PRIVACY POLICY
For not-for-profit organizations in Ontario, the privacy of personal information is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA). This Policy is based on the standards required by PIPEDA as interpreted by the Club
Defini0ons
1. The following terms have these meanings in this Policy:
a) “Commercial Activity” – any particular transaction, act or conduct that is of a commercial
character.
b) “Club” – Sail Georgian Bay
c) “Personal Information” – any information about an individual that relates to the person’s
personal characteristics including, but not limited to: gender, age, income, home address, home
phone number, ethnic background, family status, health history, and health conditions
d) “Stakeholder” – Individuals employed by, or engaged in activities on behalf of, Club including: coaches, staff members, contract personnel, volunteers, managers, administrators, committee
members, and directors and officers of the Organization
e) “Member” - All categories of membership defined in the Club’s Constitution and Bylaws as well
as all individuals employed by, or engaged in activities with, the Club including, but not limited to, athletes, coaches, convenors, officials, volunteers, managers, administrators, committee members, and directors and officers of the Club
Purpose
2. The Club recognizes Stakeholder and Members’ right to privacy with respect to their Personal Information. This Policy describes the way that the Club collects, uses, safeguards, discloses, and disposes of Personal Information.
Application of this Policy
3. This Policy applies to all Stakeholders and Members in connection with personal information that is collected, used or disclosed during Club activity.
4. Except as provided in PIPEDA, the Club’s Board of Directors will have the authority to interpret any provision of this Policy that is contradictory, ambiguous, or unclear.
Obligations
5. The Club is obligated to follow and abide by PIPEDA in all managers involving the collection, use, and disclosure of Personal Information.
6. In addition to fulfilling the legal obligations required by PIPEDA, Club Stakeholders will not:
a) Publish, communicate, divulge, or disclose to any unauthorized person, firm, corporation, or
third party any Personal Information without the express written consent of the Member
b) Knowingly place themselves in a position where they are under obligation to any organization to
disclose Personal Information
c) In the performance of their official duties, disclose Personal Information to family members,
friends, colleagues, or organizations in which their family members, friends, or colleagues have
an interest
d) Derive personal benefit from Personal Information that they have acquired during the course of
fulfilling their duties with the Club
e) Accept any gift or favour that could be construed as being given in anticipation of, or in
recognition for, the disclosure of Personal Information
Accountability
7. The Privacy Officer is responsible for the implementation of this policy and monitoring information collection and data security, and ensuring that all staff receives appropriate training on privacy issues and their responsibilities. The Privacy Officer also handles personal information access requests and complaints. The Privacy Officer may be contacted at the following address:
Sail Georgian Bay
PO Box 3253 Meaford, Ontario, N4L 1A5 [email protected]
8. Du;es - The Privacy Officer will:
a) Implement procedures to protect personal information
b) Establish procedures to receive and respond to complaints and inquiries
c) Record all persons having access to personal information
d) Ensure any third party providers abide by this policy
e) Train and communicate to staff information about Club’s privacy policies and practices.
Identifying Purposes
9. The Club may collect Personal Information from Members and prospective Members for purposes that include, but are not limited to:
Communications
a) Sending communications in the form of e-news or a newsletter with content related to Club programs, events, fundraising, activities, discipline, appeals, and other pertinent information
b) Publishing ar;cles, media rela;ons and pos;ngs on the Club website, displays or posters
c) Award nomina;ons, biographies, and media rela;ons
d) Communica;on within and between Stakeholders and Members
e) Discipline results and long term suspension list
f) Checking residency status
Registra5on, Database Entry and Monitoring
g) Registra;on of programs, events and ac;vi;es
h) Database entry at the Coaching Associa;on of Canada and to determine level of coaching
cer;fica;on coaching qualifica;ons and coach selec;on.
