Whitby Minor Hockey Association

 Privacy Policy Statement

1.  This privacy policy describes the ways in which the Association collects, uses, retains, safeguards, discloses and disposes of the personal information of all WMHA members and participants to ensure compliance with all relevant federal and provincial legislative privacy requirements. It is based on the 10 principles identified in Schedule 1 to the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and describes the methods of implementing each principle.
2.  The Association will strive to meet or exceed all federal and provincial legislative requirements and will ensure that it remains current with changing technologies and laws.

    

 Principle 1 - Accountability

1.  The Association hereby designates the President as the person who will be accountable to the Board for compliance with this policy. The President will be responsible for the Association's compliance with PIPEDA privacy principles and for responding to access requests, corrections and complaints in accordance with this policy.
2.  The President shall ensure that the Association is accountable for all personal information in its possession including that which may be transferred to a third party. Third party organizations that handle information on behalf of the Association shall be contractually obligated to adhere to the standards of this policy.
3.  The Association shall take all steps necessary to ensure compliance with this policy including security measures designed to protect personal information in its possession and staff training in all facets of information management.

    

 Principle 2 - Identifying Purposes

1.  WMHA hockey programming involves governing its teams and games including training of coaches, trainers and referees, determining players' eligibility for specific divisions and establishing appropriate rules and regulations for competition. The Association shall only collect personal information for the purpose of providing such hockey programming.
2.  The Association collects personal information for the following specific purposes:

    

1.  The Association shall request individual permission to use any personal information for purposes other than those identified in section 7 unless such usage is authorized or required by law.
2.  The Association shall advise registration candidates of the purposes for the collection of their personal information at the time of registration by reference to this policy.
3.  Where practicable, all personal information collected by the Association shall be maintained in the WMHA office.
4.  The Association may require that personal information be provided to gain access to secure areas of the WMHA website. Any information so provided will be treated within the same parameters as other personal information collected by the Association through other means. It will always remain the user's choice to provide information in certain fields.

    

 Principle 3 - Consent

1.  All members of the Association agree that the act of registering constitutes implied consent to the use personal information for the purposes specified in section 7.
2.  While participants are under no obligation whatsoever to supply medical records, medical history or medical forms and may refuse to do so without penalty, the Association will consider receipt of this information as consent for its subsequent use in an emergency medical situation.
3.  If at any time any person wishes to withdraw consent to the use of his or her personal information for any purpose, the person may do so by notifying the President in writing.
4.  In exceptional circumstances, the Association may collect, use and disclose personal information without consent where it is both necessary and reasonable to do so and where permitted by law.

    

 Principle 4 - Limiting Collection

1.  The Association shall only collect personal information by fair and lawful means. The Association shall not indiscriminately collect information. Both the amount and type of information collected shall be limited to that which is required to fulfill the purposes identified in section 7 and such other purposes as are reasonably related to the objectives of the Association.

    

 Principle 5 - Limiting Use, Disclosure and Retention

1.  The Association shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the person to whom the information relates or as required by law.
2.  No personal information shall be supplied to third party service providers or product suppliers without the consent of the person to whom the information relates.
3.  The Association may disclose personal information to a government authority that has asserted its lawful authority to obtain the information or where the Association 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, person, or body with jurisdiction to compel the production of the information or otherwise as authorized or required by law.
4.  If any WMHA team has collected personal information from its players, parents or team officials, it must adhere to the principles set out in this policy. Specifically, no WMHA team may use or disclose personal information supplied to it directly or by the Association for purposes other than those set out in section 7 without the consent of the person to whom the information relates. This includes the disclosure of personal information on any web page.
5.  The Association may release personal information for the purpose of collecting debts that are owed to the Association.
6.  Personal information shall only be retained as long as is necessary to fulfill the purpose identified unless consent is given to keep information for a longer period of time.
7.  Registration data shall be retained for a three-year period after a player has left the Association. Parental/family information shall be maintained for a similar three-year period after a member has left the Association.
8.  Personal information that is no longer required or permitted to be retained by the Association will be destroyed in a secure manner.

    

 Principle 6 - Accuracy

1.  The Association shall strive to ensure, to the extent that it can, that the information entrusted to it is maintained in an accurate manner. All WMHA members and participants will have the ability to view and review personal information retained by the Association. The Association shall attempt to maintain the privacy interests of all individuals and attempt to ensure that decisions are not made for or about an individual based on personal information that may be flawed.
2.  The Association shall only update personal information in its possession if a request is made in writing.

    

 Principle 7 - Safeguards

1.  Security safeguards will be implemented to ensure that all personal information is protected from theft as well as unauthorized use or access, disclosure, copying or modification.
2. All information collected by the Association will be considered highly sensitive. As such, a high level of security will be practiced at all times. Methods of protection and safeguards include but are not limited to locked files, offices and storage areas, security clearances and need to know access as well as technological measures such as passwords and encryption. These measures will be subject to yearly reviews by the Association and the President to ensure the best methods possible are being utilized to maximize effectiveness.

    

 Principle 8 - Openness

1.  Upon request, the Association shall provide a copy of this policy to any WMHA member or participant. The Association shall also make this policy available to all WMHA members and participants on the WMHA website.
2.  If anyone has any questions, comments or concerns regarding this policy, they can contact the President in writing at the office of the WMHA (500 Victoria Street West, Whitby, Ontario L1N 9G4), by calling the WHMA at 905-444-WMHA (9642) or by e-mail at president@whitbyhockey.com. Any forms required by this policy shall be made available on the WMHA website.

    

 Principle 9 - Individual Access

1.  Upon request, the Association shall provide access to personal information in its possession to the individual to whom the information relates or to the parent/guardian of such individual. The Association shall disclose the source of the information when requested and provide an account of any third parties to whom the information may have been disclosed. The Association shall endeavour to provide such information within 30 days of receipt of the request and only charge nominal fees for the purpose of satisfying its expenses incurred in supplying such information.
2.  The Association may request sufficient information to confirm an individual's identity before releasing any personal information.
3.  A WMHA member or participant may challenge the accuracy or completeness of the information and any inaccurate information shall be corrected and any third parties shall be notified of the corrections.

    

 Principle 10 - Challenging Compliance

1.  Anyone wishing to challenge the Association's compliance with this policy can contact the President or any Board member.
2.  The Executive Committee shall investigate all complaints received. If the complaint is deemed justified, the Association shall take the appropriate steps to ensure that compliance is achieved and will make any necessary changes to its policies to allow for compliance in the future.