PURPOSE OF THIS POLICY
The MMHA has
developed this Privacy Policy for implementation beginning January 1, 2007.
This Policy describes the way in which the MMHA collects, uses, retains,
safeguards, discloses and disposes of the personal information of prospective
members, members, and others including players, parents, trainers, coaches,
referees, managers, volunteers and employees.
This Policy describes the way that the MMHA 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 MMHA will
strive to meet or exceed federal and provincial legislative requirements and
will ensure that it remains current with changing technologies and laws. The MMHA
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
be posted to the MMHA web site (www.MarkhamHockey.com).
1.
Accountability
1.1 The
MMHA shall designate a Privacy Officer for the MMHA who will report to the
Executive Director and they are jointly accountable to the MMHA Officers for
compliance with this Policy. The Privacy Officer will be responsible for the MMHA’s compliance with PIPEDA privacy principles and for
responding to access requests, corrections and complaints in accordance with
this Policy.
1.3 The
name(s) of the individual(s) listed as the Privacy Officer(s) for the MMHA
shall be made available upon request. In the case where neither of these
individuals is available upon request, a delegate may act on their behalf.
1.4 The
MMHA’s Privacy Officer will ensure that the MMHA is
accountable for all personal information in its possession including that,
which may be transferred to a third party. Third party organizations that
handle information on behalf of the MMHA shall be contractually obligated to
adhere to the standards of the MMHA Privacy Policy.
1.5 The
MMHA will implement internal policies, which will facilitate adherence to the
Privacy Policies including but not limited to the following:
·
Security measures at all
levels designed to protect personal information in its possession.
·
Procedures designed to
respond to complaints and/or inquiries
·
Staff training in all
facets of information management, including awareness of the MMHA’s Privacy Policy and subsequent policies and
procedures developed in accordance with the Policy.
2.
Identifying Purposes
2.1 The
MMHA shall only collect information 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 MMHA’s compliance and/or adherence to the legislation in
question shall be readily available.
2.2 The
MMHA collects personal information for the purpose of providing hockey
programming, which endeavours to meet the individual needs of each participant.
2.3 The
MMHA 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 may be requested. While participants are under no obligation
whatsoever to supply this information and may refuse to do so without penalty,
the MMHA will consider receipt of this information as consent for its
subsequent use in an emergency medical situation.
2.4 The
MMHA 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 or required by law.
|
Type of Personal Information
|
Purpose of Collecting
|
|
A participant’s name, gender, place of residence and date of birth.
|
To determine that the participant’s geographical, division and level
of play information are consistent with MMHA, OMHA and Hockey Canada
regulations.
|
|
Historical information concerning past teams played for.
|
To determine if any Hockey Canada transfer regulations apply.
|
|
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 Hockey Canada
residency regulations.
|
|
Educational information
|
To ensure all Hockey Canada
residency regulations have been adhered to.
|
|
E-mail addresses and fax
|
To facilitate membership communication.
|
|
Skill levels, ability, emergency contacts and health concerns
|
To ensure our activities are carried out in a safe and secure
environment.
|
|
Resumes
|
To identify potential future employment candidates.
|
|
Registration information
|
To conduct research studies including but not necessarily limited to
hockey demographic type research. To be made available to related
organizations, Branches, associations, leagues and/or third party service
providers.
|
|
Appeal Information
|
To administer appeals and any related proceedings, and the Rules,
Regulations and By Laws of the MMHA.
|
2.5 The
information will be collected via an oral and/or written agreement to allow the
individual submitting information an opportunity to opt-out or opt-in to the
use of personal information for third parties.
2.6 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.
2.7 The
MMHA will endeavour 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 MMHA website. The MMHA 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.
2.8 All
data collected by the MMHA shall be maintained in the MMHA office.
2.9 The
MMHA may also use information about user access to secure areas of the MMHA
website or the on-line registration website. Information you are asked to
provide during your use of the MMHA website or the on-line registration website
may include your name, address, e-mail address, age, sex and will be treated
within the same parameters as other personal information.
3. Consent
3.1 The
MMHA will use the personal information for the uses specified in section 2.
3.2 All
members of the MMHA have the ability to consent to the use of their personal
information on a yearly basis. A member of the MMHA agrees that the act of
registering constitutes implied consent to such use of their personal
information by the MMHA, its Member Partners, and their Associations and Hockey
Canada.
3.3 The
MMHA may collect personal information without consent where reasonable to do so
and where permitted by law.
4.
Limiting Collection
4.1 The
MMHA and its Member Partners shall only collect personal information in a fair
and lawful manner as set forth in this Privacy Policy.
4.2 The
MMHA 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.
4.3 The
MMHA will not use any form of deception in gaining personal information from
its members.
5.
Limiting Use, Disclosure and Retention
5.1 The
MMHA, shall limit the use of personal information collected to purposes that
are listed in Section 2.2 (Identifying Purposes) and 3.2 (Consent) and will not
disclose the information for other purposes except as authorized or required by
applicable law.
5.2 Prior
to enlisting the services of third party organizations, the MMHA will
contractually commit those parties to treat your personal information in a
manner consistent with this Privacy Policy.
5.3 The
MMHA 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 required
by applicable law.
5.4 The
MMHA may at its discretion release personal information for the purposes of
collecting debts, which may be owed to the MMHA.
5.5 The
MMHA shall retain documents concerning registration, performance activities,
discipline, events and honours and awards received for specific periods of time
dependant upon necessity or destroyed accordingly when it is deemed
appropriate. More specifically:
·
Registration data will be
retained for a three-year period after an individual has left the MMHA programs
in the event that an individual chooses to return to the MMHA programs after
leaving.
·
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 MMHA 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 is 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
MMHA 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
MMHA database. The MMHA 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
MMHA 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 MMHA (as per 2.2) 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 MMHA and its Privacy
Officer(s) to ensure the best methods possible are being utilized to maximize
effectiveness.
8.
Openness
8.1 The
MMHA 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 MMHA Privacy Officer.
8.2 The
information available includes:
·
The name address and phone
number of the MMHA Privacy Officer.
·
The forms (attached) to
access your information or change your information.
·
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 Member Association Privacy
Officer, then directly to the MMHA.
9.
Individual Access
9.1 Upon
request by the individual concerned, subject to applicable legislation, the MMHA
shall disclose whether or not it actually holds personal information on an
individual. The MMHA 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
MMHA may request sufficient information to confirm your identity before
releasing any personal information to you.
9.3 Subject
to applicable legislation, the MMHA shall endeavour to provide this information
within 30 days of receipt of the request for information and only charge
nominal fees for the purpose of satisfying its expenses incurred in the supply
of requested information. This
information shall be in format understandable to you.
9.4 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
MMHA 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 MMHA’s compliance
with this Policy by contacting the MMHA Executive Director or/and Privacy
Officer(s). Upon receipt of a complaint the MMHA shall make available the
complaint procedures, which will be simple and easy to access.
10.3 The
MMHA shall investigate all complaints received. If the complaint is deemed
justified, the MMHA 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 MMHA Privacy Officer. MMHA policies and
procedures must be adhered to in order to have the challenge dealt with in an
appropriate and timely fashion.
11.
Contacting Us
11.1 If you have any questions about this
privacy policy, please contact the MMHA in writing:
Markham Minor Hockey
Association
Attention: Privacy Officer
P.O. Box
23
Markham,
Ontario
L3P 3J5