i) Database entry to determine level of officia;ng cer;fica;on and qualifica;ons
j) Determina;on of eligibility, age group and appropriate level of play/compe;;on
k) Player Registra;on, oubicng uniforms, and various components of athlete and team selec;on
l) Technical monitoring, officials training, educa;onal purposes, sport promo;on, and media
publica;ons
Sales, Promo5ons and Merchandising
m) Purchasing equipment, coaching manuals, resources and other products n) Promo;on and sale of merchandise
General
o) Travel arrangement and administra;on
p) Implementa;on of the Club screening program
q) Medical emergency, emergency contacts or reports rela;ng to medical or emergency issues
r) Determina;on of membership demographics and program wants and needs
s) Managing insurance claims and insurance inves;ga;ons
t) Video recording and photography for personal use, and not commercial gain, by spectators,
parents and friends
u) Video recording and photography for promo;onal use, marke;ng and adver;sing by the Club
v) Payroll, honorariums, company insurance and health plans
10. The Club’s Stakeholders may collect Personal Informa;on from Members and prospec;ve Members for other purposes, provided that documented consent specifying the use of the Personal Informa;on is obtained from the Members or prospec;ve Members.
Consent
11. By providing Personal Informa;on to the Club, Members are implying their consent to the use of that Personal Informa;on for the purposes iden;fied in the Iden0fying Purposes sec;on of this Policy.
12. At the ;me of the collec;on of Personal Informa;on and prior to the use or disclose of the Personal Informa;on, the Club will obtain consent from Members by lawful means. The Club may collect Personal Informa;on without consent when it is reasonable to do so and permiGed by law.
13. In determining whether to obtain wriGen or implied consent, the Club will take into account the sensi;vity of the Personal Informa;on, as well the Members’ reasonable expecta;ons. Members may consent to the collec;on and specified use of Personal Informa;on in the following ways:
a) Comple;ng and/or signing an applica;on form
b) Checking a check box, or selec;ng an op;on (such as ‘Yes’ or ‘I agree’)
c) Providing wriGen consent either physically or electronically
d) Consen;ng orally in person
e) Consen;ng orally over the phone
14. The Club will not, as a condi;on of providing a product or service, require Members to consent to the use, collec;on, or disclosure of Personal Informa;on beyond what is required to fulfill the specified purpose of the product or service.
15. A Member may withdraw consent in wri;ng, at any ;me, subject to legal or contractual restric;ons. The Club will inform the Member of the implica;ons of withdrawing consent.
16. The Club will not obtain consent from Members who are minors, seriously ill, or mentally incapacitated. Consent from these individuals will be obtained from a parent, legal guardian, or a person having power of aGorney.
17. The Club is not required to obtain consent for the collec;on of Personal Informa;on, and may use Personal Informa;on without the Member’s knowledge or consent, only if:
a) It is clearly in the Member’s interests and the opportunity for obtaining consent is not available
in a ;mely way
b) Knowledge and consent would compromise the availability or accuracy of the Personal
Informa;on and collec;on is required to inves;gate a breach of an agreement or a
contraven;on of a federal or provincial law
c) An emergency threatens a Member’s life, health, or security
d) The informa;on is publicly available as specified in PIPEDA
18. The Club is also not required to obtain consent for the collec;on of Personal Informa;on if the informa;on is for journalis;c, ar;s;c, or literary purposes.
19. The Club may disclose Personal Informa;on without the Member’s knowledge or consent only:
a) To a lawyer represen;ng the Club
b) To collect a debt that the Member owes to the Club
c) To comply with a subpoena, a warrant, or an order made by a court or other body with
appropriate jurisdic;on
d) To a government ins;tu;on that has requested the informa;on and iden;fied its lawful
authority, if that government ins;tu;on indicates that disclosure is for one of the following purposes: enforcing or carrying out an inves;ga;on, gathering intelligence rela;ng to any federal, provincial, or foreign law, na;onal security or the conduct of interna;onal affairs, or administering any federal or provincial law
e) To an inves;ga;ve body named in PIPEDA or a government ins;tu;on, if the Club believes the Personal Informa;on concerns a breach of an agreement, contravenes a federal, provincial, or foreign law, or if Club suspects the Personal Informa;on relates to na;onal security or the conduct of interna;onal affairs
f) To an inves;ga;ve body for purposes related to the inves;ga;on of a breach of an agreement or a contraven;on of a federal or provincial law
g) In an emergency threatening an Member’s life, health, or security (the Club will inform the Member of the disclosure)
h) To an archival ins;tu;on
i) 20 years a[er the individual's death or 100 years a[er the record was created
j) If it is publicly available as specified in PIPEDA
k) If otherwise required by law
Accuracy, Reten0on, and Openness
20. In order to minimize the possibility that inappropriate Personal Informa;on may be used to make a decision about a Member, Personal Informa;on will be accurate, complete, and as up-to-date as is necessary for the purposes for which it will be used.
