Conclusion: As per agreement between CoW and SLWC, the City does have a financial arrangement, an alternative revenue source, with SLWC which will be paid annually to CoW as a percentage of revenue from warranty products collected from homeowners. This financial arrangement was made public via a report presented to the Council. In the future, the City may wish to make such references clearer in City or SLWC communications.

Allegation #7:

The City of Windsor has shared personal information with this company and that is not appropriate.

Procedures and results:

	Procedure	Results
7.1	Has the City provided personal information to the company?	IA inquired with management whether CoW has provided citizens’ contact details to other parties, mainly SLWC. Management indicated that CoW only provided the list of postal codes to SLWC that fall within the boundaries of the CoW. Management understands that SLWC purchased addresses from a third party.The CoW checked/reviewed the list purchased by SLWC and removed any addresses within those postal codes which did not fall within the City of Windsor boundaries. While the CoW also noticed that the list purchased was incomplete the City did not add anything nor assist SLWC in any other manner based on the legal advice received from City legal team.
		IA inspected the email communication and exchange of lists between CoW and SLWC. In addition, inspected internal email communication between City management and the City legal department.

Conclusion: We detected no evidence to support that the City of Windsor shared personally identifiable private information with SLWC.