Privacy Policy

Owner: Governance and Policy Committee
Originally Board Approved: 2017
Last Revised: January 23, 2019
Last Reviewed: January 23, 2019

1. PURPOSE

Privacy of personal information is governed by the Personal Information Protection and Electronics Documents Act (“PIPEDA”). This policy describes the way that the Manitoba Organization of Disc Sports (hereinafter referred to as MODS) collects, uses, retains, safeguards, discloses and disposes of personal information, and states MODS' commitment to collecting, using and disclosing personal information responsibly. This policy is based on the standards required by PIPEDA, and MODS interpretation of these responsibilities.

2. POLICY/PROTOCOL

2.1 DEFINITIONS

“Personal information” is information about an identifiable individual. It includes information that relates to:

  • personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), 
  • health (e.g., health history, health conditions, health services received by them)
  • activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual)

Personal information does not include business information (e.g., an individual's business address and telephone number), which is not protected by privacy legislation.

2.2 ACCOUNTABILITY

The Board and Business and Sport Development Director are responsible for monitoring information collection and data security and ensuring that all staff receive appropriate training on privacy issues and their responsibilities. This group also handles personal information access requests and complaints. They may be contacted at the following address: 145 Pacific Avenue, R3B 2Z6, or 925-5665.

2.3 PURPOSE

2.3.1 Personal information will only be collected by MODS to meet and maintain the highest standard of organizing and programming for disc sports. MODS collects personal information from prospective members, members, coaches, observers, participants, managers and volunteers for purposes that include, but are not limited to, the following: 

  1. Name, address, phone number, cell phone number, fax number and e-mail address for the purpose of communicating about MODS' programs, events and activities or for the purpose of providing insurance coverage, managing insurance claims and conducting insurance investigations.
  2. NCCP number, education, resumes and experience for database entry at the Coaching Association of Canada to determine level of certification and coaching qualifications. 
  3. Credit card information for registration at conferences, travel administration, and purchasing equipment, coaching manuals and other products and resources. 
  4. Date of birth, athlete biography, and member club to determine eligibility, age group and appropriate level of play. 
  5. Banking information, social insurance number, criminal records check, resume, and beneficiaries for MODS' payroll, company insurance and health plan. 
  6. Personal health information including provincial health card numbers, allergies, emergency contact and past medical history for use in the case of medical emergency. 
  7. Athlete information including height, weight, uniform size, shoe size, feedback from coaches and trainers, performance results for athlete registration forms, outfitting uniforms, media relations, and various components of athlete and team selection. 
  8. Athlete whereabouts information including sport/discipline, training times and venues, training camp dates and locations, travel plans, competition schedule, and disability, if applicable, for Canadian Centre for Ethics in Sport inquiries for the purposes of out-of-competition drug testing. 
  9. Marketing information including attitudinal and demographic data on individual members to determine membership demographic structure, and program wants and needs. 
  10. Passport numbers and Aeroplan/frequent flyer numbers for the purposes of arranging travel.

2.3.2 If a purpose has not been identified herein, MODS will seek consent from individuals when personal information is used for a purpose not already consented to. This consent will be documented as to when and how it was received.

2.4 CONSENT

2.4.1 Consent is required to be obtained by lawful means from individuals at the time of collection, prior to the use or disclosure of the personal information. If the consent to the collection, use or disclosure was not obtained upon receipt of the information, consent will be obtained prior to the use or disclosure of that information. MODS may collect personal information without consent where reasonable to do so and where permitted by law. 

2.4.2 By providing personal information to MODS, individuals are consenting to the use of the information for the purposes identified in this policy. 

2.4.3 MODS will not, as a condition of a product or service, require an individual to consent to the collection, use or disclosure of information beyond that required to fulfill the specified purpose. 

2.4.4 An individual may withdraw consent to the collection, use or disclosure of personal information at any time, subject to legal or contractual restrictions, provided the individual gives one week's notice of such withdrawal to MODS. The Board or Business and Sport Development Director will advise the individual of the implications of such withdrawal.

2.5 LIMITING COLLECTION

All personal information will be collected fairly, by lawful means and for the purposes as specified in this policy. MODS will not use any form of deception to obtain personal information.

2.6 LIMITING USE, DISCLOSURE AND RETENTIION 

2.6.1 Personal information will not be used or disclosed by MODS for purposes other than those for which it was collected as described herein, except with the consent of the individual or as required by law. 

