1.1 Background – Privacy of personal information is governed by the Personal Information Protection and Electronics Documents Act (“PIPEDA”). This policy describes the way that Curling Canada collects, uses, safeguards, discloses and disposes of personal information, and states Curling Canada’s commitment to collecting, using and disclosing personal information responsibly. This policy is based on the standards required by PIPEDA, andCurling Canada’s interpretation of these responsibilities.
1.2 Purpose –The purpose of this policy is to govern the collection, use and disclosure of personal information in the course of commercial activities in a manner that recognizes the right of privacy of individuals with respect to their personal information and the need of Curling Canada to collect, use or disclose personal information.
1.3 Definitions – The following terms have these meanings in this Policy:
1. Act – Personal Information Protection and Electronic Documents Act.
2. Commercial Activity – any particular transaction, act or conduct that is of a commercial character.
3. Personal Information – any information about an identifiable individual including information that relates to their personal characteristics including, but not limited to, gender, age, income, social insurance number, home address or phone number, athletic testing and results, email, ethnic background, family status, health history and health conditions.
4. Representatives – Members, governors, officers, employees, committee members, officials, athletes, coaches, volunteers, administrators, donors, contractors and all other participants within Curling Canada’s programs and services.
1.4 Application –This Policy applies to Curling Canada in connection with personal information that is collected, used or disclosed during any commercial activity related to Curling Canada.
1.5 Statutory Obligations – Curling Canada is governed by the Personal Information Protection and Electronic Documents Act in matters involving the collection, use and disclosure of personal information.
1.6 Additional Obligations – In addition to fulfilling all requirements of the Act, Curling Canada will also fulfill the additional requirements of this Policy.
1.7 Ruling on Policy – Except as provided in the Act, Curling Canada’s Privacy Officer will have the authority to interpret any provision of this Policy that is contradictory, ambiguous, or unclear.
2.1 Privacy Officer – Katherine Henderson, Chief Executive Officer, is Curling Canada’s Privacy Officer and is responsible for the implementation of this policy and monitoring information collection and data security, and ensuring that all employees receive 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:
c/o Katherine Henderson
1660 Vimont Court
Orleans, Ontario K4A 4J4
Tel: 613-834-2076 x125
Email: [email protected]
2.2 Duties – The Privacy Officer will:
2.3 Employees – Curling Canada will be responsible to ensure that the employees, contractors, agents, or otherwise are compliant with the Act and this Policy.
3.1 Purpose – Personal information may be collected from Representatives and prospective Representatives and will only be used to meet and maintain the highest standards related to the organization and programming of curling. Curling Canada will use personal information for purposes that include, but are not limited to, the following:
*Financial information, for example credit card numbers, will not be maintained by Curling Canada and will be deleted upon completion of the applicable financial transaction.
3.2 Purposes not Identified – Curling Canada will seek consent from individuals when personal information is used for commercial purpose not identified herein or previously identified. This consent will be documented as to when and how it was received.
3.3 User ID and/or Password – A Representative or potential Representative is solely responsible for any User ID and/or password to access Curling Canada’s website and will not disclose their User ID or password to any third party. Upon such disclosure, the Representative or potential Representative will be solely responsible for the actions resulting from the disclosure.
3.4 Shopping On-Line – A Representative or potential Representative who shops and orders from Curling Canada’s on-line catalogue will be provided a secure commerce transaction by way of Stripe secure server software. Stripe encrypts all information inputted before being sent to Curling Canada, including credit card numbers, name and address, in order to prevent unauthorized disclosure on the internet. In the event that a Representative or potential Representative does not wish to provide personal information on-line, the Representative or potential Representative may otherwise choose to order via telephone (1-800-550-2875).
4.1 Consent – Curling Canada will obtain consent by lawful means from individuals at the time of collection and prior to the use or disclosure of the applicable personal information. Curling Canada may collect personal information without consent where reasonable to do so and where permitted by law.
4.2 Implied Consent – By providing personal information to Curling Canada in any format, including but not limited to email, personal correspondence, letter or via registration, individuals are consenting to the use of the information for the purposes identified in this policy.
4.3 Means of Consent – Individuals may provide consent, either written or implied, in the following ways:
4.4 Withdrawal – An individual may withdraw consent in writing to the collection, use or disclosure of personal information at any time, subject to legal or contractual restrictions. Curling Canada will inform the individual of the implications of such withdrawal.
4.5 Legal Guardians – Consent will not be obtained from individuals who are minors, seriously ill, or mentally incapacitated and therefore will be obtained from a parent, legal guardian or person having power of attorney.
4.6 Exceptions for Collection – Curling Canada is not required to obtain consent for the collection of personal information if:
4.7 Exceptions for Use – Curling Canada may use personal information without the individual’s knowledge or consent only:
4.8 Exceptions for Disclosure – Curling Canada may disclose personal information without the individual’s knowledge or consent only:
5.1 Limiting Collection, Use and Disclosure – Curling Canada will not collect, use or disclose personal information indiscriminately. Information collected will be for the purposes specified in Article 3.1, except with the consent of the individual or as required by law.
5.2 Retention Periods – Personal information will be retained as long as reasonably necessary to enable participation in Curling Canada, to maintain accurate historical records and or as may be required by law.
5.3 Destruction of Information – Documents will be destroyed by way of shredding and electronic files will be deleted in their entirety.
6.1 Safeguards – Personal information will be protected by security safeguards appropriate to the sensitivity of the information against loss or theft, unauthorized access, disclosure, copying, use or modification.
7.1 Access – Upon written request, and with assistance from Curling Canada, an individual may be informed of the existence, use and disclosure of his or her personal information and will be given access to that information. As well, an individual is entitled to be informed of the source of the personal information along with an account of third parties to whom the information has been disclosed.
7.2 Response – Requested information will be disclosed to the individual within 30 days of receipt of the written request at no cost to the individual, or at nominal costs relating to photocopying expenses, unless there are reasonable grounds to extend the time limit.
7.3 Denial – An individual may be denied access to his or her personal information if:
7.4 Reasons – Upon refusal, Curling Canada will inform the individual the reasons for the refusal and the associated provisions of PIPEDA.
7.5 Identity – Sufficient information will be required to confirm an individual’s identity prior to providing that individual an account of the existence, use, and disclosure of personal information.
8.1 Challenges – An individual will be able to challenge compliance with this Policy and the Act to the designated individual accountable for compliance.
8.2 Procedures – Upon receipt of a complaint Curling Canada will:
8.3 Whistle-blowing – Curling Canada will not dismiss, suspend, demote, discipline, harass or otherwise disadvantage all governors, officers, employees, committee members, volunteers, trainers, contractors, and other decision-makers within Curling Canada or deny that person a benefit because the individual, acting in good faith and on the basis of reasonable belief:
9.1 Applicable Law – The laws of the province of Ontario will govern.