CYGHA
PRIVACY POLICY
BACKGROUND
The
Ontario Women’s Hockey Association (OWHA) is the governing body of female
hockey in the province of Ontario and operates in cooperation with Hockey
Canada. The Central York Girls Hockey Association (CYGHA) operates under the
sanction of the OWHA.
PURPOSE OF
THIS POLICY
The CYGHA
has developed this Privacy Policy for implementation beginning April 1, 2020.
This Policy describes the way in which the CYGHA collects, uses, retains,
safeguards, discloses and disposes of the personal information of prospective
members, members, and others including players, parents, related individuals,
trainers, coaches, referees, managers, volunteers and employees.
This
Policy describes the way that the CYGHA will, subject to applicable legal
requirements, adhere to all relevant federal and provincial legislative privacy
requirements. The Policy follows the Model Code for the Protection of Personal
Information identified in the federal Personal Information Protection and Electronic
Documents Act (PIPEDA). The Policy describes each principle and the method of
implementing each. The CYGHA will strive to meet or exceed federal and
provincial legislative requirements and will ensure that it remains current
with changing technologies and laws.
The CYGHA
reserves the right in its sole discretion to make whatever changes to its
Privacy Policy it deems necessary and expedient. Any and all such changes will
immediately be posted to the CYGHA web site (WWW.CYGHA.COM)
1.
Accountability
1.1
The CYGHA shall
designate the President as the Privacy Officer for the CYGHA and they are
accountable to the Board for compliance with this Policy. The Privacy Officer will
be responsible for the CYGHA’s compliance with PIPEDA privacy principles and
for responding to access requests in accordance with this Policy.
1.2
The CYGHA’s Privacy
Officer will ensure that the CYGHA is accountable for all personal information
in its possession including that which may be transferred to a third party.
Third party organizations who handle information on behalf of the CYGHA shall
be contractually obligated to adhere to the standards of the CYGHA Privacy
Policy.
1.3
The CYGHA will
implement internal policies which will facilitate adherence to the Privacy
Policy including but not limited to the following:
1.3.1
Security
measures at all levels designed to protect personal information in its
possession.
1.3.2
Procedures
designed to respond to complaints and/or inquiries.
1.3.3
Staff training
in all facets of information management, including awareness of the CYGHA’s Privacy
Policy and subsequent policies and procedures developed in accordance with the
Policy.
2.
Identifying
Purposes
2.1
The CYGHA shall
only collect information necessary to conduct hockey programming. Access to
our Privacy Policy and procedures will be readily available. Similarly, the
process by which challenges may be made to the CYGHA’s compliance and/or
adherence to the legislation in question shall be readily available.
2.2
The CYGHA
collects personal information for the purpose of providing hockey programming,
which endeavours to meet the individual needs of each participant.
2.3
The CYGHA
recognizes that hockey by its nature is a contact sport and injuries are to a
certain extent, inherent in the game. Medical records, medical history and
medical forms of the individual may be of assistance in an emergency situation
and as such will be requested by electronic or paper based methods. The CYGHA
will consider receipt of this information from the player or member or any
lawful representative of a player or member or from a hospital or doctor or
dentist detailing personal information, as consent for its subsequent use in an
emergency medical situation.
2.4
The CYGHA will
request individual permission for the use of any data collected which is
extraneous to that which has been identified below, unless said usage is
authorized by law.
|
Type of
Personal Information
|
Purpose of Collecting
|
|
A participant’s name, sex, place of residence and date of birth.
|
To determine that the participant’s geographical, division and
level of play information are consistent with CYGHA and Hockey Canada
regulations.
|
|
Historical information concerning past teams played for.
|
To determine if any Hockey Canada transfer regulations apply. To
determine if a release or permission to skate is required.
|
|
A participant’s skill and development level and feedback on
programs, honours and awards received.
|
To measure the success of our programs and maintain governance.
|
|
A participant’s parents (if applicable); name, address,
telephone number(s), email addresses and fax.
|
To facilitate emergency contact information and to ensure
compliance with regulations.
