Orienteering Canada is a federally incorporated not-for-profit national sport organization responsible for the administration of the sport of orienteering in Canada. While providing its programs and services, Orienteering Canada may collect Personal Information. This policy has been prepared to inform individuals about Orienteering Canada’s ongoing commitment to ensuring that the Personal Information obtained during the course of the organization’s activities remains accurate and confidential; and states Orienteering Canada’s commitment to collecting, using and disclosing Personal Information responsibly.
WHAT IS PERSONAL INFORMATION?
Orienteering Canada considers "Personal Information" to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g., name, title, business address). This Policy does not cover aggregated data from which the identity of an individual cannot be determined. Orienteering Canada retains the right to use aggregated data in any way that it determines appropriate.
WHY ORIENTEERING CANADA MAY COLLECT PERSONAL INFORMATION
Orienteering Canada may use the Personal Information provided verbally or in writing (including via electronic media) for the following purposes:
- Sending communications in the form of e-news with content related to Orienteering Canada’s programs, events, fundraising, activities, and other pertinent information;
- Managing relationships and communicating with participants, clubs, coaches, officials and provincial/territorial orienteering associations (PTOAs);
- Publishing articles and postings on the Orienteering Canada website, Orienteering Canada social media, displays or posters;
- Award nominations, biographies, and media relations;
- Communication within and between individuals;
- Posting images, likenesses or other identifiable attributes to promote Orienteering Canada;
Registration, Database Entry and Monitoring:
- Registration of programs, events and activities;
- Database entry at the Coaching Association of Canada including level of coaching; certification, coaching qualifications and coach selection;
- Database entry to determine level of officials certification and qualifications;
- Determination of athlete eligibility and age group;
- Athlete registration, outfitting uniforms, and various components of athlete and team selection;
- Technical monitoring, officials training, educational purposes;
- Implementation of anti-doping policies and drug testing;
- Tracking participant information and membership demographics;
Sales, Promotions and Merchandising:
- Purchasing equipment, educational resources and other products;
- Promotion and sale of merchandise;
- Video recording and photography for promotional use, as well as for marketing and advertising by Orienteering Canada;
- Administering competitions and all matters relating to the sport of orienteering;
- Travel arrangements and administration;
- Implementation of Orienteering Canada’s screening program;
- Medical emergency, emergency contacts or reports relating to medical or emergency issues;
- Managing insurance claims and insurance investigations;
- Payroll, honorariums, company insurance and health plans;
- Meeting legal and regulatory requirements; and
- Other activities consistent with these purposes.
The Personal Information Orienteering Canada requests will depend upon which Orienteering Canada services the individual wishes to obtain.
Orienteering Canada only collects, uses and discloses Personal Information for purposes that would be considered reasonable in the circumstances and only as is required for the purpose of providing services or information to participants, clubs, coaches, officials and provincial/territorial associations. Orienteering Canada uses only fair and lawful methods to collect Personal Information. Orienteering Canada’s use of Personal Information is limited to the purposes described in this Policy and Orienteering Canada does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained.
WHEN ORIENTEERING CANADA MAY DISCLOSE PERSONAL INFORMATION
Orienteering Canada may disclose Personal Information to:
- Governmental agency funders of Orienteering Canada;
- Print and electronic media in connection with awards and recognition programs; or
- Individuals or organizations who require the Personal Information for the provision of services to Orienteering Canada.
In the event sensitive Personal Information is provided to Orienteering Canada, we will not disclose such Personal Information unless it is required to provide a participant or partner organization with our services.
Where Orienteering Canada discloses Personal Information to individuals or organizations that perform services on its behalf, we will require those service providers to use such information solely for the purposes of providing services to Orienteering Canada, participants, partner organizations or the person concerned and to have appropriate safeguards for the protection of that Personal Information.
Where Personal Information may be subject to transfer to another organization in contemplation of a merger or reorganization of all or part of Orienteering Canada, we will do this only if the parties have entered into an agreement under which the collection, use and disclosure of information (including any Personal Information) is restricted to those purposes that relate to the transaction, including a determination of whether or not to proceed with the transaction (in which case the Personal Information is only to be used by the parties to carry out and complete the transaction).