2.6.2 Personal information will be retained for certain periods of time in accordance with the following:

  1. Registration data and athlete information will be retained for a period of three years after an individual has left a program of MODS;
  2. Parental/family information will be retained for a period of three years after an individual has left a program of MODS, in the event that the individual chooses to return to the program;
  3. Information collected by coaches will be retained for a period of three years after an individual has left a program of MODS, in the event that the individual chooses to return to the program.
  4. Employee information will be retained for a period of seven years in accordance with Canada Revenue Agency requirements. 
  5. Personal health information will be immediately destroyed when an individual chooses to leave a program of MODS. 
  6. Marketing information will be immediately destroyed upon compilation and analysis of collected information. 
  7. As otherwise may be stipulated in federal or provincial legislation. 

2.6.3 Personal information that is used to make a decision about an individual will be maintained for a minimum of one year of time to allow the individual access to the information after the decision has been made. 

2.6.4 MODS may disclose personal information to a government authority that has asserted its lawful authority to obtain the information or where MODS 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 or otherwise as permitted by applicable law. 

2.6.5 Documents will be destroyed by way of shredding and electronic files will be deleted in their entirety. When hardware is discarded, MODS will ensure that the hard drive is physically destroyed.

2.7 ACCURACY

MODS will use accurate and up-to-date information as is necessary for the purposes for which it is to be used, to minimize the possibility that inappropriate information may be used to make a decision about an individual.

2.8 SAFEGUARDS

2.8.1 Personal information is protected by security safeguards appropriate to the sensitivity of the information against loss or theft, unauthorized access, disclosure, copying, use of modification. Methods of protection and safeguards include, but are not limited to, locked filing cabinets and restricted access to offices and computer files.

2.8.2 Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this policy. Volunteers who collect, use and disclose personal information will be provided with a copy of this Policy and will be given instructions on how to collect, use and disclose personal information in accordance with this Policy. 

2.8.3 External consultants and agencies with access to personal information will provide MODS with appropriate privacy assurances.

2.9 OPENNESS

2.9.1 MODS will publicize information about its policies and practices relating to the management of personal information. This information is available through this policy, on MODS' website or upon request by contacting the Board or Business and Sport Development Director. 

2.9.2 The information available to the public includes: 

  1. The name, title, and email address of MODS' board members and Business and Sport Development Director. 
  2. The forms that may be used to access personal information or change information. 
  3. A description of the type of personal information held by MODS, including a general statement of its approved uses.

2.10 INDIVIDUAL ACCESS

2.10.1 Upon written request, and with assistance from MODS, 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. 

2.10.2 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 cost relating to photocopying expenses, unless there are reasonable grounds to extend the time limit. 

2.10.3 If personal information is inaccurate or incomplete, it will be amended as required. 

2.10.4 An individual may be denied access to his or her personal information if: 

  1. This information is prohibitively costly to provide; 
  2. The information contains references to other individuals;
  3. The information cannot be disclosed for legal, security or commercial proprietary purposes;
  4. The information is subject to solicitor-client or litigation privilege. 

2.10.5 Upon refusal, MODS will inform the individual the reasons for the refusal and the associated provisions of PIPEDA.

2.11 CHALLENGING COMPLIANCE

2.11.1 An individual may challenge MODS' compliance with this policy and PIPEDA, by submitting a challenge in writing. 

2.11.2 Upon receipt of a written complaint, MODS will: 

  1. Record the date the complaint is received;
  2. Notify the Board or Business and Sport Development Director who will serve in a neutral, unbiased capacity to resolve the complaint; 
  3. Acknowledge receipt of the complaint and clarify the nature of the complaint within three days of receipt of the complaint; 
  4. Appoint an investigator using MODS personnel or an independent investigator, who will have the skills necessary to conduct a fair and impartial investigation, and who will have unfettered access to all files and personnel, within ten days of receipt of the complaint. 
  5. Upon completion of the investigation and within 25 days of receipt of the complaint, the investigator will submit a written report to MODS. 
  6. Notify the complainant of the outcome of the investigation and any relevant steps taken to rectify the complaint, including any amendments to policies and procedures, within 30 days of receipt of the complaint. 

2.11.3 An individual may appeal a decision made by MODS under this Policy, in accordance with the MODS Appeal Policy.

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