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NSGA Privacy
Policy
Purpose of the
Policy
Nova Scotia Golf
Association (NSGA) recognizes the importance of privacy and is committed
to protecting personal information that is collected, used, disclosed
and retained by our organization. The NSGA has implemented this privacy
policy to assure our members 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 the NSGA does not engage in commercial activity with its
membership/contact lists, the NSGA is committed to adopting the
principles of PIPEDA to take every measure to protect its members.
The
NSGA is committed to taking every necessary measure to respect and
protect your privacy. This privacy policy describes the responsible
manner in which the NSGA 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
Accountability:
The Nova Scotia Golf
Association has designated our Executive Director accountable for
assuring the NSGA’s overall compliance with the principles of the PIPEDA.
The Executive Director will be responsible for monitoring the personal
information collected, data security, ensuring all Executive Committee
members and staff are trained appropriately on privacy issues and
responsibilities and handling personal information requests and
complaints. However, other individuals within the NSGA may be
responsible for the day-to-day collection and processing of personal
information and may act on behalf of the designated individual(s).
The NSGA practices and
procedures that give effect to the principles, include:
o
Training NSGA Executive Committee
members and staff about the organization’s policy and procedures on
privacy
o
Maintaining data on a secured network
server
o
Response by means of a written report
within 30 days of receiving the complaint
o
Communicating information to Executive
Committee members and staff about the organization’s policies and
practices; and
o
Privacy policy made available by
hard-copy and/ or e-version.
Identifying Purposes
Nova Scotia Golf
Association 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.
Nova Scotia Golf
Association 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. Nova Scotia Golf Association will only retain the personal
information for as long as necessary to fulfill the stated purposes.
Reasons the NSGA
collects personal information:
o
To determine eligibility for provincial
and/or national amateur golf competitions and events
o
To process applications for members and
provide requested information, products or services
o
To understand and assess members
ongoing needs and offer products or services to meet those needs
o
For billing and accounting services
related to our organization
o
For member communication, service and
administration
o
For internal, external and regulatory
audit purposes
o
To comply with legal and regulatory
requirement
o
To audit special programs
o
Personal information that is no longer
required to fulfill the identified purposes will be destroyed. The
NSGA’s guidelines and procedures to govern the destruction of personal
information can be found under the Limiting Use, Disclosure, and
Retention principle.
Consent
Nova Scotia Golf
Association 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 the NSGA wants to
use information for a purpose not previously identified). The NSGA will
not require an individual to consent to the collection, use, or
disclosure of information beyond that required to fulfil the explicitly
specified and legitimate purposes. By providing personal information to
the Nova Scotia Golf Association, 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.
Nova Scotia Golf
Association’s form of consent may vary, depending upon the circumstances
and the type of information. In determining the form of consent to use,
the NSGA will take into account the sensitivity of the information.
Examples of Consent
Forms:
o
NSGA Executive Committee nomination
form - is an application completed by the nominee and given to the NSGA.
o
NSGA Tournament Entry Form - to be
completed by each competitor and submitted to the NSGA along with entry
fee.
o
Various background check forms – these
forms are required by law for any person volunteering who may be working
with children.
o
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.
Limiting Collection
Nova Scotia Golf
Association will not collect personal information that is not necessary
for the purposes identified by the organization. The NSGA will collect
information by fair and lawful means and will not collect personal
information indiscriminately. The NSGA will specify the amount and the
type of information collected which will be limited to information that
is necessary to fulfill the purposes identified.
Limiting Use,
Disclosure and Retention
Nova Scotia Golf
Association 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. NSGA
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
Accuracy
Nova Scotia Golf
Association 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.
Safeguards
Nova Scotia Golf
Association 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. NSGA Executive
Committee members and staff 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.
The NSGA will use appropriate care in the disposal or destruction of
personal information, to prevent unauthorized parties from gaining
access to the information. The NSGA protects personal information
regardless of the format in which it is held. The methods the NSGA uses
to protect personal information includes the following:
(a) Any personal information
identifiable on paper is always under the supervision of an NSGA
Executive Committee member or staff or is safeguarded in a
protected/restricted area.
(b) All computers containing
personal information are under the supervision of an NSGA Executive
Committee member or staff or are safeguarded in a protected/restricted
area.
(c) All computers containing
personal information are secured with passwords.
(d) All personal information
that must be transmitted will be done through sealed and addressed
envelopes/boxes using only reputable courier/delivery companies.
(e) All NSGA Executive committee
members and staff are trained in how to collect, use and disclose of
personal information and are familiar with the NSGA Privacy Policy.
(f) Nova Scotia Golf Association
will confirm with third party organizations, prior to allowing access to
personal information that the NSGA has collected, that they have
appropriate privacy procedures established to protect personal
information.
(g) Employees who send sensitive
personal information via faxes will use the necessary procedure
safeguards and ensure the fax has a fax cover sheet.
Openness
Nova Scotia Golf
Association 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 the
NSGA Executive Director, our Website
www.nsga.ns.ca or this privacy policy.
Nova Scotia Golf
Association will make the following information available:
(a) The name or title, address,
and telephone number of the person who is responsible for dealing with
complaints or inquiries regarding policies and practices;
(b) The means of gaining access
to personal information held by NSGA;
(c) A description of the type of
personal information held by the NSGA;
(d) A copy of the Nova Scotia
Golf Association 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.
Individual Access
Upon request, the Nova
Scotia Golf Association will inform an individual of the existence, use,
and disclosure of his or her personal information and will provide
access to that information. The NSGA 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, the NSGA 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, the NSGA will amend the information as required. Where
appropriate, the amended information shall be transmitted to third
parties having access to the information in question.
Challenging
Compliance
An individual may file a
complaint concerning compliance with this Privacy Policy to the
Executive Director listed above. Nova Scotia Golf Association 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 Executive Director.
(c) The Executive Director 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 Executive
Director/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 Executive Director will complete the investigation
and notify the complainant of the decision by means of a written report
explaining the reasons for the decision. The Executive Director will
include in the report any changes or corrections to Nova Scotia Golf
Association’s Privacy Policy.
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