21. Personal Informa;on will be retained as long as reasonably necessary to enable par;cipa;on in Club programs, events, and ac;vi;es, and in order to maintain historical records as may be required by law or by governing organiza;ons.
22. The Club’s Stakeholders will be made aware of the importance of maintaining the confiden;ality of Personal Informa;on.
23. Personal Informa;on will be protected against loss or the[, unauthorized access, disclosure, copying, use, or modifica;on by security safeguards appropriate to the sensi;vity of the Personal Informa;on.
24. Personal Informa;on that has been used to make a decision about a Member will be maintained for a minimum of one year in order to allow the individual the opportunity to access the Personal Informa;on a[er the decision has been made.
25. The Club will make the following informa;on available to Members:
a) This Privacy Policy
b) Any addi;onal documenta;on that further explains the Club’s Privacy Policy
c) The name or ;tle, and the address, of the person who is accountable for the Club’s Privacy
Policy
d) The means of gaining access to Personal Informa;on held by the Club
e) A descrip;on of the type of Personal Informa;on held by the Club, including a general account
of its use
f) Iden;fica;on of any third par;es to which Personal Informa;on is made available
Access
26. Upon wriGen request, and with assistance from the Club a[er confirming the Member’s iden;ty, Members may be informed of the existence, use, and disclosure of their Personal Informa;on and will be given access to that Personal Informa;on. Members are also en;tled to be informed of the source of the Personal Informa;on, and provided with an account of third par;es to which the Personal Informa;on has been disclosed.
27. Unless there are reasonable grounds to extend the ;me limit, requested Personal Informa;on will be disclosed to the Member, at no cost to the Member, within thirty (30) days of receipt of the wriGen request.
28. Members may be denied access to their Personal Informa;on if the informa;on:
a) Is prohibi;vely costly to provide
b) Contains references to other individuals
c) Cannot be disclosed for legal, security, or commercial proprietary purposes
d) Is subject to solicitor-client privilege or li;ga;on privilege
29. If the Club refuses a request for Personal Informa;on, it shall inform the Member the reasons for the refusal and iden;fy the associated provisions of PIPEDA that support the refusal.
Compliance Challenges
30. Members are able to challenge the Club for its compliance with this Policy.
31. Upon receipt of a complaint, the Club will:
a) Record the date the complaint is received
b) No;fy the Privacy Officer who will serve in a neutral, unbiased capacity to resolve the
complaint;
c) Acknowledge receipt of the complaint by way of telephone conversa;on and clarify the nature
of the complaint within seven (7) days of receipt of the complaint
a) Appoint an inves;gator using the Club’s personnel or an independent inves;gator, who will have
the skills necessary to conduct a fair and impar;al inves;ga;on and will have unfeGered access
to all file and personnel
d) Upon comple;on of the inves;ga;on and within thirty (30) days of receipt of the complaint, the
inves;gator will submit a wriGen report to the Club
e) No;fy the complainant the outcome of the inves;ga;on and any relevant steps taken to rec;fy
the complaint, including any amendments to policies and procedures
32. The Club will not dismiss, suspend, demote, discipline, harass, or otherwise disadvantage any Club Member or Stakeholder who:
a) Challenges the Club for its compliance with this Policy
b) Refuses to contravene this Policy or PIPEDA
c) Takes precautions to be compliant with this Policy and/or PIPEDA; even though said precau;ons may be in opposi;on to the regular du;es performed by the Member
For not-for-profit organizations in Ontario, the privacy of personal information is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA). This Policy is based on the standards required by PIPEDA as interpreted by the Club
Defini0ons
1. The following terms have these meanings in this Policy:
a) “Commercial Activity” – any particular transaction, act or conduct that is of a commercial
character.