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where Orienteering Canada is obliged to disclose information without consent. Such circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency or governmental tribunal with jurisdiction over Orienteering Canada;
- Where Orienteering Canada believes, upon reasonable grounds, that such action is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- Where it is necessary to establish or collect monies owing to Orienteering Canada;
- Where it is necessary to permit Orienteering Canada to pursue available remedies or limit any damages that we may sustain; or
- Where the information is already public.
Where obliged or permitted to disclose information without consent, Orienteering Canada will not disclose more information than is required.
Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where Orienteering Canada wishes to use the information for a purpose not identified in this Policy or not previously identified or for which the individual concerned has not previously consented.
By providing Personal Information to Orienteering Canada, the individual agrees and consents that Orienteering Canada may collect, use and disclose the Personal Information in accordance with this Policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time. In most cases and subject to legal and contractual restrictions, any individual is free to refuse or withdraw their consent at any time upon reasonable, advance notice.
Certain services can only be offered if the individual provides Personal Information to Orienteering Canada. Consequently, if the individual chooses not to provide Orienteering Canada with any required Personal Information, we may not be able to offer the services requested.
Individuals may withdraw consent for Orienteering Canada to use and disclose their consent and/or Personal Information at any time by contacting Orienteering Canada’s Executive Director. Orienteering Canada will inform the individual of the consequences of the withdrawal of consent.
ACCURACY AND RETENTION OF PERSONAL INFORMATION
Orienteering Canada endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, Orienteering Canada will revise the Personal Information and, if necessary, use its best efforts to inform third parties which were provided with inaccurate information so that those third parties may also correct their records.
We keep Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the service and the nature of the information. This period may extend beyond the end of a person’s relationship with Orienteering Canada but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date.
When Personal Information is no longer required for Orienteering Canada’s purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.
PROTECTION OF PERSONAL INFORMATION
Orienteering Canada endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities in order to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.
Orienteering Canada further protects Personal Information by restricting access to it to those employees and individuals that the management of Orienteering Canada has determined need to know that information in order for Orienteering Canada to provide our products or services or information.
If any employee of Orienteering Canada misuses Personal Information, this will be considered as a serious offense for which disciplinary action may be taken, up to and including termination of employment.
If any individual or organization misuses Personal Information – provided for the purpose of providing services to or for Orienteering Canada – this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between Orienteering Canada and that individual or organization.
ACCESS TO PERSONAL INFORMATION
Orienteering Canada permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavor to provide the information in question within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections. Orienteering Canada will provide information from our records in a form that is easy to understand. Orienteering Canada reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes to be appropriate.
Orienteering Canada reserves the right to decline to provide access to Personal Information where the information requested:
- Would disclose Personal Information, including opinions, about another individual or about a deceased individual;
- Is subject to solicitor-client or litigation privilege;
- Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
- Does not exist, is not held, or cannot be found by Orienteering Canada;
- May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or,
- May be withheld or is requested to be withheld under applicable legislation.
When Personal Information will not or cannot be disclosed, the individual making the request will be provided with the reasons for nondisclosure.
Orienteering Canada will not charge any individual for verifying or correcting their Personal Information. However, to the extent permitted by applicable law, there may be a minimal charge imposed if a copy of records is required.
RESOLVING PRIVACY CONCERNS
In the event of questions about:
- access to Personal Information;
- our collection, use, management or disclosure of Personal Information; or,
- this Policy;
please contact Orienteering Canada’s Executive Director by sending an e-mail to firstname.lastname@example.org.
Upon receipt of a concern or issue, Orienteering Canada shall:
- Record the date the concern is received;
- Notify the Executive Director who will serve in a neutral, unbiased capacity to resolve the concern;
- Acknowledge receipt of the complaint by way of written communication and clarify the nature of the concern;
- Appoint an investigator using Organization personnel (including the Executive Director) or an independent investigator, who shall have the skills necessary to conduct a fair and impartial investigation and shall have unfettered access to all relevant file and personnel;
- Upon completion of the investigation, the investigator will submit a written report to Orienteering Canada; and
- Notify the concerned individual regarding the outcome of the investigation and any relevant steps taken to rectify the concern, including any amendments to policies and procedures.
Approved March 2022
REVIEW: Every 4 years or as required.