Endorser
No automatic:
- privilege.
N.76Political Opponent
No automatic:
- penalty.
N.77Transition Inventory
Separate:
Campaign Assets
Candidate Personal Assets
Private Business Assets
Municipal Records
N.78Campaign Laptop
Campaign.
N.79City Laptop
Municipal.
N.80Private Business Laptop
Private.
N.81Do Not Merge Drives
No.
N.82Campaign Email Account
Remain separate.
N.83City Email Account
Begin public-office work.
N.84Private Business Email
Remain private-business system.
N.85No Automatic Forwarding
Do not automatically forward:
- City email to private account;
- private email to City account;
- campaign email to City account.
N.86Resident Sends Campaign Idea
Campaign can retain according to:
- campaign law;
- privacy commitments.
N.87Municipal Adoption
If idea moves into City process:
Recreate the issue through:
- municipal file;
- municipal authority;
- municipal contact;
without automatically importing unrelated campaign information.
N.88Campaign Contact Consent
Consent to receive campaign communications is not automatically:
- consent to enter municipal service database.
N.89Municipal Resident Service Contact
Not automatically:
- campaign consent.
N.90Campaign Data Separation
Do not transfer into municipal systems:
- supporter list;
- donor list;
- canvass data;
- voter preference;
- supporter ratings;
- campaign survey responses;
- volunteer list.
N.91City Data Separation
Do not transfer into campaign systems:
- service requests;
- property account contacts;
- recreation registrations;
- business records;
- permit applicants;
- Civic Corps participants;
- senior program contacts;
- Resident Pulse data;
- Strong Vote data.
N.92Private Data Separation
Do not transfer into City systems:
- RealMap customer data;
- map.ca private user data;
- brokerage client data;
- company email lists;
- commercial analytics;
unless a lawful municipal acquisition specifically provides for it.
N.93Likewise
Do not transfer City data into:
- RealMap;
- map.ca;
- private brokerage;
- private company;
without a lawful municipal decision and data-governance basis.
N.94No Informal Database Merge
Never.
N.95"But It Would Help Residents"
Not enough.
N.96Public Purpose
Required.
N.97Legal Authority
Required.
N.98Privacy
Required.
N.99Procurement / Agreement
Required where applicable.
N.100Data Firewall
Appendix J applies.
N.101Staff Firewall
Municipal staff work for:
- City.
N.102Not Mayor Personally
N.103Not Campaign
N.104Not Mayor's Private Company
N.105Staff Direction
Must relate to:
- lawful municipal work.
N.106Private Business Request
Use:
- normal private channel.
N.107Example
Mayor should not tell City communications employee:
Improve my private company's website.
N.108Nor
Prepare a map.ca investor presentation.
N.109Nor
Research RealMap competitors for my company.
N.110Nor
Export businesses from City system so I can market to them privately.
N.111Obvious
But worth writing.
N.112Staff Protection Standard
A municipal employee should be able to say:
I believe this request may cross the municipal-private firewall. I need it reviewed before proceeding.
N.113Without Retaliation
Essential.
N.114Escalation
Could include:
Manager
City Manager / CAO
Clerk
Legal
Integrity Commissioner
N.115Appropriate Route Depends On
- issue.
N.116No Staff Forced to Confront Mayor Alone
Important.
N.117Written Direction
Particularly important under:
- statutory mayoral powers.
N.118Strong-Mayor Direction
Current Ontario regulations require written records of certain directions to municipal employees under the strong-mayor framework.
N.119Firewall Standard
Any mayoral direction touching a founder-associated private interest should receive:
automatic conflict screening.
N.120If Conflict Confirmed
Do not issue direction.
N.121If Uncertain
Seek:
- independent advice.
N.122Staff Should Not Be Penalized for Delay Required by Conflict Review
No.
N.123No Performance Review Retaliation
N.124No Schedule Retaliation
N.125No Promotion Retaliation
N.126No Public Shaming
N.127Staff Independence
A City Manager or statutory official should be able to:
- disagree;
- ask for legal review;
- refuse unlawful direction.
N.128Political Authority
Does not erase:
- professional responsibility.
N.129Procurement Firewall
When founder-associated business could benefit:
Mayor does not:
- create procurement path;
- select procurement method;
- draft specification;
- choose evaluation team;
- see confidential proposals;
- score;
- negotiate;
- direct award.
N.130Independent Procurement Owner
Assign.
N.131Possible Owner
- senior municipal staff;
- independent procurement professional;
- other unconflicted authority;
as lawful.
N.132Procurement Policy
Appendix L applies.
N.133Same Rules
Founder-associated supplier receives:
- no easier rules.
N.134Also
No artificially harder rules purely for:
- optics.
N.135Same Defensible Standard
With stronger independence.
N.136Equality of Process
Not equality of influence.
N.137Founder Knowledge
Mayor may know technology deeply.
N.138That Knowledge Can Be Useful to Public Policy
But must be separated from:
- vendor selection.
N.139Public Standard
Mayor can advocate:
City should improve digital property information.
N.140Mayor should not direct:
City should buy my exact platform.
N.141Policy Objective
Legitimate political role.
N.142Supplier Selection
Independent municipal role.
N.143Separation Is Key
N.144Open Standard
Where possible:
Define desired:
- public outcome;
- interoperability;
- privacy;
- accessibility;
- data ownership.
N.145Then Market Can Respond
N.146If Related Platform Wins Fairly
Possible only after:
- conflict;
- procurement;
- legal;
- valuation;
requirements are satisfied.
N.147But
Public ownership or open standard may be:
- better model.
N.148No Presumption
Evaluate.
N.149Sole Source
Founder association should increase scrutiny.
N.150"Only My Company Can Do It"
Needs:
- independent market evidence.
N.151No Self-Certification
No.
N.152Prototype
Can demonstrate:
- concept.
N.153Prototype Does Not Prove
- fair market value;
- municipal need;
- procurement exemption;
- production readiness.
N.154Independent Business Case
Required before major adoption.
N.155Independent Valuation
Where City may acquire:
- IP;
- domain;
- software;
- brand;
- database;
- licence.
N.156Valuation Should Consider
Replacement Cost
Development Cost
Market Comparables
Revenue Potential
Liabilities
Maintenance Burden
Restrictions
Transferability
N.157Development Cost Alone
Not value.
N.158Founder Time
Not automatically:
- public acquisition price.
N.159Future Potential
Not guaranteed value.
N.160Public Ownership
If municipal adoption depends on a private founder-associated asset:
A strong default should be to examine whether public ownership, open licensing or independent nonprofit governance is more appropriate than:
- long-term founder control.
N.161map.ca Proposal
The original initiative brief already contemplates protected public ownership before City adoption of map.ca-related infrastructure.
N.162That Principle Should Be Enforced Through Independent Process
Not founder declaration.
N.163Public Ownership Means
Actual enforceable ownership or control.
N.164Not
Founder promises City can use it forever.
N.165Ownership Questions
Domain
Trademark
Source Code
Database
Design
Documentation
Accounts
Hosting
Keys
Contracts
Analytics
N.166Licence
May be appropriate.
N.167Assignment
May be appropriate.
N.168Open Licence
May be appropriate.
N.169Nonprofit Ownership
May be appropriate.
N.170Municipal Ownership
May be appropriate.
N.171Private Ownership
May be appropriate.
N.172Model Chosen By
- public interest;
- governance;
- complete cost;
- conflict;
- sustainability.
N.173Not Founder Preference Alone
N.174Founder Windfall Test
Ask:
Would municipal adoption materially increase the private value of a related company, domain, trademark or other asset?
N.175If Yes
Enhanced safeguards.
N.176Even If City Pays Nothing
Important.
N.177Free Municipal Adoption Can Create Private Value Through
- credibility;
- reference customer;
- traffic;
- network effect;
- publicity;
- data;
- future sales.
N.178Therefore
"Free" does not eliminate:
- conflict.
N.179No Promotional Testimonial
City staff should not become:
- sales references;
for founder business without independent authority.
N.180Municipal Logo
Do not place on private company marketing merely because:
- Mayor approves.
N.181Case Study
Any public-sector case study involving a related company should follow:
- City communications;
- procurement;
- conflict;
approval.
N.182No "Official City Partner"
Unless actual agreement supports:
- designation.
N.183RealMap Firewall
Any municipal consideration of RealMap should begin with:
What municipal objective are we trying to achieve independently of RealMap?
N.184Examples
- better property information;
- streetscape improvements;
- easier listing access;
- open standards.
N.185Then Ask
What lawful and competitive models could achieve that objective?
N.186If RealMap Vanishes
Policy should still make:
- public sense.
N.187Sign Transition
Must stand independently.
N.188No Sign Rule Designed to Force RealMap Usage
Never.
N.189No RealMap Requirement
No.
N.190No RealMap-Linked Permit
No.
N.191No RealMap-Linked Municipal Ranking
No.
N.192No Municipal Data Feed Reserved Exclusively for RealMap Without Defensible Public Basis
No.
N.193Open Data
If City data is lawfully public:
Provide according to:
- neutral rules;
- licensing;
- security;
- privacy.
