Approved by the Board of Directors January 27, 2011
Introduction
This "Privacy Policy" governs personal information collected from and about individuals by the Royal Life Saving Society Canada, Ontario Branch (also referred to as "Lifesaving Society" or "the Society"). It addresses the reasons why such information is collected, how it is used, how it is confidentially protected and outlines individuals' rights with respect to this information. This "Privacy Policy" incorporates the 10 principles for the protection of personal information, as devised by the Personal Information Protection and Electronic Documents Act (PIPEDA).
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. Personal information does not include any business contact information of an employee of an organization.
For the purpose of this policy:
Individual means any person who provides personal information to the Society in the regular course of business.
Member means an individual defined by the Society's Bylaw 1, Article 7-Membership, and includes Honorary Members, Active Members, Award Members and Associate Members.
Volunteer officer means an individual appointed by the Board of Directors, who performs specified duties in the Society's best interest and does not receive payment.
Privacy Promise
The Lifesaving Society respects the individual's right to privacy and is committed to keeping personal information accurate, confidential, secure and private. Except as specifically outlined in this policy, the Society does not disclose any individual's personal information to any third parties.
What personal information we collect and why
The Lifesaving Society collects information required to provide services to members and other individuals. This includes an individual's name, address, phone number, e-mail address, birth date, gender, and payment information. The Lifesaving Society's website may record information such as number of log-ins, IP address, date and time of access.
The personal information collected by the Lifesaving Society directly or through course-providers (e.g., affiliate members) is required for the administration and delivery of the Society's programs and services. The Society does not release personal information to any third party with the exception of Transport Canada as required by law as a Pleasure Craft Operator (PCO) course provider. Personal information is collected for the following purposes:
- to confirm age and award prerequisites for training program and leadership awards.
- to maintain a record of individuals' Lifesaving Society awards and to issue certification cards.
- to establish and maintain a relationship with members and to provide members with ongoing service and communication.
- to meet with legal and regulatory requirements.
- to track website use in order to improve services.
- to understand our members in order to develop services specific to their needs.
- to upload information required by Transport Canada for their PCO cardholders' database.
Consent
When an individual provides personal information, consent has been implied for the Society to deal with the information in a reasonable manner. The individual consents to the Society's collection, use and disclosure of that personal information in accordance with this policy. The Society may seek additional specific authorization or consent from time to time where required by law or in situations where it is necessary or appropriate.
An individual may withdraw consent to the collection, use or disclosure of his or her personal information at any time upon reasonable notice in writing.
Accuracy and retention
Accuracy and integrity of the Society's members' records is of the utmost concern. The Society endeavours to ensure that personal information collected is accurate, complete and maintained for the purpose for which it was collected.
The Society keeps members' personal information indefinitely to ensure:
- members' certification records are maintained.
- inactive members can become re-instated.
- the Society can generate accurate reports.
What we disclose
- The Society does not exchange or disclose personal information with other organizations except where the Society is required to disclose information without consent. In situations where the Society is obligated to disclose information without consent, no more information than is required in the applicable circumstances will be disclosed.
- Personal information provided may be shared among paid personnel and volunteer officers only as required to perform their duties with the Society.
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- The Society discloses an individual's awards earned and the date the award was earned to affiliate members, employers and the government in order to confirm eligibility for employment and prerequisites for Society awards.
- The Society publishes photos and corresponding names of individuals in Society publications and on the website.
How we protect your personal information
The Society takes measures to ensure the privacy, accuracy, security and confidentiality of individual information. The Society strives to maintain adequate physical, procedural and technical security with respect the headquarters and other information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information.
The Society limits personal information access to paid personnel and volunteer officers who require the information to conduct Society activities and to provide services and programs. Under this policy, any misuse of personal information is treated as a serious offence for which disciplinary action may be taken.
Transparency
The Society makes its policy relating to the protection of personal information available on request and on the Society's website.
The Society permits access to, and review of personal information about an individual by the individual concerned. The Society requires sufficient information to confirm the identity of the person making the request before granting access and will strive to provide information within a reasonable time.
The Society may decline access where the required information:
- is not readily retrievable and the burden or cost of providing it would be disproportionate to the nature or value of the information;
- does not exist, is not held, or cannot be found;
- is required not to be disclosed on any legal ground;
- is permitted by law not to be disclosed.
Where information is not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
Challenging compliance
In the event that an individual wishes to voice a complaint regarding the Society's protection of personal information policy or procedures, the Lifesaving Society shall:
- acknowledge the complaint promptly.
- investigate the complaint and contact the individual to clarify if necessary.
- notify the individual of the outcome of the investigation clearly and promptly.
- inform the individual of her or her avenues of recourse.
- take appropriate measures to correct information-handling practices and policies.
How to Contact Us
In the event of any questions about access to personal information; the collection, use, management or disclosure of personal information by or on behalf of the Society; or this policy, individuals can contact the Privacy Officer directly.
Lifesaving Society - Ontario
400 Consumers Road, Toronto, ON M2J 1P8
Tel: 416-490-8844
Fax: 416-490-8766
Individuals may also contact the Office of the Privacy Commissioner at:
The Office of the Privacy Commissioner of Canada
112 Kent Street, Ottawa, ON K1A 1H3
www.priv.gc.ca
1-800-282-1376
Amendment of the Lifesaving Society's Practices and this Policy
This policy is effective as of January 27, 2011. The Society reserves the right to review and revise its privacy practices and this policy without notice. Policy changes will apply to the information collected from the date of the revised policy as well as existing information held.