|
|
Educational or training information
|
To ensure all regulations have been adhered to.
|
|
E-mail addresses, phone and/or fax numbers
|
To facilitate membership communication.
|
|
Skill levels, ability, emergency contacts and health concerns
|
To support the objective of providing activities in a safe and
secure environment.
|
|
Resumes, Coach Applications and any other employment or
volunteer application form
|
To identify potential future employment or volunteer candidates.
|
|
Registration information
|
To conduct research including but not necessarily limited to
hockey demographic type research.
|
|
Appeal/Hearing Information
|
To administer appeals/hearings and any related proceedings, and
the Rules, Regulations, By Laws and Code of Conduct of the CYGHA.
|
|
Information required for the administration of the its members
and for the safety and well-being of its members and the efficient
administration of female hockey.
|
To administer the CYGHA and players of the CYGHA for the benefit
and well-being of female hockey and the individual participants.
|
|
Survey data, including but not limited to, coach evaluations, member
preferences, etc,
|
To better understand the wants and needs of its members.
|
2.5
All information
is kept for the duration of seven years or as long as required to fulfill the
purposes identified, unless permission is obtained from the member providing
the information to hold it for a different length of time.
2.6
The CYGHA will
endeavour through its members to advise potential registration candidates of
the purpose for the collection of their data at the time of registration. This
information will be made available by reference to the CYGHA website or relevant
policy documents. The CYGHA will further endeavour to ensure that all
collectors of the personal information are familiar with the potential use of
the data. Any other purpose of collection will be stated at time of
collection.
2.7
All data
collected by the CYGHA shall be maintained in the CYGHA office or within
information systems licensed by the CYGHA. The office location is listed on
the CYGHA web site.
2.8
The CYGHA may
also use information about user access to secure areas of the CYGHA website.
Information you are asked to provide during your use of the CYGHA web site may
include your name, address, phone, e-mail address, age, sex and will be treated
within the same parameters as other personal information collected by Hockey
Canada through other means.
3.
Consent
3.1
The CYGHA will
use the personal information for the uses specified in section 2.
3.2
All members of
the CYGHA have the ability to consent to the use of their personal information
on a yearly basis. A member of the CYGHA agrees that the act of registering
constitutes implied consent to such use of their personal information by the CYGHA,
related leagues, the OWHA and Hockey Canada.
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 CYGHA Privacy Officer at any time,
subject to legal or contractual restrictions and by providing reasonable
written notice. Previous consent will be removed from the CYGHA database upon
receipt of a written request and that request will be communicated to the
pertinent team and/or league within 10 business days.
3.4
The CYGHA may
collect personal information without consent where reasonable to do so and
where permitted by law.
4.
Limiting
Collection
4.1
The CYGHA its
Teams, Associations, Programs and Leagues shall only collect personal
information in a fair and lawful manner as set forth in this Privacy Policy.
4.2
The CYGHA shall
not indiscriminately collect information. The amount and type of information
collected shall be limited to that which is required to fulfill its identified
purposes.
5.
Limiting
Use, Disclosure and Retention
5.1
The CYGHA, its
Teams, Programs and Leagues shall limit the use of personal information
collected to purposes that are listed in Section 2.4 (Identifying Purposes) and
3.2 (Consent) and will not disclose the information for other purposes except
as authorized or required and permitted by applicable law.
5.2
Prior to
enlisting the services of third-party organizations, the CYGHA will
contractually commit those parties to treat your personal information in a
manner consistent with this Privacy Policy.
5.3
The CYGHA 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 authorized or permitted by
applicable law.
5.4
The CYGHA may
at its discretion release personal information for the purposes of collecting
debts which may be owed to the CYGHA.
5.5
The CYGHA shall
retain documents concerning registration, performance activities, discipline,
events and honours and awards received for specific periods of time dependent
upon necessity or destroyed accordingly when it is deemed appropriate. More
specifically:
5.5.1
Registration
data will be retained for a three-year period after an individual has left the CYGHA
programs in the event that an individual chooses to return to the CYGHA
programs after leaving.