b) “Club” – Sail Georgian Bay
c) “Personal Information” – any information about an individual that relates to the person’s
personal characteristics including, but not limited to: gender, age, income, home address, home
phone number, ethnic background, family status, health history, and health conditions
d) “Stakeholder” – Individuals employed by, or engaged in activities on behalf of, Club including: coaches, staff members, contract personnel, volunteers, managers, administrators, committee
members, and directors and officers of the Organization
e) “Member” - All categories of membership defined in the Club’s Constitution and Bylaws as well
as all individuals employed by, or engaged in activities with, the Club including, but not limited to, athletes, coaches, convenors, officials, volunteers, managers, administrators, committee members, and directors and officers of the Club
Purpose
2. The Club recognizes Stakeholder and Members’ right to privacy with respect to their Personal Information. This Policy describes the way that the Club collects, uses, safeguards, discloses, and disposes of Personal Information.
Application of this Policy
3. This Policy applies to all Stakeholders and Members in connection with personal information that is collected, used or disclosed during Club activity.
4. Except as provided in PIPEDA, the Club’s Board of Directors will have the authority to interpret any provision of this Policy that is contradictory, ambiguous, or unclear.
Obligations
5. The Club is obligated to follow and abide by PIPEDA in all managers involving the collection, use, and disclosure of Personal Information.
6. In addition to fulfilling the legal obligations required by PIPEDA, Club Stakeholders will not:
a) Publish, communicate, divulge, or disclose to any unauthorized person, firm, corporation, or
third party any Personal Information without the express written consent of the Member
b) Knowingly place themselves in a position where they are under obligation to any organization to
disclose Personal Information
c) In the performance of their official duties, disclose Personal Information to family members,
friends, colleagues, or organizations in which their family members, friends, or colleagues have
an interest
d) Derive personal benefit from Personal Information that they have acquired during the course of
fulfilling their duties with the Club
e) Accept any gift or favour that could be construed as being given in anticipation of, or in
recognition for, the disclosure of Personal Information
Accountability
7. The Privacy Officer is responsible for the implementation of this policy and monitoring information collection and data security, and ensuring that all staff receives appropriate training on privacy issues and their responsibilities. The Privacy Officer also handles personal information access requests and complaints. The Privacy Officer may be contacted at the following address:
Sail Georgian Bay
PO Box 3253 Meaford, Ontario, N4L 1A5 [email protected]
8. Du;es - The Privacy Officer will:
a) Implement procedures to protect personal information
b) Establish procedures to receive and respond to complaints and inquiries
c) Record all persons having access to personal information
d) Ensure any third party providers abide by this policy
e) Train and communicate to staff information about Club’s privacy policies and practices.
Identifying Purposes
9. The Club may collect Personal Information from Members and prospective Members for purposes that include, but are not limited to:
Communications
a) Sending communications in the form of e-news or a newsletter with content related to Club programs, events, fundraising, activities, discipline, appeals, and other pertinent information
b) Publishing ar;cles, media rela;ons and pos;ngs on the Club website, displays or posters
c) Award nomina;ons, biographies, and media rela;ons
d) Communica;on within and between Stakeholders and Members
e) Discipline results and long term suspension list
f) Checking residency status
Registra5on, Database Entry and Monitoring
g) Registra;on of programs, events and ac;vi;es
h) Database entry at the Coaching Associa;on of Canada and to determine level of coaching
cer;fica;on coaching qualifica;ons and coach selec;on.
