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PRIVACY POLICY

PURPOSE OF THIS POLICY

1. Privacy of personal information is governed by the Personal Information Protection and Electronics Documents Act (“PIPEDA”). This policy describes the way that SOFTBALL CANADA collects, uses, retains, safeguards, discloses and disposes of personal information, and states SOFTBALL CANADA’s commitment to collecting, using and disclosing personal information responsibly. This policy is based on the standards required by PIPEDA, and SOFTBALL CANADA’s interpretation of these responsibilities.  

BACKGROUND

2. Our organization, SOFTBALL CANADA, is the governing body for the sport of Softball in Canada, and is duly recognized by the Government of Canada as the sole National Sport Governing Body.

PERSONAL INFORMATION

3. Personal information is information about an identifiable individual. Personal information may include:

a) Personal characteristics (e.g., gender, date of birth, age, height, weight, body weight, mass and body fat index, uniform size, shoe size, income, ethnic background, family status).
b) Contact information (e.g. address, phone number, cell phone number, fax number, e-mail address).
c) Health information (e.g., health history, health conditions, and health services received by them).
d) Activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).
e) NCCP number, education, resumes, personal reference information and experience.
f)  Credit card and banking information.
g)  Athlete biography, performance results and feedback from coaches and trainers.
h) Member club.
i)  Social insurance number.
j)  Criminal records check.
k) Beneficiaries.
l)  Athlete whereabouts including sport/discipline, training times and venues, training camp dates and locations, travel plans, competition schedule.
m) Marketing information including attitudinal and demographic data.
n)  Passport numbers and Aeroplan/frequent flyer numbers.

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

ACCOUNTABILITY

4. The CEO is the Privacy Officer and is responsible for the monitoring information collection and data security, and ensuring that all staff 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: 223 Colonnade Road, Suite 212, Ottawa Ontario, K2E 7K3.

PURPOSE

5. Personal information will only be collected by SOFTBALL CANADA to meet and maintain the highest standard of organizing and programming the sport of Softball. SOFTBALL CANADA collects personal information from prospective members, members, coaches, umpires, participants, support staff and volunteers for purposes that include, but are not limited to, the following:

i. Receiving communications from SOFTBALL CANADA in regards to E-news, e-mails, bulletins, donation requests, invoices, notifications, merchandise sales, newsletters, programs, events and activities.
ii. Database entry in SOFTBALL CANADA’s National Membership Database.
iii. Database entry at the Coaching Association of Canada to determine level of certification and coaching qualifications. 
iv. Coach selection.
v.  Database entry to determine level of officiating certification and qualifications.
vi. Determination of eligibility, age group and appropriate level of competition.
vii. Promotion and sale of merchandise.
viii. Registration at conferences, travel administration, and purchasing equipment, coaching manuals and other products and resources.  
ix. To determine eligibility, age group and appropriate level of play. 
x. For SOFTBALL CANADA’s payroll, company insurance and health plan.
xi. Implementing SOFTBALL CANADA’s volunteer screening program.
xii. In the case of medical emergency.
xiii. Athlete registration forms, outfitting uniforms, media relations, and various components of athlete and team selection.
xiv. Canadian Centre for Ethics in Sport inquiries for the purposes of out-of-competition drug testing.
xv. To monitor physical response to training and to maintain an appropriate weight for competition. 
xvi. To determine membership demographic structure and program wants and needs.
xvii. The purposes of arranging travel.
xviii. Providing insurance coverage, managing insurance claims, conducting insurance investigations and managing payroll.
xix. Competition registration.
xx. Technical monitoring, coach/club review, officials training, educational purposes, media publications, and sport promotion.
xxi. Publishing articles, media relations and posting on the SOFTBALL CANADA website, displays or posters.
xxii. Posting images, likeness or other identifiable attributes to promote SOFTBALL CANADA on its website, displays or posters. 

6. If a purpose has not been identified herein, SOFTBALL CANADA 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.

CONSENT

7. 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.  SOFTBALL CANADA may collect personal information without consent where reasonable to do so and where permitted by law.