N.194Private Platform Can Use Open Data
Like others.
N.195No Private API Privilege
Without agreement / procurement.
N.196map.ca Firewall
Any municipal map.ca evaluation should be led by:
- independent municipal process.
N.197Mayor May State Vision
For example:
I want residents to have a better public map and public information system.
N.198Mayor Should Not Determine
- vendor;
- valuation;
- acquisition price;
- procurement outcome;
- security approval.
N.199Independent Architecture Review
Required where major.
N.200Independent Privacy Review
Required.
N.201Independent Cybersecurity Review
Required.
N.202Accessibility Review
Required.
N.203Procurement Review
Required.
N.204Legal Review
Required.
N.205Financial Review
Required.
N.206No One Reviewer Selected Solely by Founder
No.
N.207Reviewer Independence
Document.
N.208Reviewer Conflict
Disclose.
N.209Review Scope
Publish where appropriate.
N.210Findings
Publish where appropriate.
N.211Negative Findings
Do not suppress.
N.212Founder Rebuttal
Can be heard.
N.213Founder Does Not Approve Final Report
No.
N.214Municipal Technology Pilot
If related platform is tested:
Use:
- isolated pilot;
- limited data;
- no preferential future guarantee;
- predetermined criteria;
- stop condition.
N.215Pilot Does Not Equal Procurement Award
No.
N.216Pilot Does Not Equal Endorsement
No.
N.217Pilot Does Not Equal Transfer of Ownership
No.
N.218Pilot Result
Can be:
Proceed
Modify
Compete
Transfer
Stop
N.219Private Intellectual Property
An elected official may continue to own private IP subject to:
- law;
- conflict;
- governance.
N.220But
Private IP should not be quietly developed using:
- City employees;
- City equipment;
- City data;
- City paid time;
- City contractors.
N.221Municipal IP
Likewise should not be privately captured.
N.222Current Owen Sound Code
The City's currently published code says members should not use City resources for personal purposes and addresses personal financial gain from City-developed intellectual property, reflecting the importance of keeping public resources and public IP separate from private benefit.
N.223New Idea Created in Office
Ownership can be fact-specific.
N.224Therefore
Document boundary.
N.225Mayor Sketches Private Invention on Weekend
Potentially private.
N.226City Employees Develop It During Paid Work
Potential municipal interest.
N.227City Funds Development
Potential municipal interest.
N.228Joint Development
Needs agreement.
N.229Do Not Resolve Later From Memory
Define before work.
N.230IP Development Notice
For founder-sensitive project:
Identify:
Existing Private IP
Municipal Contributions
New IP
Ownership
Licence
Commercialization
Public Reuse
N.231Pre-Existing IP
Document before municipal work begins.
N.232Otherwise
Future ownership disputes become likely.
N.233Git Repository
Ownership.
N.234Design Files
Ownership.
N.235Data Schema
Ownership / licence.
N.236Domain
Ownership.
N.237Brand
Ownership.
N.238Training Materials
Ownership.
N.239City-Funded Improvements
Define.
N.240Public Money
Should not invisibly increase private IP value without:
- lawful;
- transparent;
arrangement.
N.241Commercialization Rights
If public asset can later be commercialized:
Decide in advance.
N.242Revenue Share
Possible.
N.243Open Source
Possible.
N.244Public Domain
Possible where lawful.
N.245Municipal Licence
Possible.
N.246Private Retention
Possible only with defensible public benefit.
N.247Founder Royalty
High conflict threshold.
N.248Do Not Negotiate Own Royalty With City
No.
N.249Independent Negotiation
Required.
N.250Public Value
Demonstrate.
N.251Private Business Time
Mayor should clearly separate:
- municipal hours;
- private commercial work;
in practice.
N.252Mayor Is Not Hourly Employee
True.
N.253Therefore "Hours" Are Not Perfect Boundary
Better question:
What role is being exercised?
N.254Municipal Role
If meeting occurs because person is Mayor:
Treat as:
- municipal.
N.255Private Role
If meeting concerns private company sales:
Treat as:
- private.
N.256Mixed Meeting
Avoid where possible.
N.257If Mixed
Split agenda.
Record:
- transition;
- attendees;
- role.
N.258Example
Municipal conference meeting:
First:
- City-to-company public issue.
Then if appropriate and ethically permissible:
Separate private discussion after clear transition.
N.259Better
Schedule separately.
N.260No Municipal Introduction as Private Sales Leverage
Mayor should not say to another mayor:
As Mayor of Owen Sound, I want you to buy my company product.
N.261Public Office Network
Should not become:
- private sales pipeline.
N.262Private Business Can Exist
But business development must not exploit:
- public authority;
- confidential municipal access;
- preferential government introductions.
N.263Business Card
Separate.
N.264Municipal Email
Not private sales email.
N.265City Letterhead
Not private sales letterhead.
N.266Mayor Title
Use carefully in private commercial context.
N.267Biography
Factual public office can be mentioned where appropriate.
N.268But
Do not imply:
- municipal endorsement.
N.269"Mayor of Owen Sound recommends..."
High concern if referring to own private company.
N.270Private Company Website
Should not imply City adoption that does not exist.
N.271City Website
Should not market private founder business.
N.272Neutral Public Directory
Different.
N.273If map.ca / RealMap Appears in Neutral Directory
Same rules as:
- comparable services.
N.274No Featured Placement Because Founder Is Mayor
No.
N.275No Exclusion of Competitor
No.
N.276Communications Firewall
City communications should serve:
- municipal information.
N.277Campaign Communications
Serve:
- election.
N.278Private Communications
Serve:
- business.
N.279Separate Branding
Essential.
N.280Owen Sound's current election-resource policy prohibits candidate use of City branding, City-funded web properties, City email and voicemail, corporate IT and data, City communications staff and City-created photo or video for campaign purposes.
N.281Extend the Principle Beyond Election Day
Municipal communications should never function as:
- personal commercial advertising.
N.282Mayor Update
Can explain:
- municipal work.
N.283Mayor Update Should Not Say
Visit my private company to solve this.
N.284Public Policy Discussion
Can reference market examples when necessary.
N.285Founder Product
Higher disclosure.
N.286Press Conference
No private product placement.
N.287City Video
No private product demonstration unless part of:
- lawful public procurement;
- public event;
- neutral program.
N.288City Photographer
Not private marketing photographer.
N.289City Social Media
Not campaign or private channel.
N.290Campaign Can Share City Post
Like any member of public.
N.291But City Should Not tailor post to:
- incumbent campaign needs.
N.292Official Mayor Social Account
Needs clear policy.
N.293Personal Political Account
Different.
N.294Campaign Account
Different.
N.295Do Not Quietly Convert Campaign Account Into Official City Account
Without clear:
- ownership;
- records;
- data;
- follower;
decision.
N.296Followers
Not municipal property automatically.
N.297City Account
Should be institutionally controlled.
N.298Passwords
City-controlled.
N.299Account Survives Mayor
Yes.
N.300Official Website
Same.
N.301Mayor Domain
If personal:
- personal.
N.302City Domain
Municipal.
N.303map.ca Domain
Private unless lawfully transferred.
N.304Do Not Blur
N.305City Events
Campaign participation should comply with:
- current election resource rules.
N.306Owen Sound's present policy permits campaign-related facility use under ordinary rental or licence terms and standard fees while prohibiting other improper use of municipal resources.
N.307Equal Terms
Critical.
N.308Incumbent
Same rental terms.
N.309Challenger
Same.
N.310Private Company
Same ordinary commercial terms where facility use allowed.
N.311No Free Room Because Mayor Owns Company
No.
N.312No Hidden Staff Support
No.
N.313City Event Sponsorship
If Mayor-associated company wants to sponsor:
Enhanced conflict review.
N.314Better Default
Avoid founder-associated sponsorship of City events during term unless independent review establishes:
- public value;
- fair process.
N.315Why
Even small sponsorship can create:
- promotional benefit;
- perceived endorsement.
N.316Donation
Same concern.
N.317"Free Gift"
Still benefit.
N.318Gifts and Hospitality
Current Owen Sound Code contains a dedicated gifts, benefits and hospitality framework.
N.319This Appendix Adds Founder-Specific Rule
Do not accept gifts from a vendor seeking:
- founder-associated municipal decision;
as a way to normalize relationship.
N.320Mayor-Owned Company Gift to City
Requires same scrutiny as:
- unrelated private gift;
plus conflict review.
N.321Free Software Licence
Gift or contract implications.
N.322Free Equipment
Same.
N.323Free Consulting
Same.
N.324Free Hosting
Same.
N.325Free Trial
Same.
N.326"No Cost"
Does not mean:
- no value;
- no influence;
- no dependency.
N.327Political Gifts
Campaign contribution rules separate.
N.328Campaign Donation
Does not buy:
- meeting;
- contract;
- appointment.
N.329Procurement Donor Firewall
Procurement evaluator should not be selected because:
- donor relationship.
N.330Donor Identity
Need not be routinely injected into procurement.
N.331Unless Legal Conflict Requires
Handle appropriately.