5.5.2
Parental/Family
information will be maintained for a similar three-year period after a member
has left our programs.
5.6
Other personal
information will be retained by the CYGHA for regulated timeframes as requested
by legislation governing its operation and/or the information provided, after
which time (unless consent is given to keep information for a longer period)
the information will be destroyed in a secure manner.
5.7
If there are no
legislative requirements to retain other information, it will be kept for a
minimum of 24 months from the time it was provided.
6.
Accuracy
6.1
The CYGHA shall
strive to ensure to the extent that it can, that the information entrusted to
it is maintained in an accurate manner. Members will have the ability to view
and review data provided on their application for membership at any time through
the CYGHA database or equivalent. The CYGHA shall attempt to maintain the
privacy interests of the individual and attempt to ensure that decisions are
not made for or about an individual based on personal information that may be
flawed.
6.2
The CYGHA shall
only update information if a request is made in writing.
7.
Safeguards
7.1
Security
safeguards will be implemented to ensure your personal information is protected
from theft as well as unauthorized use or access, disclosure, copying, or
modification thereof.
7.2
All information
collected by the CYGHA (as per 2.4) will be considered highly sensitive. As
such, a high level of security will be practiced at all times.
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.
7.4
These measures
will be subject to yearly reviews by the CYGHA and its Privacy Officer(s) to
ensure the best methods possible are being utilized to maximize effectiveness.
8.
Openness
8.1
The CYGHA
publicly discloses the methods by which personal information is handled. This
information is readily available through its Privacy Policy, on its website or
upon request by contacting the CYGHA Privacy Officer.
8.2
The information
available includes:
8.2.1
The name
address and phone number of the CYGHA Privacy Officer.
8.2.2
The forms
(attached) to access your information or change your information.
8.2.3
A description
of the type of personal information and our general uses thereof (review chart
in section 2.2 for more details).
8.3
If any
participant shall have a question regarding the personal information collected,
the investigation may be initiated to the CYGHA Privacy Officer, then directly
to the CYGHA Officers.
9.
Individual
Access
9.1
Upon request by
the individual concerned, subject to applicable legislation, the CYGHA shall
disclose whether or not it actually holds personal information on an
individual. The CYGHA 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
You shall not
have access to personal information which would likely reveal personal
information about another person or third party unless the information can be
severed from the record containing the information about another person or
third party or unless that other person or third party specifically consents in
writing to the release of her/his or its personal information.
9.3
The CYGHA may
request sufficient information to confirm your identity before releasing your
personal information to you.
9.4
Subject to
applicable legislation, the CYGHA shall endeavour to provide individual access
to information within 30 days of receipt of a request for information and only
charge nominal fees for the purpose of satisfying its expenses incurred in the
supply of requested information. Information shall be provided in an
understandable format.
9.5
A member may
challenge the accuracy and completeness of the information through written
request and any inaccurate information which may be so validated, shall be
corrected and any third parties shall be notified of the corrections as per 3.4
(Consent).
10.
Challenging
Compliance
10.1
The CYGHA has
established a set of procedures for the resolution of grievances in the
administration of its Privacy Policy.
10.2
Prospective
members and staff may challenge the CYGHA’s compliance with this Policy by
contacting the CYGHA President or/and Privacy Officer(s). Upon receipt of a
complaint, the CYGHA shall make available the complaint procedures which will
be simple and easy to access.
10.3
The CYGHA shall
investigate all complaints made to it. If the complaint is deemed justified,
the CYGHA shall take the appropriate steps to ensure that compliance is
achieved and will make any necessary changes to its policies to allow for
compliance in the future.
10.4
All complaints
shall be addressed to the CYGHA Privacy Officer. CYGHA policies and procedures
must be adhered to in order to have the challenge dealt with in an appropriate
and timely fashion.
11.
Contacting
Us
If you
have any questions about this privacy policy, please contact the CYGHA by email
or in writing. The contact information can be found at: WWW.CYGHA.COM