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Privacy Policy

Intent

Protecting the privacy and confidentiality of personal information is an important aspect of the way Ortona Gymnastics Club (“OGC”) conducts its business. Collecting, using, and disclosing personal information in an appropriate, responsible, and ethical manner is fundamental to OGC’s daily operations. OGC strives to protect and respect personal information of its customers, employees, business partners, and so on, in accordance with Alberta’s Personal Information Protection Act ("PIPA"), and other applicable laws. Each staff member of OGC must abide by this organization’s procedures and practices when handling personal information.

Guidelines

Applicability

This Privacy Policy informs everyone of OGC’s commitment to privacy and establishes some of the methods by which privacy is ensured. This Privacy Policy applies to all personal information within OGC’s possession and control.

Private Information

Personal information is defined as including any identifying information about an individual or group of individuals, including name, date of birth, address, phone number, e-mail address, marital or family status, social insurance/security number, identifying number, employee file, nationality, gender, health history, financial data, credit card numbers, bank account numbers, assets, debts, liabilities, payment records, opinions, and personal views ("Personal Information").

Consent

Member/Prospective Member/Participant/Athlete

Consent occurs and is obtained when an individual signs a membership application or other form containing Personal Information, thereby authorizing OGC to collect, use, and disclose the individual’s Personal Information for the purposes stated on the form or in the Appropriate Use section of this Privacy Policy.

Employee/Volunteer/Intern/Student

OCG advises that Personal Information will be collected for the purposes of establishing an employment/volunteer relationship and consent is deemed through the employment/volunteer relationship.   Withdrawal or Variation of Consent If any individual wishes to withdraw or vary his/her consent respecting the collection, use, or disclosure of his/her Personal Information, please notify of this in writing to the OGC Privacy Officer. At that point, OGC will note the request and discuss with the individual options going forward.

Where Consent Not Needed

OGC may collect, use, or disclose Personal Information without an individual’s consent under particular circumstances. These situations include, but are not limited to:

Personal Information Purposes

OGC collects and uses Personal Information solely for the purpose of conducting business and developing an understanding of its customers. Personal Information may be collected from a prospective member, member, athlete, participant, employee, coach, referee, manager, fan and volunteer (“Individual”) and used by OGC representatives for purposes that include, but are not limited to, the following:

Policy Statements and Measures

  1. OGC assumes accountability for the Personal Information within its possession and control. OGC has a Privacy Officer, to act as custodian of all privacy matters and compliance with this Privacy Policy, other OGC privacy policies and procedures, and applicable privacy laws. In the absence of a separate appointment, the OGC Board of Directors has appointed the OGC Executive Director to act as the Privacy Officer.
  2. OGC obtains Personal Information directly from the Individual to which the information belongs. Individuals are entitled to know how OGC uses Personal Information and this organization will limit the use of any Personal Information collected only to what is needed for those stated purposes. OGC will obtain consent if Personal Information is to be used for any other purpose, other than in situations where consent is not required as permitted by legislation.
  3. OGC will not sell, distribute, or otherwise disclose Personal Information or contact lists to third parties, although, limited disclosure may be required as part of OGC fulfilling its business duties and day-to-day operations. This may include disclosure to agents, consultants, contractors, suppliers, or business partners of OGC, but only with the understanding that these parties obey and abide by this Privacy Policy, to the extent necessary for fulfilling their own business duties and day-to-day operations.
  4. OGC will retain Personal Information only for the duration it is needed for conducting business. Once Personal Information is no longer required, it will be destroyed in a safe and secure manner. However, some laws may require that certain Personal Information be kept for a specified amount of time, which will govern. For more information, please refer to the OGC Records Retention Policy and Procedure.
  5.  OGC vows to protect Personal Information with the appropriate security measures, physical safeguards, and electronic precautions. OGC maintains Personal Information through a combination of paper and electronic files. Where required by law or disaster recovery/business continuity policies, older records may be stored in a secure location. For more information, please refer to the OGC Records Retention Policy and Procedure, but some safety measures include that:

6. OGC’s Website will include this Privacy Policy and disclose our Personal Information practices. Individuals inputting data into the Website will be notified of: 

7. OGC will make efforts to ensure the accuracy of the Personal Information recorded/collected. However, OGC relies on Individuals to notify OGC in writing if there is a change to their Personal Information.

8. In most instances, OGC will grant Individuals access to their Personal Information upon presentation of a written request and satisfactory identification to the Privacy Officer. Should the OGC deny an Individual’s request for access to his/her Personal Information (i.e. where the information cannot be severed and is protected by legal privilege, the information was collected for an investigation or legal proceeding, where the information could reasonably be expected to threaten the life or security of another individual, or if it would reveal the identity of an Individual who has provided an opinion in confidence and that Individual does not consent to its disclosure), OGC will advise in writing of the reason for such a refusal. The Individual may then challenge the decision through an internal review/grievance process and if still unresolved it may be brought to the attention of the Office of the Information and Privacy Commissioner for Alberta, if necessary.

9. If an Individual finds errors of fact with his/her Personal Information, the OGC should be notified in writing as soon as possible of the request to make the correction(s). OGC will correct, where appropriate, the information as soon as reasonably possible, and if the organization has disclosed the incorrect information to other organizations, the OGC will send a notification containing the corrected information to each organization to which the incorrect information has been disclosed, if it is reasonable to do so. If, despite the request for a correction, OCG decides that no factual error or omission exists, the request will be documented nonetheless.

10. OGC will respond to an Individual seeking to access or correct Personal Information within 45 days from the day that the OGC has received the written request. In certain situations, this time period can be extended by up to 30 days (or longer with the permission of the Information and Privacy Commissioner of Alberta) and the Individual will be notified of the extension and the reason(s) for such.

11. Any questions or concerns regarding this Privacy Policy, any other privacy policy or procedure implemented by OGC, or any other privacy issue can be directed to the Privacy Officer by contacting OGC at 780-492-7300. The Privacy Officer will investigate and respond to any concern regarding the handling of Personal Information by OGC. If the Privacy Officer is unable to resolve the concern, the OGC internal review/grievance process may be utilized. After OGC has issued a decision, a request for review of an OGC decision relating to Personal Information matters may also be made to the Office of the Information and Privacy Commissioner of Alberta, if necessary.

12. In the case of a privacy breach (where there is an unauthorized access to, collection, use, disclosure, retention or destruction of Personal Information) OGC will respond as quickly as possible upon notice. OGC will first use its best efforts to stop the privacy breach from continuing. The Privacy Officer will then conduct an investigation to determine the source and make recommendation(s). The Individual whose Personal Information has been affected, will be contacted and it will also be reported to the Office of the Information and Privacy Commissioner of Alberta. Police may be notified if there is a possible criminal infraction such as theft. Other bodies that may be notified include insurers, professional or other regulatory bodies involved, and credit card companies and/or credit reporting agencies.

13. OGC will, to the best of its ability, train all of its employees in the application of PIPA, this Privacy Policy, and other privacy policies and procedures implemented by OGC.

14. Copies of this Privacy Policy are readily available at OGC and copies can also be provided upon request. A copy of PIPA can also be found through the Alberta Queen’s Printer website at www.qp.alberta.ca.