i) Database entry to determine level of officia;ng cer;fica;on and qualifica;ons
j) Determina;on of eligibility, age group and appropriate level of play/compe;;on
k) Player Registra;on, oubicng uniforms, and various components of athlete and team selec;on
l) Technical monitoring, officials training, educa;onal purposes, sport promo;on, and media
publica;ons
Sales, Promo5ons and Merchandising
m) Purchasing equipment, coaching manuals, resources and other products n) Promo;on and sale of merchandise
General
o) Travel arrangement and administra;on
p) Implementa;on of the Club screening program
q) Medical emergency, emergency contacts or reports rela;ng to medical or emergency issues
r) Determina;on of membership demographics and program wants and needs
s) Managing insurance claims and insurance inves;ga;ons
t) Video recording and photography for personal use, and not commercial gain, by spectators,
parents and friends
u) Video recording and photography for promo;onal use, marke;ng and adver;sing by the Club
v) Payroll, honorariums, company insurance and health plans
10. The Club’s Stakeholders may collect Personal Informa;on from Members and prospec;ve Members for other purposes, provided that documented consent specifying the use of the Personal Informa;on is obtained from the Members or prospec;ve Members.
Consent
11. By providing Personal Informa;on to the Club, Members are implying their consent to the use of that Personal Informa;on for the purposes iden;fied in the Iden0fying Purposes sec;on of this Policy.
12. At the ;me of the collec;on of Personal Informa;on and prior to the use or disclose of the Personal Informa;on, the Club will obtain consent from Members by lawful means. The Club may collect Personal Informa;on without consent when it is reasonable to do so and permiGed by law.
13. In determining whether to obtain wriGen or implied consent, the Club will take into account the sensi;vity of the Personal Informa;on, as well the Members’ reasonable expecta;ons. Members may consent to the collec;on and specified use of Personal Informa;on in the following ways:
a) Comple;ng and/or signing an applica;on form
b) Checking a check box, or selec;ng an op;on (such as ‘Yes’ or ‘I agree’)
c) Providing wriGen consent either physically or electronically
d) Consen;ng orally in person
e) Consen;ng orally over the phone
14. The Club will not, as a condi;on of providing a product or service, require Members to consent to the use, collec;on, or disclosure of Personal Informa;on beyond what is required to fulfill the specified purpose of the product or service.
15. A Member may withdraw consent in wri;ng, at any ;me, subject to legal or contractual restric;ons. The Club will inform the Member of the implica;ons of withdrawing consent.
16. The Club will not obtain consent from Members who are minors, seriously ill, or mentally incapacitated. Consent from these individuals will be obtained from a parent, legal guardian, or a person having power of aGorney.
17. The Club is not required to obtain consent for the collec;on of Personal Informa;on, and may use Personal Informa;on without the Member’s knowledge or consent, only if:
a) It is clearly in the Member’s interests and the opportunity for obtaining consent is not available
in a ;mely way
b) Knowledge and consent would compromise the availability or accuracy of the Personal
Informa;on and collec;on is required to inves;gate a breach of an agreement or a
contraven;on of a federal or provincial law
c) An emergency threatens a Member’s life, health, or security
d) The informa;on is publicly available as specified in PIPEDA
18. The Club is also not required to obtain consent for the collec;on of Personal Informa;on if the informa;on is for journalis;c, ar;s;c, or literary purposes.
19. The Club may disclose Personal Informa;on without the Member’s knowledge or consent only:
a) To a lawyer represen;ng the Club
b) To collect a debt that the Member owes to the Club
c) To comply with a subpoena, a warrant, or an order made by a court or other body with
appropriate jurisdic;on
d) To a government ins;tu;on that has requested the informa;on and iden;fied its lawful
authority, if that government ins;tu;on indicates that disclosure is for one of the following purposes: enforcing or carrying out an inves;ga;on, gathering intelligence rela;ng to any federal, provincial, or foreign law, na;onal security or the conduct of interna;onal affairs, or administering any federal or provincial law
e) To an inves;ga;ve body named in PIPEDA or a government ins;tu;on, if the Club believes the Personal Informa;on concerns a breach of an agreement, contravenes a federal, provincial, or foreign law, or if Club suspects the Personal Informa;on relates to na;onal security or the conduct of interna;onal affairs
f) To an inves;ga;ve body for purposes related to the inves;ga;on of a breach of an agreement or a contraven;on of a federal or provincial law
g) In an emergency threatening an Member’s life, health, or security (the Club will inform the Member of the disclosure)
h) To an archival ins;tu;on
i) 20 years a[er the individual's death or 100 years a[er the record was created
j) If it is publicly available as specified in PIPEDA
k) If otherwise required by law
Accuracy, Reten0on, and Openness
20. In order to minimize the possibility that inappropriate Personal Informa;on may be used to make a decision about a Member, Personal Informa;on will be accurate, complete, and as up-to-date as is necessary for the purposes for which it will be used.