N.332No Donor Blacklist Either
Political contribution should not penalize:
- bidder.
N.333Campaign Contribution Rules
Use current election law.
N.334Private Corporations and Campaigns
A private corporation is legally distinct from:
- candidate campaign.
N.335Third-Party Advertising
Owen Sound's current 2026 election guidance states that candidates cannot register as third-party advertisers and that registered third-party advertising must operate independently of candidates.
N.336Therefore
A candidate-controlled business should not be used as:
an indirect campaign advertising arm
to evade candidate campaign rules.
N.337If a Related Corporation Contemplates Election Advertising
Obtain:
- election-law advice.
N.338Do Not Coordinate Through Back Channel
No.
N.339Private Company Employees
May have personal political rights.
N.340Employment Pressure
Do not require private employees to:
- campaign;
- donate;
- endorse.
N.341Voluntary Political Activity
Separate.
N.342Business Customer List
Do not use for campaign without:
- lawful basis;
- appropriate consent;
- election compliance.
N.343Conversely
Campaign list should not become:
- business marketing list.
N.344"Same People"
Not same purpose.
N.345City Officials and Private Employees
Do not blur reporting lines.
N.346Private employee should not direct City staff
No.
N.347City staff should not direct private company
Unless acting through:
- lawful contract;
- regulatory authority.
N.348Private Employee at City Meeting
Identify role.
N.349Mayor's Private Advisor
Does not gain municipal authority.
N.350Campaign Advisor
Does not gain municipal authority.
N.351If Appointed to City Job
Then:
- transparent hiring;
- conflict;
- qualification;
rules apply.
N.352No Automatic Job
N.353No Automatic Consulting Contract
N.354No Automatic Board Appointment
N.355Appointments
Should use:
- defined criteria;
- open process;
where appropriate.
N.356Campaign Loyalty
Not qualification.
N.357Political Opponent
Should not be disqualified merely because:
- opponent.
N.358Staff Hiring
Mayor should not seek to use appointment powers to reward:
- campaign work.
N.359Strong-Mayor Powers
Particularly sensitive.
N.360Personnel Firewall
For any statutory mayoral staffing authority:
Role first.
Qualifications first.
Public need first.
Conflict review.
N.361Campaign Staff Candidate
Can be qualified.
N.362But Relationship
Should be:
- disclosed;
- reviewed.
N.363Independent HR Input
Useful.
N.364No Fictitious Competition
Do not advertise job if outcome:
- predetermined.
N.365No Political Loyalty Requirement for Professional Staff
No.
N.366City Manager
Must serve:
- institution.
N.367Not campaign.
N.368Political Office Staff
If Ontario municipal law permits specific structures, define separately.
N.369Do Not Invent Unfunded Mayor's Private Office
No.
N.370Family and Related Persons
Conflict rules may extend beyond the official's direct personal interest depending on:
- applicable law;
- facts.
N.371Therefore
Do not attempt to create own legal family definition.
Use:
- current law.
N.372Governance Standard
If close family member could materially benefit:
Seek:
- conflict advice.
N.373Family Business
High concern.
N.374Family Employment
High concern.
N.375Family Property
Potential concern.
N.376Ordinary Citywide Benefit
Different.
N.377Do Not Treat Every General Policy as Family Conflict
No.
N.378But
Do not hide specific benefit inside:
- broad policy.
N.379Related Company
Look through:
- holding company;
- nominee;
- partnership;
where law requires.
N.380Ownership Disclosure
Sufficient to permit proper advice.
N.381No Hidden Beneficial Interest
N.382Private Meetings
Mayor will meet:
- businesses;
- developers;
- residents;
- investors;
- nonprofits.
That is normal.
N.383Meeting Itself Is Not Improper
No.
N.384But
Founder-associated opportunity creates boundary issue.
N.385Municipal Meeting Register
For material external meetings involving:
- procurement;
- development;
- major City business;
a public meeting register could improve transparency where lawful.
N.386Proposed Fields
Date
Organization
General Topic
Municipal Participants
N.387Do Not Publish
- confidential negotiations;
- personal resident cases;
- security matters.
N.388Private-Business Meeting
Keep separate.
N.389If Person Meets Mayor Because of Office
Treat as:
- municipal relationship.
N.390If They Also Want Private Product
Do not pivot casually.
N.391Say
That is a private matter and should be scheduled separately.
N.392Lobbying
If City establishes lobbying registry:
Apply equally.
N.393No Founder Exemption
N.394No Opponent Penalty
N.395Access
Mayor should not give preferred vendors:
- secret access.
N.396But
Mayor must be able to hear:
- ideas.
N.397Listening Is Not Procurement
Correct.
N.398Meeting Is Not Commitment
Correct.
N.399"Send it to staff"
Can be proper.
N.400But
Staff should evaluate:
- independently.
N.401No "I Already Promised Them"
No.
N.402Developer Meeting
Same.
N.403Investor Meeting
Same.
N.404Community Organization
Same.
N.405Open Door
Good.
N.406Favouritism
Not.
N.407Private Real-Estate Work
If Mayor remains involved in private real estate:
Establish additional practical boundaries.
N.408City Development Information
Confidential information obtained through office must not be used for:
- private client advantage.
N.409Upcoming Municipal Land Sale
No private use.
N.410Confidential zoning discussion
No private use.
N.411Infrastructure timing
If non-public and material:
No private use.
N.412Development lead
No private brokerage solicitation.
N.413Resident property issue
No private client recruitment.
N.414City Introduces Business
No automatic private lead.
N.415Private Brokerage Client
If requires City service:
Use normal:
- public process.
N.416No Fast Lane
No.
N.417No Slow Lane for Competitor
No.
N.418Planning Staff
Must not be asked to:
- prioritize Mayor's private client;
outside normal lawful process.
N.419Mayor Can Advocate for Better System
For everyone.
N.420Not Queue-Jump for Specific Client
N.421Private Property Owned by Mayor
Municipal service should be:
- ordinary service.
N.422Permit
Ordinary process.
N.423Inspection
Ordinary process.
N.424Tax
Ordinary process.
N.425Enforcement
Ordinary process.
N.426No Special Access
N.427No Special Punishment
N.428Firewalls Protect Mayor Too
Yes.
N.429Complaint
If someone alleges private benefit:
There should be:
- records;
- independent process;
to answer.
N.430Campaign Branding
Campaign slogan should remain:
- campaign.
N.431City Strategic Plan
Should not simply adopt campaign slogan as:
- taxpayer-funded incumbent branding.
N.432Campaign Policy
Can become municipal proposal.
N.433But It Must Go Through
- staff;
- Council;
- public;
- legal;
- financial;
process as appropriate.
N.434"It Was My Platform"
Not authority.
N.435Election Mandate
Politically relevant.
N.436But
Does not erase:
- Council;
- law;
- procurement;
- evidence.
N.437City Communications
Should describe adopted policy as:
City policy
not:
Mayor's campaign promise
after lawful adoption.
N.438Credit
Can acknowledge origin where relevant.
N.439But Public Asset Belongs to
- City.
N.440Public Playbook
If initiative developed publicly:
Other municipalities should be able to reuse where intended.
N.441No Hidden Founder Licence
If public playbook says:
- open.
N.442Campaign Photos
Do not become official City photo library automatically.
N.443City Photos
Do not become campaign library automatically under current resource policy. Owen Sound's current election policy specifically prohibits use of City-created photographic and video material in campaign materials.
N.444Personal Photo
Different.
N.445Publicly Available City Fact
Campaign may discuss:
- public facts.
N.446City Staff Draft
Do not ask staff to:
- write campaign rebuttal.
N.447Campaign Fact Check
Campaign pays / performs.
N.448City Correction
If official City information is wrong:
City corrects for everyone.
N.449Incumbent Criticism
City communications should not become:
- political defence shop.
N.450Staff Can Correct False Statement About City Operations
Through neutral:
- factual;
- institutional;
communication.
N.451Not Personal Attack
N.452Press Office Firewall
Communications staff should distinguish:
Municipal information request
from
campaign media request.
N.453Reporter Asks About City Policy
Municipal.
N.454Reporter Asks Why Candidate Deserves Re-Election
Campaign.
N.455Reporter Asks About Private Company
Private.
N.456Mixed Question
Separate answers.
N.457Contact Channels
Provide correct:
- municipal;
- campaign;
- private;
contact.
N.458No Staff Answering Campaign Phone
No.
N.459No Campaign Volunteer Answering City Phone
No.
N.460Municipal Newsletter
No campaign ask.
N.461No "Vote for"
Obvious.
N.462No Subtle Incumbent Promotion
Election-period resource policy should be interpreted and followed according to:
- current policy;
- Clerk advice.
N.463Official Achievements
Government still has obligation to communicate:
- services;
- decisions.
N.464Election Does Not Shut Down Government
Correct.
N.465Distinction
Communicate:
- institutional fact.
Avoid:
- campaign persuasion.
N.466Election-Year Work
Should continue where:
- ordinary;
- necessary;
- previously planned;
- responsibly approved.
N.467Do Not Stop Infrastructure Repair Because Election
No.