8. By providing personal information to SOFTBALL CANADA, individuals are consenting to the use of the information for the purposes identified in this policy.  

9. SOFTBALL CANADA 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.   

10. 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 SOFTBALL CANADA. The Privacy Officer will advise the individual of the implications of such withdrawal. 

LIMITING COLLECTION

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

LIMITING USE, DISCLOSURE AND RETENTION

12. Personal information will not be used or disclosed by SOFTBALL CANADA 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.

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

i. Registration data and athlete information will be retained indefinitely after an individual has left a program of SOFTBALL CANADA, in the event that the individual chooses to return to the program and for archival purposes;
ii. Parental/family information will be retained  indefinitely after an individual has left a program of SOFTBALL CANADA, in the event that the individual chooses to return to the program;
iii. Information collected by coaches will be retained indefinitely after an individual has left a program of SOFTBALL CANADA, in the event that the individual chooses to return to the program and for archival purposes.
iv. Employee information will be retained for a period of seven years in accordance with Canada Revenue Agency requirements.
v. Personal health information will be immediately destroyed when an individual chooses to leave a program of SOFTBALL CANADA.
vi. Marketing information, related specifically to individuals, will be immediately destroyed upon compilation and analysis of collected information. 
vii. As otherwise may be stipulated in federal or provincial legislation.

14. 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. 

15. SOFTBALL CANADA may disclose personal information to a government authority that has asserted its lawful authority to obtain the information or where SOFTBALL CANADA 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. 

16. Documents will be destroyed by way of shredding or secure destruction and electronic files will be deleted in their entirety. When hardware is discarded, SOFTBALL CANADA will ensure that the hard drive is physically destroyed. 

ACCURACY

17. SOFTBALL CANADA 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.

SAFEGUARDS

18. Personal information is protected by security safeguards appropriate to the sensitivity of the information against loss or theft, unauthorized access, disclosure, copying, use or modification. 

19. Methods of protection and safeguards include, but are not limited to, locked filing cabinets, restricted access to offices, need-to-know access and technological measures including the use of passwords, encryption and firewalls. 

20. The following steps will be taken to ensure security:

i. Paper information is either under supervision or secured in a locked or restricted area.
ii. Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers.
iii. Paper information is transmitted through sealed, addressed envelopes or in boxes by reputable courier/delivery companies.
iv. Electronic information is transmitted either through a direct line or is encrypted.
v. Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this policy.
vi. External consultants and agencies with access to personal information will provide SOFTBALL CANADA with appropriate privacy assurances.

OPENNESS

21. SOFTBALL CANADA will publicize information about its policies and practices relating to the management of personal information. This information is available through this policy on SOFTBALL CANADA’s web site, or upon request by contacting the Privacy Officer. The name, business address, phone, fax and email address of the Privacy Officer will be available to the public.

INDIVIDUAL ACCESS

22. Upon written request, and with assistance from SOFTBALL 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.

23. 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.

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

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

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

26. Upon refusal, SOFTBALL CANADA will inform the individual of the reasons for the refusal and the associated provisions of PIPEDA. 

CHALLENGING COMPLIANCE

27. An individual may challenge SOFTBALL CANADA’s compliance with this policy and PIPEDA, by submitting a challenge in writing.

28. Upon receipt of a written complaint, SOFTBALL CANADA will:

  • Record the date the complaint is received;
  • Notify the Privacy Officer who will serve in a neutral, unbiased capacity to resolve the complaint;
  • Acknowledge receipt of the complaint by way of telephone conversation or registered mail/courier and clarify the nature of the complaint within fourteen days of receipt of the complaint;
  • Appoint an investigator using SOFTBALL CANADA 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 twenty-eight days of receipt of the complaint.
  • Upon completion of the investigation and within 45 days of receipt of the complaint, the investigator will submit a written report to SOFTBALL CANADA.
  • Notify the complainant of the outcome of the investigation and any relevant steps taken to rectify the complaint, including any proposed amendments to policies and procedures, within 60 days of receipt of the complaint.  

29. An individual may appeal a decision made by SOFTBALL CANADA under this Policy, in accordance with SOFTBALL CANADA’s policies for appeals. 

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