Privacy Policy

Background

Squash Nova Scotia (SNS) fosters and promotes a squash community for players of all abilities from across the province to improve the profile of the sport and its enjoyment by its members.

General

Purpose of the Policy: SNS recognizes the importance of privacy and is committed to protecting personal information that is collected, used, disclosed and retained by our organization. The SNS privacy policy showcases how the personal information is handled and safeguarded.

Squash Nova Scotia has implemented this privacy policy to assure Nova Scotians that their personal information is being protected as governed by the Personal Information Protection and Electronics Documents Act [PIPEDA]. PIPEDA “applies to every organization in respect of personal information that … the organization collects, uses or discloses in the course of commercial activities”. Although Squash Nova Scotia does not engage in commercial activity with its membership/contact lists, Squash Nova Scotia is committed to adopting the principles of PIPEDA to take every measure to protect its members.

Squash Nova Scotia is committed to taking every necessary measure to respect and protect your privacy. This privacy policy describes the responsible manner in which Squash Nova Scotia collects, uses, discloses, safeguards and disposes of personal information. This policy strictly models the principles and is compliant with the provisions of the PIPEDA.

Definitions [as defined in the PIPEDA]

Personal information: information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.

Commercial Activity: any particular transaction, act or conduct or any regular course of conduct that is of a commercial character, including the selling, bartering or leasing of donor, membership or other fundraising lists.”

Principles

1) Accountability:

Squash Nova Scotia has designated its Executive Director as accountable for assuring Squash Nova Scotia’s overall compliance with the principles of the PIPEDA. As the designated Privacy Officer, the Executive Director will be responsible for monitoring the personal information collected, data security, ensuring all staff and volunteers are trained appropriately on privacy issues and responsibilities and handling personal information requests and complaints. However, other individuals within Squash Nova Scotia may be responsible for the day-to-day collection and processing of personal information and may act on behalf of the designated individual.

The Privacy Officer can be contacted at:

Squash Nova Scotia Office, 5516 Spring Garden Road, P.O. Box 3010 Park Lane Centre

Halifax , Nova Scotia , B3J 3G6 Tel: (902) 425-5450 • Fax: (902) 425-5606

Squash Nova Scotia practices and procedures that give effect to the principles, include:

(a) Procedure to protect personal information
(i) Training Squash Nova Scotia employees about the organization’s policy and procedures on privacy,
(ii) Maintaining data in a restricted access database,
(b) Procedure to receive and respond to complaints and inquiries
(i) Privacy Officer will respond by means of a written report within 30 days of receiving the complaint
(c) Training staff and communicating information to staff about the organization’s policies and practices; and
(d) Information explaining Squash Nova Scotia policies and procedures.
(i) Privacy policy made available by hard-copy and/ or e-version
(ii) SquashNS.ca web page link to privacy policy.

2) Identifying Purposes:

Squash Nova Scotia , orally or in writing, will identify why the personal information is being collected at the time or before the information is collected. If personal information has been collected for a purpose not previously identified, the new purpose will be identified to the individual prior to use, unless the new purpose is required by law.

Squash Nova Scotia will only collect that minimal information necessary to satisfy the purposes that have been identified and will not use or disclose the information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Squash Nova Scotia will only retain the personal information for as long as necessary to fulfill the stated purposes.

Reasons Squash Nova Scotia collects personal information:

a) To mail or email out periodic newsletters;
b) Annual promotion of program, service or event, or promotion of new programs, services or events that are created, or solicit sponsorship funding,
c) To audit special programs,
d) To track success of specific programs

Personal information that is no longer required to fulfill the identified purposes will be destroyed. Squash Nova Scotia ‘s guidelines and procedures to govern the destruction of personal information can be found under the Limiting Use, Disclosure, and Retention principle.

3) Consent:

Squash Nova Scotia will request the knowledge and consent of the individual prior to the collection, use, or disclosure of personal information, except where inappropriate. However, in certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Squash Nova Scotia wants to use information for a purpose not previously identified). Squash Nova Scotia will not require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes.
By providing personal information to Squash Nova Scotia, individuals are consenting to the use of the information for the purposes identified in this policy.
An individual may withdraw consent to collection, use or disclosure of personal information, subject to legal or contractual restrictions and reasonable notice [10 business days]. The organization shall inform the individual of the implications of such withdrawal.

Squash Nova Scotia ‘s form of consent may vary, depending upon the circumstances and the type of information. In determining the form of consent to use, Squash Nova Scotia will take into account the sensitivity of the information.