N.468Do Not Accelerate Ribbon Cutting Because Election
No.
N.469Do Not Delay Bad News Until After Election
No.
N.470Do Not Rush Good News Before Verification
No.
N.471Strong-Mayor Election Transition
Current Ontario regulation imposes specific election-period restrictions on certain mayoral powers once defined electoral conditions are met. The municipal firewall should incorporate those rules into the election-transition checklist rather than relying on memory.
N.472Election Transition Checklist
Strong-mayor restrictions checked
Resource policy active
Staff communications guidance issued
Campaign contacts separated
Municipal accounts secured
Conflict-sensitive files independently assigned
N.473Candidate Incumbency
Incumbent may still:
- govern.
N.474Challenger Equality
City should not provide incumbent with candidate services unavailable to:
- challengers.
N.475City Election Information
Neutral.
N.476Current Candidate Information
Owen Sound's 2026 candidate materials explicitly state that the City does not endorse or support any candidate.
N.477Keep That Principle
Beyond candidate listing.
N.478Third-Party Groups
City should not coordinate campaign activity with:
- registered third parties.
N.479Candidate
Likewise.
N.480Private Business Advocacy
Issue advocacy and election advertising can engage different rules.
Seek:
- election-law review;
where related private entities participate.
N.481No Corporate Back Door
Core.
N.482Donations and Sponsorships During Election Year
Extra scrutiny.
N.483Municipal Sponsor
Should not become:
- incumbent advertiser.
N.484Private Founder Company Sponsor
Avoid heightened conflict where possible.
N.485City-Funded Event
No campaign stage.
N.486Candidate Debate
Different.
May be hosted under:
- neutral election process.
N.487Equal Invitation Rules
Where relevant.
N.488City Facility
Use ordinary terms.
N.489Campaign Event
Current City policy permits ordinary facility use under standard agreements and fees while maintaining resource restrictions.
N.490Municipal Equipment
No campaign use.
N.491Municipal Vehicle
No campaign use.
N.492City Uniform
No campaign staging where policy prohibits or creates endorsement impression.
N.493Public Asset
Campaign may use public space only under:
- same lawful rules;
as others.
N.494Campaign Sign
Separate by-law.
N.495Real-Estate Sign Reform
Do not combine with:
- campaign sign advantage.
N.496Policy Independence
Critical.
N.497Private-to-Public Asset Transfer
If founder wishes to donate private IP to City:
Donation still needs:
- due diligence.
N.498Why
Gift can carry:
- maintenance;
- liability;
- licensing;
- privacy;
- security;
- third-party rights.
N.499Donation Does Not Cure Conflict
No.
N.500$1 Sale
Same.
N.501$0 Licence
Same.
N.502Independent Acceptance Review
Required for material founder-associated gift.
N.503Questions
Do we need it?
Who owns it?
Are rights clear?
What liabilities attach?
What does maintenance cost?
Can City modify it?
Can City share it?
Can City abandon it?
N.504No Ceremonial Donation
Before review.
N.505Transfer Before Adoption
Could reduce conflict.
N.506But
Only if transfer is:
- genuine;
- complete;
- independently verified.
N.507Founder Retained Royalty
Means private interest remains.
N.508Founder Retained Control Right
Means private interest remains.
N.509Founder Retained Veto
Means private interest remains.
N.510Founder Retained Exclusive Commercialization
Means private interest may remain.
N.511Public Ownership Claim
Must match:
- legal documents.
N.512No "Community-Owned" Marketing
Unless governance actually reflects:
- community/public ownership.
N.513Independent Nonprofit
Must be genuinely independent.
N.514Founder Appoints Majority Forever
Not independent.
N.515Founder Veto
Not independent.
N.516Board Filled With Campaign Team
Not convincingly independent.
N.517Governance Independence Test
Who appoints?
Who removes?
Who votes?
Who owns assets?
Who controls budget?
Who benefits?
Who can amend bylaws?
N.518Public Benefit Corporation / Nonprofit
Legal form alone does not guarantee:
- independence.
N.519Governance Substance
Matters.
N.520Data and Private Platforms
No founder-associated private platform should obtain:
- preferred municipal access to non-public data.
N.521Public Data
Can be open to:
- everyone;
under same terms.
N.522Protected Data
No.
N.523Early Access
Can create:
- commercial advantage.
N.524Embargoed Data
No founder preference.
N.525Draft City Data
No.
N.526Resident Feedback
No.
N.527Business Registration Data
No.
N.528Tender Information
No.
N.529Upcoming Land Decision
No.
N.530Confidential Development Information
No.
N.531Municipal Analytics
No private use.
N.532AI Training
City data should not train founder-associated commercial AI without:
- explicit lawful agreement;
- procurement / valuation;
- privacy review.
N.533Public Open Data
Could be used like anyone else.
N.534Private Platform User Data
City should not receive:
- private user behaviour;
merely because founder is Mayor.
N.535"Helpful Insight"
Still data transfer.
N.536Aggregate Public Insight
Could be provided under:
- neutral methodology.
N.537Personal Data
No.
N.538Data Sharing Agreement
Does not cure conflict alone.
N.539Independent Need
First.
N.540MFIPPA
Municipal personal information remains governed by Ontario's municipal freedom-of-information and privacy framework.
N.541Campaign List
Not exempt from election / privacy responsibility because:
- privately maintained.
N.542Data Minimization
Appendix J.
N.543Records
Conflict-related municipal decisions should be:
- documented.
N.544But
Do not create unnecessary public record of:
- private unrelated information.
N.545Conflict File
Maintain appropriate:
- declarations;
- advice;
- decisions;
- recusals;
- procurement records.
N.546Privileged Advice
Protect.
N.547Public Explanation
Where possible:
Explain:
- conflict;
- safeguard;
- decision;
without revealing privileged details.
N.548Recusal Record
Clear.
N.549Current Owen Sound Practice
The City's accountability page maintains an index of written pecuniary-interest declarations and notes the current legal requirement for written statements of an interest and its general nature.
N.550Additional Founder-Sensitive Register
Could publicly identify:
File
Related Interest
Mayor Participation Status
Independent File Owner
Review Status
N.551Do Not Publish
- confidential commercial detail;
- legal advice.
N.552Public Should Know
Who is making the decision?
N.553Conflict Does Not Require Project Disappearance
Sometimes project can proceed through:
- independent route.
N.554Sometimes
Project should stop.
N.555Sometimes
Private asset should transfer.
N.556Sometimes
Open competition solves.
N.557Sometimes
Independent nonprofit solves.
N.558Sometimes
No lawful or credible firewall exists.
N.559Then
Do not proceed.
N.560Conflict Risk Levels
For internal governance:
Level 0 - No Known Private Connection
Level 1 - Remote / General Connection
Level 2 - Material Appearance or Relationship
Level 3 - Direct Private Interest
Level 4 - Direct Financial Interest in Proposed Municipal Transaction
N.561This Is Governance Tool
Not legal classification.
N.562Statutory Conflict Still Determined Under Law
Yes.
N.563Level 0
Normal process.
N.564Level 1
Disclosure if appropriate.
N.565Level 2
Independent screening.
N.566Level 3
Likely recusal / independent file ownership subject to legal advice.
N.567Level 4
Maximum safeguards and legal review.
N.568Do Not Self-Assign Lower Level
Independent review for founder-sensitive file.
N.569Independent File Owner
Should receive authority to:
- communicate with supplier;
- select reviewers;
- manage procurement;
- report to proper decision-maker.
N.570Mayor Should Not Receive Confidential Updates
If legally recused from:
- matter.
N.571Public Information
Mayor can receive like:
- public;
- Council member;
only as law permits.
N.572No Informal Text Messages
To file owner.
N.573No "Just Curious"
Back channel.
N.574No Proxy Influence
Through:
- colleague;
- staff;
- family;
- advisor;
- campaign volunteer.
N.575MCIA Head-of-Council Rule
Ontario's current statute expressly addresses attempts by a head of council with a pecuniary interest to use office to influence municipal decisions relating to specified mayoral powers.
N.576Recusal Scope
Follow exact legal advice.
N.577Do Not Invent Rule
No.
N.578Integrity Commissioner Advice
Use early.
N.579Advice Before Decision
Better than:
- investigation after.
N.580Written Advice
Where appropriate.
N.581Facts Supplied
Must be complete.
N.582Do Not Omit
- ownership;
- royalties;
- family interests;
- prior agreements;
where material.
N.583Advice Can Become Stale
If facts change.
N.584Re-ask.
N.585Provincial Reform
Because Ontario enacted but has not yet brought into force its 2026 municipal accountability changes, the incoming Council should recheck the Integrity Commissioner and code-of-conduct framework once the new term begins.
N.586Gifts and Benefits
Founder-sensitive procurement should avoid:
- meals;
- travel;
- hospitality;
that could complicate independence.
N.587Conference
Normal networking possible.
N.588Vendor-Paid Travel
Higher concern.
N.589City-Paid Official Travel
Municipal.
N.590Private-Company-Paid Travel
Private.
N.591Mixed Trip
Separate costs.
N.592No City Paying Private Sales Trip
No.
