CUSSL/LUCNS
Privacy Policy
Purpose of this Policy
1. Privacy of personal information is governed by the Personal Information
Protection and Electronic Documents Act (“PIPEDA”). This policy describes
the way that CUSSL/LUCNS collects, uses, retains, safeguards, discloses
and disposes of personal information, and states CUSSL/LUCNS’s commitment
to collecting, using and disclosing personal information responsibly. This
policy is based on the standards required by PIPEDA, and CUSSL/LUCNS’s
interpretation of these responsibilities.
Background
2. Our organization, CUSSL/LUCNS, is the governing body for the sport
of synchronized swimming in Canadian Universities, and provides these services
to members and the public:
“CUSSL/LUCNS is the sport body that oversees synchronized swimming
in Canadian Universities. Our mission is to develop, promote, support and
regulate synchronized swimming through the implementation of an integrated
sports system that is accessible to all Canadian University students by
providing opportunities for enjoyment and the pursuit of individual goals.“
Personal Information
3. Personal information is information about an identifiable individual.
Personal information includes information that relates to their personal
characteristics (e.g. gender, age, income, home address or phone number,
ethnic background, family status), their health (e.g. health history, health
conditions, health services received by them), or their activities and
views (e.g. religion, politics, opinions expressed by an individual, an
opinion or evaluation of an individual). 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. Anne Smeeton 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:
CUSSL/LUCNS 87 Glenridge Avenue
St.Catharines, ON L2R 4X4
Purpose
5. Personal information will only be collected by CUSSL/LUCNS to meet
and maintain the highest standard of organizing and programming the sport
of synchronized swimming. CUSSL/LUCNS collects personal information from
prospective members, coaches, referees, participants, managers and volunteers
for purposes that include, but are not limited to the following:
a. Name, address, phone number, cell phone number, fax number and e-mail
address for the purpose of communicating about CUSSL/LUCNS’s programs,
events and activities.
b. Name, address, phone number, cell phone number, fax number and e-mail
address for the purpose of emergency contacts.
c. NCCP number, education, resumes and experience for database entry
at the Coaching Association of Canada and to determine level of certification
and coaching qualifications.
d. General member numbers, CASSA numbers, NCCP numbers, résumé’s,
length of service/participation, history, details of performance, certifications,
awards won, details of participation, background, and bio information for
the purpose of award nominations, bio’s or published articles.
e. Credit card or chequing information for registration at workshops,
courses, conferences, membership/athlete/club registrations, travel administration
and purchasing equipment, coaching manuals and other products, payment,
services and resources.
f. Date of birth, athlete history, Star/Superstar/Trillium levels,
Birth Certificate, citizenship, CASSA number, and member club to determine
eligibility, age group and appropriate level of play/competition.
g. Club name, age, participant/coach name, NCCP number, general member
number, team listing, events, Star/Tier levels, etc for the ability to
compete in events.
h. Banking information, social insurance number, criminal records check,
resume and beneficiaries for CUSSL/LUCNS’s payroll, company insurance and
health plan.
i. Criminal records check and related personal reference information
for the purpose of implementing CUSSL/LUCNS’s volunteer screening program.
j. Personal health information including provincial health card numbers,
allergies, emergency contact, Doctors notes and past medical history for
use in the case of medical emergency, byes or reports relating to medical
or emergency issues or their reporting.
k. Athlete information including height, weight, uniform size, shoe
size, feedback from coaches and trainers, performance results for athlete
registration forms, outfitting uniforms, media relations and various components
of athlete and team selection.
l. Athlete whereabouts information including sport/discipline, training
times and venues, training camp dates and locations, travel plans, competition
schedule and disability, if applicable, for Canadian Centre for Ethics
in sport inquiries for the purposes of out-of-country drug testing.
m. Body weight, mass and body fat index to monitor physical response
to training and to maintain an appropriate weight for competition.
n. Marketing information including attitudinal and demographic data
on individual members to determine membership demographic structure, and
program wants and needs.
o. Passport numbers and Aeroplan/frequent flyer numbers for the purposes
of arranging travel.
p. Name address, phone number, cell phone number, fax number and e-mail
address for the purpose of providing insurance coverage, managing insurance
claims and conducting insurance investigations.
q. Club contact person information such as club name, web address,
name, phone number and email address for the purpose of relaying and collecting
information. Further, this information is used to direct the public to
such club and provide easy access for club-to-club communication.
r. Video footage at competitions for the purpose of technical monitoring,
coach/club review, officials training, educational purposes, and sport
promotion. In some cases, videos from an event will be available for purchase.
s. Photos for the purpose of educational training, reporting and marketing
of the sport in newsletters, on website, on displays or posters.
t. Scores and ranking of athletes, coaches and clubs for record keeping,
publishing, competing and identifying athletes.
u. Names, ages and signatures for the purpose of participant agreements,
permission where medical treatment is concerned, and collection of waivers.
v. Name and contact information for the purpose of communication within
and between committees, volunteers, Board members, etc.