In certain circumstances personal information can be collected, used, or disclosed without the knowledge and/ or consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent.

4) Limiting Collection

Squash Nova Scotia will not collect personal information that is not necessary for the purposes identified by the organization. Squash Nova Scotia will collect information by fair and lawful means and will not collect personal information indiscriminately. Squash Nova Scotia will specify the amount and the type of information collected which will be limited to information that is necessary to fulfill the purposes identified.

5) Limiting Use, Disclosure, and Retention

Squash Nova Scotia will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

No personal information will be sold or shared with third parties or external sources, unless consent has been given.

When personal information is no longer required to fulfill the identified purposes aforementioned, the personal information will be destroyed, erased, or made anonymous. Squash Nova Scotia guidelines and procedures for the destruction of personal information is as follows:
(i) Paper Shredder for hard copy financials and sensitive data
(ii) Direct removal from database records, immediately wipes record from storage

6) Accuracy:

Squash Nova Scotia , to the best of our ability, will use personal information that is accurate, complete, and up-to-date 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 the individual.

7) Safeguards:

Squash Nova Scotia has in place security safeguards appropriate to protect the sensitivity of the information. The security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

Squash Nova Scotia employees and volunteers are governed by policies and procedures in regards to personal information and are adequately aware of the importance of maintaining the confidentiality of personal information. Squash Nova Scotia will use appropriate care in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.

Squash Nova Scotia protects personal information regardless of the format in which it is held. The methods Squash Nova Scotia uses to protect personal information includes the following:

(a) Any personal information identifiable on paper is always under the supervision of a Squash Nova Scotia employee or Executive Member.
(b) All personal information that must be transmitted will be done through sealed and addressed envelopes/boxes using only reputable courier/delivery companies.
(c) All Squash Nova Scotia employees are trained in how to collect, use and disclose of personal information and are familiar with the Squash Nova Scotia Privacy Policy.
(d) Squash Nova Scotia will confirm with third party organizations, prior to allowing access to personal information that Squash Nova Scotia has collected, that they have appropriate privacy procedures established to protect personal information.
(e) Employees who send sensitive personal information via faxes will use the necessary procedure safeguards and ensure the fax has a fax cover sheet.

8) Openness

Squash Nova Scotia will make readily available to individuals specific information about its policies and practices relating to the management of personal information. This specific information can be obtained via the Privacy Officer, our Squash Nova Scotia Website [www.squashns.ca] or this privacy policy.

Squash Nova Scotia will make the following information available:

(a) The name or title, address, and telephone number of the Privacy Officer who is responsible for dealing with complaints or inquiries regarding policies and practices;
(b) The means of gaining access to personal information held by Squash Nova Scotia;
(c) A description of the type of personal information held by Squash Nova Scotia;
(d) A copy of the Squash Nova Scotia Privacy Policy and any other information that explains the organization’s policies, standards, or codes; and
(e) What personal information is made available to related organizations.

9) Individual Access

Upon request, Squash Nova Scotia will inform an individual of the existence, use, and disclosure of his or her personal information and will provide access to that information. Squash Nova Scotia will respond to an individual’s request within a reasonable time. Any individual has the right to challenge the accuracy and completeness of the information and have it amended as appropriate.

In certain situations, Squash Nova Scotia may not be able to provide access to all the personal information it holds about an individual. The reasons for denying access will be provided to the individual upon request. Reasons for denying the individual access to personal information may include:

(a) The 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 reasons; and
(d) The information is subject to solicitor-client or litigation privilege.

When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, Squash Nova Scotia will amend the information as required. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.

10) Challenging Compliance

An individual may file a complaint concerning compliance with this Privacy Policy to the Privacy Officer listed above. Squash Nova Scotia will respond to a complaint via the following procedure:

(a) Record and date the written complaint when received.
(b) This complaint will be forwarded to the Privacy Officer.
(c) The Privacy Officer will attempt to resolve the complaint by investigating the complaint or appointing another investigator within ten business days of the complaint being filed.
(d) The Privacy Officer/appointed investigator will have access to all files necessary to carry out an objective and impartial investigation.
(e) Within 30 days of receipt of the complaint, the Privacy Officer will complete the investigation and notify the complainant of the decision by means of a written report explaining the reasons for the decision. The Privacy Officer will include in the report any changes or corrections to Squash Nova Scotia’s Privacy Policy.