N.593No Private Company Paying Municipal Procurement Trip
Without appropriate:
- review.
N.594Travel Log
For material official travel:
- purpose;
- cost;
- funder.
N.595Expense
Appendix E.
N.596Private Meeting During Official Trip
If unavoidable:
Separate.
N.597City Staff
Should not attend as private sales support.
N.598Private Staff
Should not attend confidential municipal meeting without:
- proper role.
N.599Conference Booth
If private company booths:
Mayor should not staff it in apparent:
- official capacity.
N.600Title Usage
Distinguish.
N.601Private Investment
Mayor may invest.
N.602But
Cannot use non-public municipal information to:
- invest;
- trade;
- acquire property;
- advise clients.
N.603Confidential Information
Never private benefit.
N.604Land Purchase
Particularly sensitive.
N.605If City planning confidentially affects parcel
Do not use information privately.
N.606Business Purchase
Same.
N.607Technology Company Investment
Same.
N.608Former Private Activity
Pre-election activity should be documented where it later intersects:
- City.
N.609Prior Proposal to City
Disclose.
N.610Prior Negotiation
Disclose.
N.611Prior Licence
Disclose.
N.612Prior Relationship With Vendor
Disclose where material.
N.613Historic Business Dispute
Could affect appearance.
N.614Does Not automatically require:
- recusal.
N.615Seek advice.
N.616Staff Personal Interests
This appendix should also protect against staff:
- conflicts.
N.617Employee Ethics
Existing City rules apply.
N.618Procurement Staff
Declare conflicts.
N.619Developer Relationship
Declare.
N.620Vendor Family Member
Declare.
N.621No Mayor Exception
No staff exception either.
N.622Council-Wide Standard
Apply generally.
N.623But Founder-Specific Rules
Needed because:
- particular proposed municipal platforms;
create unusual overlap.
N.624Public Cannot Be Asked to Pretend That Overlap Does Not Exist
No.
N.625Better
Design around it.
N.626Complaint Process
Residents should know where to raise concerns regarding:
- member conduct;
- election resource use;
- procurement;
- employee conduct;
- privacy.
N.627Different Complaints
Different routes.
N.628Integrity Commissioner
Member conduct / conflict issues within jurisdiction.
N.629Clerk
Election administration / municipal process as applicable.
N.630Procurement
Procurement complaint process.
N.631Privacy
MFIPPA / privacy process.
N.632Employee Ethics
City employee process.
N.633No One Giant Political Complaints Office
No.
N.634Route Correctly
N.635Whistleblower Protection
Staff should have route to report:
- improper private-benefit request;
- campaign-resource misuse;
- procurement interference;
- data misuse.
N.636Without Retaliation
Critical.
N.637Anonymous Reporting
May be useful.
N.638But
Not every complaint can be investigated anonymously.
N.639Good-Faith Complaint
Protect.
N.640Malicious Complaint
Different.
N.641Criticism
Not misconduct by itself.
N.642Investigation
Independent where Mayor is:
- subject.
N.643Mayor Should Not Select Investigator
No.
N.644Mayor Should Not Set Scope
No.
N.645Mayor Should Not Receive Draft for Approval
No.
N.646Mayor Can Respond to Allegation
Yes.
N.647Procedural Fairness
Applies.
N.648Public Result
Follow legal process.
N.649No Trial by Social Media
No.
N.650No Political Exoneration by Self-Statement
No.
N.651Evidence
Appendix H.
N.652Correction
If allegation unsupported:
Say.
N.653If breach found:
Say according to lawful process.
N.654Remediation
More important than:
- spin.
N.655Procurement Remedy
Could include:
- restart;
- independent review;
- cancellation.
N.656Data Remedy
Could include:
- deletion;
- access removal;
- breach response.
N.657Communication Remedy
Could include:
- correction;
- reimbursement.
N.658Resource Misuse
Could require:
- repayment;
where applicable.
N.659Campaign Finance
Follow election law.
N.660Compliance Audit
Owen Sound participates in a Grey County joint compliance-audit framework for 2026 campaign-finance applications under the Municipal Elections Act.
N.661This Is Separate From Municipal Ethics Complaint
Yes.
N.662Do Not Mix
- election finance;
- conflict;
- procurement;
- employee conduct;
into one accusation.
N.663Specificity
Protects fairness.
N.664Post-Election Transition
If elected:
Firewall starts:
- before inauguration.
N.665Campaign Wind-Down
Campaign still has financial-reporting obligations after:
- voting day.
N.666Campaign Treasurer / Records
Remain campaign.
N.667City Finance
Not campaign bookkeeper.
N.668No City Staff Preparing Campaign Financial Statement
No.
N.669No City Auditor Doing Campaign Return as City work
No.
N.670Campaign Debt
Private campaign matter.
N.671Campaign Surplus
Election-law matter.
N.672Inauguration
Municipal event.
N.673Campaign Celebration
Campaign / private event.
N.674Keep Costs Separate
N.675Transition Team
If informal campaign transition team assists:
They do not automatically receive:
- confidential City data.
N.676Background Briefings
City decides what can be shared.
N.677Incoming Mayor
May receive official transition information according to:
- law;
- City process.
N.678Private Advisors
Not automatically.
N.679NDA
Does not create entitlement to:
- confidential City information.
N.680Municipal Appointment
Required where role requires.
N.681First 24 Hours in Office
Change:
- passwords;
- accounts;
- device;
- contact methods;
appropriately.
N.682Campaign Phone
Could remain personal.
N.683City Phone
Institutional.
N.684Contact Forwarding
Carefully designed.
N.685Residents Will Keep Using Campaign Contact
Expected.
N.686Response
Direct them to:
- official City channel;
for municipal files.
N.687Do Not Build Municipal record inside campaign inbox
No.
N.688If substantive City matter arrives there
Forward to appropriate:
- City system;
then continue municipally.
N.689Preserve record as required.
N.690First 30 Days
Create:
Conflict and Firewall Baseline.
N.691First 30-Day Actions
Obtain legal / Integrity advice on relevant private interests.
File required statutory declarations.
Publish appropriate voluntary public-interest disclosure.
Inventory founder-associated municipal proposals.
Assign independent owners to conflict-sensitive files.
Separate accounts and data.
Brief senior staff on firewall.
Confirm campaign resource separation.
N.692First 30 Days
Review:
- map.ca;
- RealMap;
- other founder IP;
and classify each:
Private Only
Potential Municipal Relevance
Independent Review Required
Not Proceeding
N.693No Assumption of Adoption
None.
N.694First 30 Days
Freeze any founder-associated municipal procurement until:
- conflict pathway confirmed.
N.695Freeze Does Not Mean Reject
It means:
- review first.
N.696First 60 Days
Publish:
Founder-Associated Initiative Review Protocol.
N.697Protocol Should Define
File owner
Legal reviewer
Procurement reviewer
Privacy reviewer
Valuation trigger
Public reporting
Mayor participation limits
N.698First 60 Days
Create:
Private / Campaign / Municipal Data Separation Checklist.
N.699First 60 Days
Review municipal websites and accounts for:
- campaign remnants;
- private links;
- unclear ownership.
N.700First 60 Days
Review official social media ownership.
N.701First 60 Days
Confirm intellectual-property boundaries.
N.702First 100 Days
Complete independent initial review of any founder-associated system the City may reasonably consider.
N.703Review Is Not Adoption
Again.
N.704First 100 Days
Publish non-privileged conclusions:
Proceed to Further Review
Compete
Transfer / Restructure
Hold
Stop
N.705First 100 Days
Establish staff escalation route.
N.706Year One
Primary objective:
Make the firewall institutional rather than dependent on personal restraint.
N.707Year One
Complete:
- disclosure;
- conflict procedures;
- independent file ownership;
- data separation;
- procurement firewall;
- IP records.
N.708Year One
Any municipal use of map.ca or RealMap should occur only after:
- required independent gates.
N.709If Gates Fail
Stop.
N.710No Sunk-Cost Argument
N.711Year Two
Audit whether firewall worked in:
- practice.
N.712Questions
Did staff receive improper private requests?
Were conflicted files independently managed?
Did founder data cross boundaries?
Were campaign accounts used for municipal business?
Were private companies given unusual access?
N.713Fix Weakness
N.714Year Two
Review private-interest disclosure for:
- changes.
N.715Year Three
Review institutionalization.
N.716Ask
Would this firewall still work if the Mayor were less careful?
N.717If No
Strengthen.
N.718Governance Should Protect Against
- good intentions failing;
- future officeholders.
N.719Year Three
Review related digital platform ownership.
N.720If municipal dependence remains on founder-controlled asset
Reassess.
N.721Year Four
Election year deserves:
- heightened firewall.
N.722Do Not Relax Because Record Is Good
No.
N.723Election-Year Review
Before nomination period / campaign period:
Resource policy
official accounts
staff guidance
event rules
City photography
municipal communications
founder-associated businesses
data separation
strong-mayor transition rules
N.724Incumbent Candidate
Should be able to run vigorous:
- campaign.
N.725But
Using:
- campaign resources.