21. Personal Informa;on will be retained as long as reasonably necessary to enable par;cipa;on in Club programs, events, and ac;vi;es, and in order to maintain historical records as may be required by law or by governing organiza;ons.
22. The Club’s Stakeholders will be made aware of the importance of maintaining the confiden;ality of Personal Informa;on.
23. Personal Informa;on will be protected against loss or the[, unauthorized access, disclosure, copying, use, or modifica;on by security safeguards appropriate to the sensi;vity of the Personal Informa;on.
24. Personal Informa;on that has been used to make a decision about a Member will be maintained for a minimum of one year in order to allow the individual the opportunity to access the Personal Informa;on a[er the decision has been made.
25. The Club will make the following informa;on available to Members:
a) This Privacy Policy
b) Any addi;onal documenta;on that further explains the Club’s Privacy Policy
c) The name or ;tle, and the address, of the person who is accountable for the Club’s Privacy
Policy
d) The means of gaining access to Personal Informa;on held by the Club
e) A descrip;on of the type of Personal Informa;on held by the Club, including a general account
of its use
f) Iden;fica;on of any third par;es to which Personal Informa;on is made available
Access
26. Upon wriGen request, and with assistance from the Club a[er confirming the Member’s iden;ty, Members may be informed of the existence, use, and disclosure of their Personal Informa;on and will be given access to that Personal Informa;on. Members are also en;tled to be informed of the source of the Personal Informa;on, and provided with an account of third par;es to which the Personal Informa;on has been disclosed.
27. Unless there are reasonable grounds to extend the ;me limit, requested Personal Informa;on will be disclosed to the Member, at no cost to the Member, within thirty (30) days of receipt of the wriGen request.
28. Members may be denied access to their Personal Informa;on if the informa;on:
a) Is prohibi;vely costly to provide
b) Contains references to other individuals
c) Cannot be disclosed for legal, security, or commercial proprietary purposes
d) Is subject to solicitor-client privilege or li;ga;on privilege
29. If the Club refuses a request for Personal Informa;on, it shall inform the Member the reasons for the refusal and iden;fy the associated provisions of PIPEDA that support the refusal.
Compliance Challenges
30. Members are able to challenge the Club for its compliance with this Policy.
31. Upon receipt of a complaint, the Club will:
a) Record the date the complaint is received
b) No;fy the Privacy Officer who will serve in a neutral, unbiased capacity to resolve the
complaint;
c) Acknowledge receipt of the complaint by way of telephone conversa;on and clarify the nature
of the complaint within seven (7) days of receipt of the complaint
a) Appoint an inves;gator using the Club’s personnel or an independent inves;gator, who will have
the skills necessary to conduct a fair and impar;al inves;ga;on and will have unfeGered access
to all file and personnel
d) Upon comple;on of the inves;ga;on and within thirty (30) days of receipt of the complaint, the
inves;gator will submit a wriGen report to the Club
e) No;fy the complainant the outcome of the inves;ga;on and any relevant steps taken to rec;fy
the complaint, including any amendments to policies and procedures
32. The Club will not dismiss, suspend, demote, discipline, harass, or otherwise disadvantage any Club Member or Stakeholder who:
a) Challenges the Club for its compliance with this Policy
b) Refuses to contravene this Policy or PIPEDA
c) Takes precautions to be compliant with this Policy and/or PIPEDA; even though said precau;ons may be in opposi;on to the regular du;es performed by the Member