6. If a purpose has not been identified herein, CUSSL/LUCNS will seek
consent from the 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 of disclosure was not
obtained upon receipt of the information, consent will be obtained prior
to the use or disclosure of that information. CUSSL/LUCNS may collect personal
information without consent where reasonable to do so and where permitted
by law.
8. By providing personal information to CUSSL/LUCNS, individuals are
consenting to the use of the information for the purposes identified in
this policy.
9. The determining the form of consent to use, CUSSL/LUCNS will take
into account the sensitivity of the information.
10. CUSSL/LUCNS 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.
11. 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 of notice of such withdrawal to
CUSSL/LUCNS. The Privacy Officer will advise the individual of the implications
of such withdrawal.
Limiting Collection
12. All personal information will be collected fairly, by lawful means
and for the purposes as specified in this policy. CUSSL/LUCNS will not
use any form of deception to obtain personal information.
Limiting Use, Disclosure and Retention
13. Personal information will not be used or disclosed by CUSSL/LUCNS
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.
14. Information may be forwarded to volunteers in the association (such
as Meet Managers, Scorers, Referees, Officials, Meet volunteers, committee
members, Board of Directors, Coaches, session leaders, etc); other provincial
associations for the purpose of clinics, competitions, etc.; Coaching Association
of Canada; Synchro Canada; ClubLink (database); Coaches Association of
Ontario; Award Organizations; or other parties with whom the association
deals.
15. Information disclosed to a third party with consent from the individual
shall be protected by a third party agreement to limit use and disclosure.
16. Personal information will be retained for certain periods of time
in accordance with the following:
a. Registration data and athlete information will be retained indefinitely
for the sake of historical record, alumni mailing list and/or in the event
that a swimmer requires former numbers if returning to the program;
b. Parental/family information will be retained for a period of three
years after an individual has left a program of CUSSL/LUCNS, in the event
that the individual chooses to return to the program;
c. Registration data and coach information will be retained indefinitely
for the sake of historical record and/or in the event that a swimmer requires
former numbers if returning to the sport.
d. Registration data for courses, clinics, workshops, etc. may be retained
indefinitely after the event for records purposes.
e. Employee information will be retained for a period of seven years
in accordance with Canada Customs and Revenue Agency requirements.
f. Personal health information will be immediately destroyed when an
individual chooses to leave a program of CUSSL/LUCNS.
g. Marketing information will be immediately destroyed upon compilation
and analysis of collected information.
h. As otherwise may be stipulated in federal or provincial legislation.
17. 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.
18. CUSSL/LUCNS may disclose personal information to a government authority
that has asserted its lawful authority to obtain the information or where
CUSSL/LUCNS 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.
19. Documents will be destroyed by way of shredding and electronic
files will be deleted in their entirety.
Accuracy
20. CUSSL/LUCNS 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
21. 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 and firewalls.
22. Association volunteers, coaches, etc. who receive personal information
in order to carry out the work of the organization, will be notified with
regard to safekeeping of such information.
23. Whenever possible, and when appropriate, group email lists will
be sent “blind copy”.
24. The following steps will be taken to ensure security:
a. Paper information is either under supervision or secured in a locked,
restricted or private area.
b. Electronic hardware is either under supervision or secured in a
locked, restricted or private area at all times. Passwords are used on
computers.
c. Paper information is transmitted by sealed, addressed envelopes
or in boxes by reputable courier/delivery companies.
d. Staff are trained to collect, use and disclose personal information
only as necessary to fulfill their duties and in accordance with this policy
e. External consultants and agencies with access to personal information
will provide CUSSL/LUCNS with appropriate privacy assurances.
Openness
25. CUSSL/LUCNS will publicize information about its policies and practices
relating to the management of personal information. This information is
available through this policy, on CUSSL/LUCNS’s web site or by request
by contacting the Privacy Officer.