N.726Government Continues
Using:
- municipal resources.
N.727Private Businesses Continue
Using:
- private resources.
N.728Three Systems
Remain.
N.729Four-Year Audit
Publish:
Campaign, Private Interest and Municipal Firewall Audit.
N.730Audit Should Answer
What material interests were disclosed?
What founder-associated municipal files arose?
Which were independently reviewed?
Which proceeded?
Which stopped?
Which entered procurement?
Which transferred ownership?
Which remained private?
What recusals occurred?
Were any municipal resources improperly used?
Were any data-boundary incidents identified?
Were any procurement processes restarted?
Were any staff concerns raised?
What changes followed?
N.731Do Not Publish Protected Details
No.
N.732Public Audit
Should be enough to establish:
- process integrity.
N.733Name map.ca Outcome
Clearly.
N.734Name RealMap Outcome
Clearly.
N.735Possible Outcomes
Municipally Adopted After Independent Process
Open Standard Adopted Instead
Independent Nonprofit Model
Remained Private
Not Proceeding
N.736No Face-Saving Category
No.
N.737Name Any Related Procurement
N.738Show Result
N.739Name Any Related IP Transfer
N.740State consideration
Where lawful and appropriate.
N.741Name Any Private Benefit Safeguard
N.742Name Any Firewall Failure
If one occurred.
N.743Name Remediation
N.744Election-Year Resource Review
Include.
N.745Handoff
The next Council receives:
Relevant interest disclosures
Founder-sensitive file list
Independent review records
Procurement status
Public-ownership agreements
IP agreements
Data-sharing restrictions
Recusal history
Pending conflict advice
Election-resource procedures
N.746No Conflict Surprise
Next Council should not discover:
The Mayor's company owns the software City depends upon.
N.747Or
The domain is personally owned.
N.748Or
The City cannot leave without founder permission.
N.749Or
Municipal data was copied into a private platform.
N.750Or
City staff developed private commercial IP.
N.751Or
A campaign list became the City's communications list.
N.752Or
City resident data went to campaign.
N.753Or
A municipal procurement was designed by the person financially benefiting from it.
N.754Or
Nobody documented the conflict because everybody trusted each other.
N.755Anti-Gaming Rule One
Do not say:
There is no conflict because I disclosed it.
N.756Rule Two
Do not say:
There is no conflict because City pays nothing.
N.757Rule Three
Do not say:
There is no conflict because project is good.
N.758Rule Four
Do not say:
There is no conflict because I would have done this even if I were not Mayor.
N.759Rule Five
Do not say:
There is no conflict because everyone knows I own it.
N.760Rule Six
Do not self-certify:
- absence of conflict.
N.761Rule Seven
Do not use public office to create:
- private reference customer.
N.762Rule Eight
Do not use City adoption to increase private company valuation without:
- independent review.
N.763Rule Nine
Do not call software:
free
if municipal adoption creates private commercial benefit.
N.764Rule Ten
Do not allow founder to:
- choose evaluator.
N.765Rule Eleven
Do not allow founder to:
- draft municipal evaluation criteria.
N.766Rule Twelve
Do not allow founder to:
- score competitors.
N.767Rule Thirteen
Do not allow founder to:
- negotiate with City on both sides.
N.768Rule Fourteen
Do not allow founder to:
- approve valuation.
N.769Rule Fifteen
Do not allow founder to:
- approve independence of review.
N.770Rule Sixteen
Do not use private meeting to:
- direct City file.
N.771Rule Seventeen
Do not use intermediary to:
- accomplish prohibited influence.
N.772Rule Eighteen
Do not text staff about file after:
- recusal.
N.773Rule Nineteen
Do not use Council ally to:
- pressure file.
N.774Rule Twenty
Do not use campaign volunteer as:
- unofficial City negotiator.
N.775Rule Twenty-One
Do not give donor:
- procurement preference.
N.776Rule Twenty-Two
Do not punish donor's competitor.
N.777Rule Twenty-Three
Do not hire campaign supporter because:
- loyal.
N.778Rule Twenty-Four
Do not reject qualified campaign opponent because:
- opponent.
N.779Rule Twenty-Five
Do not turn public-policy campaign mandate into:
- procurement mandate.
N.780Rule Twenty-Six
Do not write:
City shall use map.ca
before independent governance / procurement review.
N.781Rule Twenty-Seven
Do not write:
City shall use RealMap
into sign regulation.
N.782Rule Twenty-Eight
Do not create regulatory burden whose practical purpose is to force residents toward:
- founder platform.
N.783Rule Twenty-Nine
Do not make private platform a condition of:
- municipal service.
N.784Rule Thirty
Do not give private platform early access to:
- City data.
N.785Rule Thirty-One
Do not give private platform non-public data because:
- founder is trusted.
N.786Rule Thirty-Two
Do not give City private customer data because:
- founder thinks it would help.
N.787Rule Thirty-Three
Do not merge City and private analytics.
N.788Rule Thirty-Four
Do not train private commercial AI on protected City information without:
- explicit lawful process.
N.789Rule Thirty-Five
Do not train City system on private customer data without:
- proper authority.
N.790Rule Thirty-Six
Do not use City employees to:
- develop;
- market;
- support;
private business.
N.791Rule Thirty-Seven
Do not use City contractors for private work billed to:
- City.
N.792Rule Thirty-Eight
Do not use City equipment for:
- campaign;
- private business.
N.793Rule Thirty-Nine
Do not use City photography for campaign contrary to current election-resource rules.
N.794Rule Forty
Do not use City logo or branding for campaign contrary to current policy.
N.795Rule Forty-One
Do not use City email for campaign activity contrary to current policy.
N.796Rule Forty-Two
Do not use City data for campaign activity.
N.797Rule Forty-Three
Do not transfer campaign contact list into City database.
N.798Rule Forty-Four
Do not transfer City resident list into campaign database.
N.799Rule Forty-Five
Do not transfer City business directory into private sales CRM unless information is separately public and used on the same terms available to everyone.
N.800Rule Forty-Six
Do not use municipal office to obtain private sales introductions.
N.801Rule Forty-Seven
Do not use title of Mayor to imply municipal endorsement of:
- private company.
N.802Rule Forty-Eight
Do not use municipal conference as private trade show through:
- office.
N.803Rule Forty-Nine
Do not mix private invoice into:
- City expense.
N.804Rule Fifty
Do not mix City expense into:
- private business accounting.
N.805Rule Fifty-One
Do not have private company pay official municipal expense unless proper:
- sponsorship;
- reimbursement;
process exists.
N.806Rule Fifty-Two
Do not have City pay private company expense.
N.807Rule Fifty-Three
Do not accept founder-associated donation without:
- independent review.
N.808Rule Fifty-Four
Do not treat donation as cure for:
- ownership;
- conflict;
- liability.
N.809Rule Fifty-Five
Do not describe platform as publicly owned until:
- legal transfer;
- governance;
actually supports statement.
N.810Rule Fifty-Six
Do not describe nonprofit as independent if founder retains:
- effective control.
N.811Rule Fifty-Seven
Do not create board of campaign allies and call it:
- independent governance.
N.812Rule Fifty-Eight
Do not hide founder royalty.
N.813Rule Fifty-Nine
Do not hide related IP interest.
N.814Rule Sixty
Do not hide related domain ownership.
N.815Rule Sixty-One
Do not hide option, warrant or future payment.
N.816Rule Sixty-Two
Do not route payment through:
- third party;
to disguise benefit.
N.817Rule Sixty-Three
Do not use related nonprofit as:
- pass-through;
to avoid conflict.
N.818Rule Sixty-Four
Do not use unrelated-looking corporation if beneficial control remains:
- related.
N.819Rule Sixty-Five
Do not use recusal theatrically while exercising:
- back-channel influence.
N.820Rule Sixty-Six
Do not receive confidential file updates after withdrawal where law and advice prohibit involvement.
N.821Rule Sixty-Seven
Do not pressure staff who request:
- conflict review.
N.822Rule Sixty-Eight
Do not punish whistleblower.
N.823Rule Sixty-Nine
Do not direct Integrity Commissioner.
N.824Rule Seventy
Do not select investigator into your own conduct.
N.825Rule Seventy-One
Do not approve investigator's draft findings.
N.826Rule Seventy-Two
Do not dismiss complaint merely because:
- politically motivated;
without examining evidence.
N.827Rule Seventy-Three
Do not sustain complaint merely because:
- politically useful.
N.828Rule Seventy-Four
Do not conflate:
- appearance;
- statutory conflict;
- corruption.
Use precise terms.
N.829Rule Seventy-Five
Do not label lawful interest:
- corruption;
without evidence.
N.830Rule Seventy-Six
Do not minimize actual statutory conflict as:
- optics.
N.831Rule Seventy-Seven
Do not hide behind legal minimum when stronger governance safeguard is reasonably available.
N.832Rule Seventy-Eight
Do not invent stricter legal requirement than law actually imposes.
N.833Rule Seventy-Nine
Do not let conflict policy paralyze:
- ordinary governance.
N.834Rule Eighty
Use proportionality.
