PRIVACY POLICY

Purpose of this Policy

This Policy describes the way that the association will, subject to applicable legal requirements, adhere to all relevant federal and provincial legislative privacy requirements. The Policy follows the 10 Canadian Standards Association (CSA) principles identified in the federal Personal Information Protection and Electronic Documents Act (PIPEDA). The Policy describes each principle and the method of implementing each. The association will strive to meet or exceed federal and provincial legislative requirements and will ensure that it remains current with changing technologies and laws.

1. Accountability

1.1 The association will appoint a staff/volunteer person (the “Privacy Officer”) whose responsibilities will include those of the implementation and monitoring of the association Privacy Policy. The Privacy Officer will be responsible for the association’s compliance with privacy principles. This person will also be responsible for responding to access requests in accordance with this Policy. The Privacy Officer will report to the President, or designate and the ultimate responsibility for Privacy issues will rest with the association Executive Board. The Privacy Officer may at his/her discretion enlist assistance from other staff/Executive members and/or volunteers within the organization. This will not in any manner mitigate his/her responsibility for Privacy issues.
1.2 The Privacy Officer’s identity will be fully disclosed and publicly accessible to the association members and the public in general. The association’ Privacy Officer can be reached at P.O. Box 612, Midland, Ontario, L4R 4L3.
1.3 The association Privacy Officer will ensure that the association manages all personal information in its possession in accordance with this Policy including that which may be transferred to a third party. Third party organizations that handle information on behalf of the association shall be contractually obligated to adhere to the standards of the association.
1.4 The association will implement internal policies that will facilitate adherence to this Privacy Policy including but not limited to the following:
Security measures at all levels designed to protect personal information in our possession.
Implementing procedures designed to respond to complaints and/or inquiries.
Staff/volunteer training in all facets of information management, including awareness of the association’ Privacy Policy and policies and procedures developed in accordance with the Policy.

2. Identifying Purposes, Type of Information Collected and Website

2.1 The association shall only collect the information reasonably necessary to conduct Hockey Programming. Access to our Privacy policies and procedures will be readily available. Similarly, the process by which challenges may be made to the association compliance and/or adherence to the legislation in question shall be readily available and transparent. To obtain further information, contact the association’s Privacy Officer. The association’ Privacy Officer can be reached at P.O. Box 612, Midland, Ontario, L4R 4L3.
2.2 The association collects personal information from prospective members, members, coaches, referees, managers and volunteers for the purposes of conducting Hockey Programming. Specifically:
A player’s name, address and date of birth are collected to determine that the player’s geographical, division of play and level of play information are consistent with Hockey Canada and OWHA regulations.

Historical information concerning past teams played for is collected in order to determine if any the association transfer regulations may apply. Information concerning an individual’s skill level and development and feedback on programs is collected to measure the success of our programs in order that we may better plan future programs.

Information as to a player’s parents’ or guardians’ name, address, telephone numbers and email addresses may be collected in order to facilitate emergency contact information, to facilitate membership communication and to facilitate association residency matters.

Information as to Team Official’s names, addresses, telephone numbers, email addresses, training and coaching certifications and qualifications, to facilitate membership communication and communication amongst other team officials and other hockey organizations, and to certify team officials.
On-ice and Off-ice official’s names, addresses, telephone numbers, email addresses and HCOP level, to facilitate communication amongst officials and the assignment of officials to games, and to assist in the development of officials.

Information about skill levels, ability, emergency contacts and health to ensure our activities are carried out in a safe and secure environment. Personal information collected for the purposes of hockey registrations may also be used for hockey specific research purposes including but not necessarily limited to hockey demographic type research.

Team and individual pictures, to provide players with a memento of their hockey experience.
Resumes and application forms, to determine a prospective team official’s or employee’s suitability for a position with the association. Parent or Player Satisfaction or Feedback Surveys, to help evaluate the suitability of a team official, to provide feedback to team officials and the association.

Player Evaluations, to assist in the selection of players for competitive teams and in balancing local league teams. Appeal Information, to administer appeals and any related proceedings, and the rules, regulations and by-laws of the Association and the OWHA.
2.3 The association shall advise registration candidates of the purpose for the collection of the data requested at the time of registration. We will further endeavour to ensure that all collectors of the personal information are familiar with the potential use of the personal data. Where practicable, all personal data collected by the association shall be maintained with our executive or Privacy Officer.
2.4 The association will individually request permission for the use of any personal data collected which is extraneous to that which has been identified above, unless said usage is authorized by law.
2.5 The association may also use information about an individual who accesses secure areas of the association website. Information you are asked to provide during your use of our web site may include your name, address, e-mail address, age, gender [and the other types of personal information listed in paragraph 2.2]. All such personal information will be treated within the same parameters as other personal information collected by the association through other means. It is always your choice to provide information in certain fields although failure to complete certain sections may inhibit your ability to fully access all areas of the web site. Our web site also collects non-identifiable information about users such as the users IP address, the sections of the web site visited and the information downloaded. The association may use this non-identifiable information and disclose it to service providers, for system administration purposes and to improve the web site.