26. The information available to the public includes:
a. The name or title, address and telephone number of CUSSL/LUCNS’s
Privacy Policy.
b. The forms that may be used to access personal information or change
information.
c. A description of the type of personal information held by CUSSL/LUCNS,
including a general statement of its approved uses.
Individual Access
27. Upon written request, and with assistance from CUSSL/LUCNS, an
individual may be informed of the existence, use and disclosure of his
or her personal information and will be given access to 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.
28. 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 costs relating to photocopying expenses, unless there are
reasonable grounds to extend the time limit.
29. If personal information is inaccurate or incomplete, it will be
amended as required.
30. An individual may be denied access to his or her personal information
if:
a. This information is prohibitively costly to provide;
b. The information contains references to other individuals;’
c. The information cannot be disclosed for legal, security or commercial
proprietary purposes;
d. The information is subject to solicitor-client or litigation privilege.
31. Upon refusal, CUSSL/LUCNS will inform the individual the reasons
for the refusal and the associated provision of PIPEDA.
Challenging Compliance
32. An individual may challenge CUSSL/LUCNS’s compliance with this
policy and PIPEDA, buy submitting a challenge in writing.
33. Upon receipt of a written complaint, CUSSL/LUCNS will:
a. Record the date the complaint is received;
b. Notify the Privacy Officer who will serve in a neutral, unbiased
capacity to resolve the complaint;
c. Acknowledge receipt of the complaint by way of telephone conversation
and clarify the nature of the complaint within three days of receipt of
the complaint;
d. Appoint an investigator using CUSSL/LUCNS Executive or an independent
investigator, who will have unfettered access to all files and personnel,
within ten days of receipt of the complaint.
e. Upon completion of the investigation and within 25 days of receipt
of the complaint, the investigator will submit a written report to CUSSL/LUCNS.
f. Notify the complainant of the outcome of the investigation and any
relevant steps taken to rectify the complaint, including any amendments
to policies and procedures, within 30 days of receipt of the complaint.
34. An individual may appeal a decision made by CUSSL/LUCNS
Approvals and Review
35. This Policy was approved by the Board of Directors of CUSSL/LUCNS
in July 2008 and will be reviewed annually.
IP Address
When the user’s web browser requests a web page from another computer
on the Internet, it automatically gives the computer the address where
it should send the information. This address is called the computers “IP
Address”.
CUSSL/LUCNS does not collect, use or disclose IP addresses.
Cookies
Cookies are small text files that a web browser transfers to and from
your hard drive for record keeping purposes. Cookies make life easier for
you by saving your passwords, purchases and preferences while you’re at
our site. The use of cookies is an Internet standard, and you’ll find cookies
at most major web sites.
The use of cookies is an industry standard and many major browsers
are initially set up to accept them. You can reset your browser to either
refuel to accept all cookies or to notify you when you have received a
cookie. However, if you refuse to accept cookies, you may not be able to
use some of the features available on websites.
CUSSL/LUCNS does not use cookies to identify specific individuals.
Copyright and Legal Disclaimer
This web site is a product of CUSSL/LUCNS. The information on this
website is provided as a resource to those interested in synchronized swimming.
CUSSL/LUCNS disclaims any representation or warranty, express or implied,
concerning the accuracy, completeness or fitness for a particular purpose
of the information. Persons accessing this information assume full responsibility
for the use of the information and understand and agree that Synchro Swim
Ontario is not liable for any claim, loss or damage arising from the use
of this information. Reference to specific products, processes or services
does not constitute or imply recommendation or endorsement by CUSSL/LUCNS.
CUSSL/LUCNS also reserves the right to make changes at any time without
notice.
Links made available through this website may allow you to leave the
CUSSL/LUCNS site. Please be aware that the Internet sites available through
these links are not under the control of CUSSL/LUCNS. Therefore, CUSSL/LUCNS
does not make any representation to you about these sites or the materials
available there. CUSSL/LUCNS is providing these links only as a convenience
to you, and in no way guarantees these links and the material available
there. CUSSL/LUCNS is not responsible for privacy practices employed by
other companies or websites.
Applicable Law
This site is created and controlled by CUSSL/LUCNS in the province
of Ontario. As such, the laws of the province of Ontario will govern these
disclaimers, terms and conditions, without giving effect to any principles
of conflict of laws.