N.835The Three-System Test
Is this campaign, private or municipal activity?
N.836The Authority Test
What public authority is being exercised?
N.837The Private-Benefit Test
Could this decision materially increase the official's private financial or commercial position?
N.838The Appearance Test
Could a reasonable resident reasonably question the independence of the process?
N.839The Disclosure Test
Has the relevant interest been disclosed to the proper authority?
N.840The Recusal Test
Does current law or prudent governance require withdrawal?
N.841The Influence Test
After withdrawing, is the official still influencing the matter directly or indirectly?
N.842The Staff Test
Would staff feel free to disagree with the Mayor on this file?
N.843The Procurement Test
Would another supplier receive the same path?
N.844The Founder Test
Would we accept this process if the private platform belonged to a political opponent?
N.845The Reverse-Founder Test
Would we impose these same safeguards if the founder were someone we liked less?
N.846The Public-Ownership Test
Who legally owns the domain, software, IP, data and administrative control?
N.847The Windfall Test
Does municipal adoption increase a private asset's value even if no City money changes hands?
N.848The Data Test
Did information cross campaign, private or municipal boundaries?
N.849The Consent Test
Was information collected for the purpose for which it is now being used?
N.850The Staff-Resource Test
Did publicly paid staff contribute to private or campaign work?
N.851The Time Test
Was this meeting or work undertaken in a municipal, private or campaign capacity?
N.852The Account Test
Which email, device, cloud account and records system is being used?
N.853The Communications Test
Would a reasonable resident mistake this message for City endorsement of a campaign or private business?
N.854The Title Test
Is the title Mayor being used to create private commercial credibility?
N.855The Gift Test
Would City accept this gift on the same terms if it came from an unrelated business?
N.856The Appointment Test
Is this person being selected because they are best suited or because they helped the campaign?
N.857The Donor Test
Would this supplier receive the same treatment if they had donated to a different candidate?
N.858The Opponent Test
Would this resident or business receive the same service if they campaigned against the Mayor?
N.859The Confidentiality Test
Did public office provide information unavailable to ordinary market participants?
N.860The IP Test
Did public money or staff create value that remains privately owned?
N.861The Valuation Test
Who determined fair value and were they independent?
N.862The Free Test
If the City pays zero dollars, does somebody still receive material commercial value?
N.863The Exit Test
Can the City leave without the founder's permission?
N.864The Future-Mayor Test
Would we want the next Mayor to inherit the same power to benefit their own business?
N.865The Staff-Safety Test
Can a staff member flag this concern without fear?
N.866The Public Test
Could the process be explained openly without asking residents to simply trust the interested person?
N.867The Evidence Test
Can each safeguard be demonstrated through records rather than recollection?
N.868The Conflict Firewall Commitment
Owen Sound should commit to:
Maintain a hard institutional separation among campaign activity, private interests and municipal government.
Recognize that a person may lawfully be a business owner, inventor, candidate and public official while still requiring strong boundaries among those roles.
Use the Municipal Conflict of Interest Act, Municipal Act, Municipal Elections Act, MFIPPA and current City policies as the legal floor for the firewall.
Reverify the legal framework whenever Ontario changes municipal accountability law.
Recognize that Ontario enacted significant municipal accountability changes in 2026 that were not yet in force as of August 2026 and therefore require re-verification for the incoming term.
Recognize that Owen Sound is currently subject to the strong-mayor framework and that conflict safeguards must cover mayoral powers and directions as well as Council votes.
Comply with current statutory restrictions that apply when a head of council has a relevant pecuniary interest in matters involving specified mayoral powers.
Use the City's Integrity Commissioner and appropriate legal advice for conflict questions rather than allowing elected officials to self-certify compliance.
Maintain required declarations and written records.
Add a proportionate voluntary Public Interest Disclosure for significant private interests that could reasonably intersect with City business.
Keep that disclosure relevant rather than turning municipal transparency into unnecessary publication of unrelated private information.
Disclose founder roles and related interests in map.ca, RealMap and other private systems before any municipal evaluation of those systems.
Treat disclosure as the beginning of conflict management rather than automatic permission to participate.
Use recusal whenever current law requires it.
Use additional independent safeguards where appearance or institutional confidence reasonably requires them even if the exact statutory issue is broader or different.
Do not overuse recusal merely to avoid difficult political decisions.
Do not underuse recusal merely because an elected official believes personally that they can remain impartial.
Create a Campaign-to-Government Transition Protocol before inauguration.
Keep campaign staff, campaign volunteers, campaign donors and campaign endorsers separate from municipal appointments and employment unless they independently qualify through the appropriate process.
Never reward campaign activity with municipal employment, contracts or appointments.
Never punish political opponents through municipal service, contracts or appointments.
Keep campaign computers, email, websites, cloud storage and contact lists separate from municipal systems.
Keep private-company systems separate from both campaign and municipal systems.
Do not automatically forward municipal email into campaign or private accounts.
Move substantive municipal matters received through campaign channels into the official municipal record rather than continuing City business through campaign systems.
Never import campaign supporters, donors, canvass results, survey responses or political-preference information into municipal databases.
Never export resident-service information, permit contacts, business information, Civic Corps lists, seniors' contacts, Resident Pulse data or Strong Vote information to an election campaign.
Never merge private RealMap, map.ca, brokerage or other commercial customer data into municipal systems without a specific lawful municipal purpose and independent process.
Never export protected municipal data into private founder-associated platforms without lawful authority, independent review and proper agreement.
Ensure City staff work for the City rather than the Mayor personally, the campaign or the Mayor's businesses.
Never ask City staff to design, research, market, sell or support a private founder-owned product except pursuant to a lawful municipal arrangement under independent control.
Never ask City staff to prepare campaign content.
Give staff a protected way to identify requests that may cross the campaign-private-municipal boundary.
Protect employees who seek good-faith conflict review from retaliation.
Allow staff to escalate questionable requests to appropriate management, Clerk, legal or Integrity Commissioner channels.
Recognize that written mayoral direction requirements under the strong-mayor regime can strengthen accountability but do not themselves cure a conflict.
Automatically screen founder-sensitive mayoral directions for conflict before they are acted upon.
Keep the Mayor out of municipal specification, evaluation, negotiation and procurement decisions where a related private interest could benefit and the applicable legal or independent review requires separation.
Assign an independent municipal file owner to material founder-associated proposals.
Allow the Mayor to advocate for broad public policy goals such as better public mapping, property information or digital sovereignty without converting that advocacy into direction to purchase a related private product.
Separate Policy Objective from Supplier Selection.
Define the public standard first.
Allow the municipal organization and market to determine how that standard can best be delivered.
Use independent legal, procurement, privacy, cybersecurity, accessibility, financial and architecture review for material map.ca or RealMap municipal proposals.
Do not allow the founder to select all reviewers, control their scope or approve their conclusions.
Publish non-privileged findings where appropriate, including negative findings.
Do not suppress an independent recommendation merely because it would stop a founder-associated project.
Do not reject a founder-associated project merely to create an appearance of independence if it can demonstrate public value under a fair process.
Apply the same substantive standard with stronger process independence.
Require independent market evidence before claiming that only a founder-associated supplier can provide a service.
Treat prototypes as evidence of possibility rather than proof of procurement value, readiness or exclusivity.
Require a municipal business case before significant adoption.
Use independent valuation before the City purchases, licenses or receives material founder-associated intellectual property where value is significant.
Recognize that development cost, founder time and future potential are not by themselves fair market value.
Examine public ownership, open licensing and genuinely independent nonprofit structures where a founder-associated platform is intended to become public infrastructure.
Implement the original map.ca principle that protected public ownership should precede municipal adoption through actual legal governance rather than a verbal promise.
Define who owns the domain, trademarks, source code, databases, design files, accounts, administrative credentials and analytics before calling any system publicly owned.
Do not describe a system as community owned if the founder retains practical control.
Do not describe an organization as independent if the founder retains permanent veto, appointment or financial control.
Assess whether municipal adoption could create a private commercial windfall even when the City pays no money.
Recognize that municipal endorsement, reference-customer status, traffic, data and market credibility can create private value.
Do not treat Free as Conflict Free.
Do not allow City staff to become private sales references without independent authorization.
Do not use City branding to market founder-associated private products.
Require RealMap-related municipal policy to make public-policy sense even if RealMap disappeared.
Never regulate real-estate signs for the purpose of compelling use of RealMap.
Never make RealMap a municipal permit, regulatory or listing requirement without an independently justified lawful public process.
Do not reserve municipal open data to RealMap when comparable lawful access should be available under neutral terms.
Treat any map.ca pilot as a municipal pilot, not as an automatic endorsement, procurement award or permanent platform selection.
Use pre-established measures and stop conditions.
Permit a pilot to end with Stop.
Do not use public staff, public money or public information to invisibly increase the value of privately retained intellectual property.
Document pre-existing private IP before municipal development begins on a related concept.
Define ownership of new IP created through municipal work before the work begins.
Never negotiate a personal founder royalty with one's own municipality.
Use independent negotiation and valuation if a royalty or licence is legally and publicly justified.
Keep private-business meetings distinct from municipal meetings.