3. Consent

3.1 The association will use the personal information for the uses specified above in section 2 and in Section
3.2 below. All members of the association agree that the act of registering constitutes implied consent to the use of personal information for the purposes specified in Section 2 and 3.
3.2 The association recognizes that hockey by its nature is a contact sport and injuries are to a certain extent inherent in the game. We believe medical records, medical history and medical forms of the individual may be of assistance in an emergency situation and therefore we may request them. While our members and prospective members are under no obligation whatsoever to supply this information and may refuse to do so without penalty, the association will consider receipt of this information as consent for its subsequent use in an emergency medical situation.
3.3 If at any time you wish to withdraw your consent to the use of your information for any purposes, you may do so by contacting the Privacy Officer for the association in writing, subject to legal and contractual restrictions.
3.4 The association may collect personal information without consent where reasonable to do so and where permitted by law.

4. Limiting Collection

4.1. All information shall be collected in a fair and lawfully manner as set forth in this Privacy Policy. The association shall not indiscriminately collect information. The amount and type of information we collect shall be limited to that which is required to fulfill our identified purposes.

5. Limiting Use, Disclosure and Retention

5.1 Subject to applicable legislation, the association shall limit use of personal information it collects to purposes that we have disclosed in Sections 2 (Identifying Purposes) and 3, Consent.
5.2 The association shall maintain documents for certain periods of time dependant upon necessity. More specifically:
We will normally maintain registration data for a three-year period after an individual has left our programs in the event that an individual chooses to return to our programs after leaving.
Parental/family information will be normally maintained for a similar three-year period after a member has left our programs.
5.3 The association may enlist the services of third party organizations. Prior to enlisting the services of these firms we will contractually commit them to treat your personal information consistent with the Privacy Policy of the association.
5.4 The association may at some point be involved in the merger, transfer or reorganization of its activities. We may disclose personal information to the other party in such a transaction. The association will ensure that we contractually obligate the other party to treat this information in a manner consistent with our Privacy Policy.
5.5 The association may disclose your personal information to a government authority that has asserted its lawful authority to obtain the information or where the association has reasonable grounds to believe the information could be useful in the investigation of an unlawful activity, or to comply with a subpoena or warrant or an order made by the court, person, or body with jurisdiction to compel the production of the information or otherwise as permitted by applicable law.
5.6 The association may at its discretion release personal information for the purposes of collecting debts that may be owed to the association.
5.7 Certain documents may be subject to legislated retention periods either federally or provincially and these will be respected at all times by the association.
5.8 Personal information that is no longer required or permitted to be retained by the Association, will be destroyed in a secure manner.

6. Accuracy

6.1 The association shall strive to ensure to the extent it can that the information entrusted to us is maintained in an accurate manner. We shall try to maintain the interests of the individual and attempt to ensure that decisions are not made for or about an individual based on personal information that is flawed.
6.2 The association shall only update information in the event of a renewal of registration and/or an update.

7. Safeguards

7.1 Security safeguards have been implemented to ensure your personal information is protected from theft as well as unauthorized access, disclosure, copying, use or modification thereof.
7.2 The level of safeguards employed shall be directly related to the level of sensitivity of the personal information collected. The more sensitive the information, the higher the level of security employed.
7.3 Methods of protection and safeguards to be employed shall include but in no way be necessarily limited to locked files, offices and storage areas, security clearances and need to know access as well as technological measures such as passwords and encryption.

8. Openness

8.1 The association publicly discloses the methods by which we handle your personal information. This information is readily available through our Privacy Policy, on our web site or upon request by contacting the association Privacy Officer in writing at P.O. Box 612, Midland, Ontario, L4R 4L3.
8.2 The information available includes:
The name address and phone number of the association Privacy Officer. The forms (attached) that you may use to access your information or change your information. A description of the type of personal information held by the association and our general uses thereof. This includes:
registration information, including name, date of birth, address, past teams played on, medical information and e-mail addresses information used for scouting, potential sponsorship opportunities, donors, alumni and information retained for the purposes of the association business contacts.

9. Individual Access

9.1 Subject to applicable legislation, upon request by the individual concerned the association shall disclose whether or not it actually holds personal information on an individual. We shall disclose the source of this information when requested and provide an account of third parties to whom the information may have been disclosed.
9.2 The association may request sufficient information to confirm your identity before releasing your personal information to you.
9.3 Subject to applicable legislation, the association shall endeavour to provide this information within 30 days of receipt of the request and only charge nominal fees for the purpose of satisfying its expenses incurred in supplying the requested information. This information shall be provided in an understandable format.
9.4 Any inaccurate information that is brought to our attention shall be corrected by the association as quickly as possible and any pertinent third parties shall be notified of the corrections.

10. Challenging Compliance

10.1 Anyone wishing to challenge the Associations compliance with this policy may contact the President or any member of the executive.
10.3 The association shall investigate all complaints. If the complaint is deemed justified the association shall take the appropriate steps to ensure that compliance is achieved and will make changes to its policies to allow for compliance in the future.