Personal Information Protection Policy

The BC Seniors Games Society and the 55+ BC Games is committed to providing our members, participants and volunteers with a safe and enjoyable sporting experience. As providing this service involves the collection, use and disclosure of some personal information about our members, participants and volunteers, protecting their personal information is one of our highest priorities.

While we have always respected our members, participants and volunteer’s privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our members, participants and volunteers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting members, participants and volunteers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our members, participants and volunteers’ personal information and allowing our members, participants and volunteers to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to BC Seniors Games Society and its subsidiaries, each of the 12 Zone Organizations and the Host Societies for the 55+ BC Games.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of BC Seniors Games Society or the 55+ BC Games.

Definitions

Personal Information –means information about an identifiable individual (for example your name, age, home town, address, phone number, medical information). Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that BC Seniors Games and 55+ BC Games complies with this policy and PIPA.
Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the member, participant or volunteer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect member, participant or volunteer information that is necessary to fulfill the following purposes:

• To verify identity, we will collect name, home address, telephone number, email address, birthdate;
• To identify member, participant or volunteer preferences, we may collect the sport you would like to participate in and your level of proficiency. As a volunteer we will request your preference and previous experience in areas of participation;
• To understand the registration or safety needs of our member, participant or volunteer, we may collect personal information such as previous medical conditions or your level of proficiency at a sport or activity;
• To deliver requested products and services, we will request your name, address, telephone number, email address, clothing sizing or other information to facilitate the delivery of the product or service;
• To enrol the member, participant or volunteer in a program, we will collect name, home address, phone number, email address, personal preferences;
• To send out association membership information, we will request your name, address, telephone number, email address;
• To contact our members, participants or volunteers for fundraising, we will request your name, address, telephone number, email address;
• To ensure a high standard of service to our member, participant or volunteer, we will request your name, address, telephone number, email address or other information that is important to be able to deliver that service;
• To meet regulatory requirements such as but not limited to our Shared Cost Agreement with the Ministry of Tourism, Arts and Culture or our Provincial Sport partners, we may request your name, address, telephone number, email address, age, sport, results of participation in the Games;
• To collect and process payments, we may request your name, address, telephone number, email address;

Policy 2 – Consent

2.1 We will obtain member, participant and volunteer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided by completing the Membership, Participant or Volunteer registration or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the member, participant or volunteer voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a member, participant or volunteer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for email newsletters, the marketing of new services or products, fundraising and the member, participant or volunteer does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), member, participant or volunteer can withhold or withdraw their consent for BC Seniors Games Society or the 55+ BC Games to use their personal information in certain ways. A member, participant or volunteer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the member, participant or volunteer in making the decision.

2.5 We may collect, use or disclose personal information without the member, participant or volunteer’s knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual’s life, health, or personal security;
• When the personal information is available from a public source (e.g., a telephone directory)
• the personal information is collected by observation at a performance, at the 55+ BC Games or a similar event (i) at which the individual voluntarily appears, and (ii) that is open to the public;
• the collection use or disclosure is to determine the individual’s suitability (i) to receive an honour, award or similar benefit, including an honorary degree, scholarship or bursary, or (ii) to be selected for an athletic purpose;
• the collection use or disclosure of results for the purposes of maintaining athletic performance records;
• When the collection use or disclosure is on behalf of another organization without consent of the individual to whom the information relates, if it is to assist that organization to carry out work on behalf of the other organization
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law.

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose member, participant or volunteer personal information where necessary to fulfill the purposes identified at the time of collection:

• To register or enroll our members, participants or volunteers in our programs such as the 55+ BC Games;
• To create schedules of play or participation at the 55+ BC Games or in our programs;
• To report results of the 55+ BC Games or other programs we may offer;
• To ensure sanctioning of events at the 55+ BC Games;
• To conduct member, participant and volunteer surveys in order to enhance the provision of our services;
• To contact our member, participant and volunteers directly about products and services that may be of interest.

3.2 We will not use or disclose member, participant or volunteer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell member, participant or volunteer lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1 If we use member, participant or volunteer personal information to make a decision that directly affects the member, participant or volunteer, we will retain that personal information for at least one year so that the member, participant or volunteer has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain member, participant or volunteer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that member, participant or volunteer personal information is accurate and complete where it may be used to make a decision about the member, participant or volunteer or disclosed to another organization.
5.2 Member, participant or volunteer may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
A request for correction to personal information should be addressed to:

President, BC Seniors Games Society
#203 – 2453 Beacon Avenue
Sidney, British Columbia V8L 1X7
info@55plusbcgames.org.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the members’, participants’ or volunteers’ correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of member, participant or volunteer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that member, participant or volunteer personal information is appropriately protected:
• Volunteers who have access to the personal information must adhere to our Criminal Records Check Policy
• Employees or contractors have access to personal information only as needed;
• Other security measures may include locked file cabinets, restricted access to offices, safety deposit boxes, and for computers: user ids and password-protected electronic files.

6.3 We will use appropriate security measures when destroying member, participant or volunteer’s personal information such as shredding documents, deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Member, Participant or Volunteer Access to Personal Information

7.1 Members, participants or volunteers have a right to access their personal information, subject to limited exceptions.
• solicitor-client privilege,
• disclosure would reveal personal information about another individual,
• health and safety concerns

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

Request can be forwarded to:
President, BC Seniors Games Society
#203 – 2453 Beacon Avenue
Sidney, British Columbia V8L 1X7
info@55plusbcgames.org.

7.3 Upon request, we will also tell member, participant or volunteer how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the member, participant or volunteer of the cost and request further direction from the member, participant or volunteer on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the member, participant or volunteer in writing, providing the reasons for refusal and the recourse available to the member, participant or volunteer.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The BC Seniors Games Society President is responsible for ensuring BC Seniors Games Society’s compliance with this policy and the Personal Information Protection Act.

8.2 Members, participants or volunteers should direct any complaints, concerns or questions regarding BC Seniors Games Society’s compliance in writing to the President. If the President is unable to resolve the concern, the members, participant or volunteer may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for BC Seniors Games Society’s President is:

President, BC Seniors Games Society
#203 – 2453 Beacon Avenue
Sidney, British Columbia V8L 1X7
info@55plusbcgames.org.

Draft created – October 2018
Adopted – November 2018

For more information please contact our Privacy Officer:

Cindy Simpson, President

info@55plusbcgames.org

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