Avoid mixed-purpose meetings where possible.
Where a meeting changes from municipal to private subject matter, make the transition explicit or reschedule it separately.
Do not use municipal office and intergovernmental relationships as private sales channels.
Do not use a City email address, City letterhead or City staff for private business development.
Do not imply municipal endorsement through the title Mayor.
Do not give founder-owned products privileged placement in City directories, websites or events.
Apply the same neutral public-directory rules to competitors.
Maintain clear separation among municipal, campaign and private communications.
Continue to enforce Owen Sound's election-resource rules governing City branding, websites, IT, email, staff and City-created media during election periods.
Do not treat City communications staff as an incumbent political communications office.
Allow City staff to communicate accurate institutional information while keeping electoral persuasion with the campaign.
Separate official mayoral social media accounts from personal or campaign accounts.
Keep institutional account credentials under City control so public accounts survive a change of Mayor.
Do not silently convert campaign followers or account data into municipal property.
Use municipal facilities for campaign activities only according to the same lawful ordinary terms available under City policy.
Do not provide free municipal facility access, equipment or staff support to an incumbent campaign.
Apply the same lawful facility rules to challengers.
Apply heightened conflict review when a Mayor-associated business proposes to sponsor or donate to a municipal event.
Recognize that free software, equipment, consulting or hosting can still create contractual obligations, dependence or private commercial value.
Do not use campaign contributions, gifts or sponsorships as pathways to procurement advantage.
Do not penalize a supplier merely because the supplier supported another candidate.
Keep candidate campaigns legally separate from registered third-party advertisers and obtain election-law advice before any related private corporation participates in election advertising.
Never use a candidate-controlled company as an indirect campaign advertising vehicle designed to circumvent candidate campaign rules.
Keep private-company customer lists separate from candidate campaign lists unless lawful purpose and consent independently support the communication.
Never pressure private employees, contractors or clients to donate, volunteer or endorse.
Do not allow campaign volunteers or private advisors to exercise municipal authority merely because they have the Mayor's trust.
Require normal appointment, hiring, procurement and confidentiality processes before any such person receives municipal authority or access.
Apply heightened safeguards when campaign staff seek municipal employment or contracts.
Do not use strong-mayor staffing powers as a patronage system.
Use qualifications, public need and independent HR input for professional municipal appointments.
Seek conflict advice where close-family financial interests may be affected materially.
Do not invent municipal conflict law from intuition.
Do not treat every broad sectoral policy as a personal conflict merely because an elected official works in that sector.
Do not hide a specific private benefit inside a broadly framed policy.
Use transparent meeting records for material external municipal meetings where lawful and useful.
Do not turn normal mayoral accessibility to businesses and residents into secret preferential access.
Listen to ideas openly while keeping procurement and regulatory decisions independent.
Do not allow the Mayor's private real-estate interests or clients to receive accelerated municipal permits, planning decisions, inspections or service.
Do not delay a competitor's municipal matter because of private competition.
Never use confidential municipal planning, development, property, infrastructure or business information for private real-estate or investment advantage.
Keep campaign branding distinct from municipal strategic planning and City branding.
Recognize that an election mandate may create political support for a proposal but does not bypass Council, law, procurement, financial review or evidence.
Once a campaign proposal becomes duly adopted municipal policy, treat it as City policy rather than continuing to market it as an incumbent campaign product.
Do not use municipal photography, staff, websites or branding for campaign purposes contrary to Owen Sound's current election-resource policy.
Keep private-to-public asset transfers subject to due diligence even when the transfer price is one dollar or zero dollars.
Recognize that donated software, domains, land and equipment may carry substantial maintenance, legal and operational liabilities.
Use independent review before accepting material founder-associated donations.
Do not call an asset publicly owned until the legal transfer and governance actually make it so.
Do not call a nonprofit independent merely because it has been incorporated separately.
Examine appointment rights, vetoes, budgets, ownership and beneficial control.
Do not provide founder-associated private systems preferential access to non-public municipal information.
Provide open municipal data according to neutral standards where lawful.
Do not use municipal data to train commercial founder-associated AI systems without a specifically approved municipal purpose, independent process and lawful data governance.
Do not import private-platform behavioural analytics into municipal government merely because they could be interesting.
Apply MFIPPA and the City's privacy framework to municipal personal information.
Keep conflict-related municipal records sufficient to demonstrate what was disclosed, who decided, who withdrew and what independent safeguards were used.
Protect privileged and legitimately confidential material.
Provide public explanations of safeguards where doing so does not improperly disclose protected information.
Maintain the existing statutory declaration process and consider an additional public founder-sensitive file register showing independent file ownership and review status.
Recognize that conflict can sometimes be managed through independent process and sometimes requires a project to stop.
Do not force a project forward merely because significant private development effort has already been invested.
Use early Integrity Commissioner and legal advice rather than waiting for a complaint after the decision.
Supply reviewers with complete facts.
Reverify advice when material facts change.
Recheck the provincial municipal accountability framework after the enacted 2026 reforms are brought into force.
Separate official, private and campaign travel expenses.
Do not require City staff to support private commercial activity during municipal travel.
Do not privately exploit non-public municipal information concerning land, development, infrastructure, procurement or regulation.
Extend conflict safeguards to municipal staff and evaluators as well as elected officials.
Maintain clear routes for residents and staff to raise concerns through the correct Integrity Commissioner, Clerk, procurement, privacy or employee-ethics processes.
Do not turn every concern into one political complaint.
Protect good-faith staff reporting of possible private-benefit, campaign-resource, procurement or data misuse.
Use independent investigation where the Mayor is the subject of a material allegation and independence is required.
Do not allow the subject of an investigation to select the investigator, define the findings or approve the final report.
Give the subject a fair opportunity to respond.
Do not conduct ethics investigations through social media.
Use evidence and precise terminology when distinguishing appearance of conflict, statutory conflict and actual wrongdoing.
Recognize that election-finance compliance processes are separate from municipal code-of-conduct, privacy, procurement and employment processes.
Keep post-election campaign financial administration separate from City staff and City accounting.
Separate inauguration costs from campaign celebration costs.
Do not automatically provide private transition advisors with confidential municipal information.
Move municipal correspondence arriving through old campaign channels into official City systems.
Use the first 30 days to establish the Conflict and Firewall Baseline, obtain appropriate advice, publish relevant disclosure, separate data and assign independent owners to founder-sensitive files.
Use the first 60 days to publish a Founder-Associated Initiative Review Protocol and verify municipal, private and campaign accounts and intellectual-property boundaries.
Use the first 100 days to complete initial independent review of any founder-associated platform being seriously considered for municipal use.
Permit the first 100-day outcome to be Proceed, Compete, Transfer, Hold or Stop.
Use Year One to make the firewall institutional rather than dependent on personal restraint.
Use Year Two to audit whether staff, data, procurement and conflict boundaries actually worked.
Use Year Three to test whether the system would remain safe under a less careful future Mayor.
Use Year Four to apply heightened election-year resource, data and communications safeguards.
Incorporate Ontario's current election-period restrictions on specified strong-mayor powers into the transition checklist.
Publish a Four-Year Campaign, Private Interest and Municipal Firewall Audit that identifies material founder-sensitive files, independent reviews, recusals, transfers, procurements, failures and remaining risks without exposing protected information.
State clearly what ultimately happened with map.ca and RealMap rather than allowing their status to remain ambiguous.
Give the next Council all ownership agreements, independent reviews, procurement records, conflict-sensitive file records and pending issues needed to understand the City's relationship with any founder-associated system.
Never leave the next Council dependent on the former Mayor's personal permission, passwords, domains, relationships or recollection.
Never allow public office to become a private distribution channel, procurement advantage, data source or ownership shortcut.
Apply the final firewall test to every material overlap: Is this campaign, private or municipal activity, what public authority is being used, who could benefit privately, who independently controls the municipal process, what information crossed the boundary, and would we accept the same arrangement if the private interest belonged to a political opponent?
The firewall can therefore be reduced to twelve rules:
Three systems: campaign, private, municipal.
Never merge the data.
Never merge the staff.
Never merge the money.
Never use public power for private sales.
Disclose relevant interests.
Recuse when required.
Remove the interested person from control of the evaluation process.
Value private assets independently.
Public ownership must be real ownership.
Protect staff who question the boundary.
Use the political-opponent test every time.
The objective is not to prevent:
- inventors from serving;
- business owners from serving;
- entrepreneurs from becoming Mayor;
- good private ideas from becoming public solutions.
That would make municipal government poorer.
The objective is to ensure that when those worlds intersect:
the public receives the benefit without surrendering the integrity of the public process.
The strongest protection is not a promise that the Mayor is:
- trustworthy.
It is a system that does not require residents to gamble on:
- personal trust.
A trustworthy person should welcome that system.
A future untrustworthy person should be constrained by it.
That is the test of good governance.
Public office must never become a private distribution channel, procurement advantage, data source or ownership shortcut. Disclose the interest. Separate the systems. Protect the staff. Independentize the decision. Keep the record. Apply the same rules even when the private idea is your own.