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Background
Hockey Canada is the sole governing body for amateur hockey in Canada. In
co-operation with thirteen Branch associations, the Canadian Hockey League and Canadian Inter-University
Sport, Hockey Canada operates Hockey Programming across Canada. Hockey Programming means making all
arrangements for amateur hockey leagues, teams and games including choosing and training coaches and
referees, deciding which players may participate at which level, establishing appropriate rules and
regulations for amateur hockey. As part of their Hockey Programming activities, Hockey Canada and its
aforementioned partners also take responsibility for determining if transfer regulations may apply, scouting,
gauging the success of certain programs in order that might improve upon them, facilitating emergency
contact, providing educational opportunities, career opportunities, research and to maintaining regular
electronic updates/contact with participants.
Purpose of this Policy
Hockey Canada has developed this Privacy Policy for implementation beginning January
1, 2004. This Policy describes the way that Hockey Canada collects, uses, retains, safeguards, discloses and
disposes of the personal information of prospective members, members, and others including players, coaches,
referees, managers and volunteers.
This Policy describes the way that Hockey Canada will, subject to applicable legal
requirements, adhere to all relevant federal and provincial legislative privacy requirements. The Policy
follows the 10 Canadian Standards Association (CSA) principles identified in the federal Personal Information
Protection and Electronic Documents Act (PIPEDA). The Policy describes each principle and the method of
implementing each. Hockey Canada will strive to meet or exceed federal and provincial legislative
requirements and will ensure that it remains current with changing technologies and laws. Any and all changes
will immediately be posted to the Hockey Canada web site.
1. Accountability
1.1 Hockey Canada will appoint a staff person (the "Privacy
Officer") whose responsibilities will include those of the implementation and monitoring of the Hockey Canada
Privacy Policy. The Privacy Officer will be responsible for Hockey Canada’s compliance with privacy
principles. This person will also be responsible for responding to access requests in accordance with this
Policy. The Privacy Officer will report to the President and the ultimate responsibility for Privacy issues
will rest with the Hockey Canada Board of Directors. The Privacy Officer may at his/her discretion enlist
assistance from other staff members and/or volunteers within the organization. This will not in any manner
mitigate his/her responsibility for Privacy issues.
1.2 The Privacy Officer’s identity will be fully disclosed and
publicly accessible to Hockey Canada members and the public in general. Hockey Canada’s Privacy Officer is
Glen McCurdie and can be reached at gmccurdie@hockeycanada.ca,
or by phone at 613-562-5677, extension #2314.
1.3 Hockey Canada’s Privacy Officer will ensure that Hockey Canada
manages all personal information in its possession in accordance with this Policy including that which may be
transferred to a third party. Third party organizations who handle information on behalf of Hockey Canada
shall be contractually obligated to adhere to the standards of Hockey Canada.
1.4 Hockey Canada will implement internal policies which will
facilitate adherence to this Privacy Policy including but not limited to the following:
Security measures at all levels designed to protect personal information in our
possession.
• Implementing procedures designed to respond to complaints and/or inquiries.
• Staff training in all facets of information management, including awareness of Hockey Canada’s Privacy
Policy and policies and procedures developed in accordance with the Policy.
2. Identifying Purposes, Type
of Information Collected and Website
2.1 Hockey Canada shall only collect the information reasonably
necessary to conduct Hockey Programming. Access to our Privacy policies and procedures will be readily
available. Similarly, the process by which challenges may be made to Hockey Canada’s compliance and/or
adherence to the legislation in question shall be readily available and transparent. To obtain further
information, contact Hockey Canada’s Privacy Officer. Hockey Canada’s Privacy Officer is Glen McCurdie and
can be reached at gmccurdie@hockeycanada.ca, or by phone at
613-562-5677, extension #2314.
2.2 Hockey Canada collects personal information from prospective
members, members, coaches, referees, managers and volunteers for the purposes of conducting Hockey
Programming. Specifically:
• A player’s name, address and date of birth are collected to determine that the player’s geographical,
division of play and level of play information are consistent with Hockey Canada/Branch regulations.
• Historical information concerning past teams played for is collected in order to determine if any Hockey
Canada transfer regulations may apply.
• Information concerning an individual’s skill level and development and feedback on programs is collected to
measure the success of our programs in order that we may better plan future programs.
• Information as to a player’s parents’ name, address, telephone numbers and email addresses may be collected
in order to facilitate emergency contact information as well as to ensure compliance with Hockey Canada
residency regulations.
• Educational information may be collected in order to ensure all Hockey Canada residency regulations have
been adhered to.
• E-mail addresses may be collected for the purposes of facilitating membership communication related to
upcoming events and programs.
• Information about skill levels, ability, emergency contacts and health to ensure our activities are carried
out in a safe and secure environment.
• Personal information collected for the purposes of hockey registrations may also be used for hockey
specific research purposes including but not necessarily limited to hockey demographic type research.
• Affiliates. Hockey Canada has numerous organizations which offer hockey programs under the auspices of
Hockey Canada. These include the Canadian Hockey League, Canadian Inter-University Sport and provincial and
local Branches, associations, and leagues. Hockey Canada discloses the personal information described in
paragraph 2.2 to all of these organizations in order to facilitate Hockey Programming and ensure compliance
with rules and regulations.
• Potential and actual insurance claims and the subsequent investigation thereof.
• Appeals and regulations challenges as well as information collected to defend Hockey Canada against legal
action brought against Hockey Canada.
2.3 Hockey Canada will endeavour through its member Branches,
associations/leagues to advise potential registration candidates of the purpose for the collection of the
data requested at the time of registration or by reference to our web site at www.hockeycanada.ca. We will
further endeavour to ensure that all collectors of the personal information are familiar with the potential
use of the personal data. All personal data collected by Hockey Canada shall be maintained in either of its
two offices or its four Centres of Excellence offices all of which are listed on our web site.
2.4 Hockey Canada will request individually permission for the use
of any personal data collected which is extraneous to that which has been identified above, unless said usage
is authorized by law.
2.5 Hockey Canada may also use information about an individual who
accesses secure areas of www.hockeycanada.ca. Information you are asked to provide during your use of our web
site may include your name, address, e-mail address, age, sex [and the other types of personal information
listed in paragraph 2.2]. All such personal information will be treated within the same parameters as other
personal information collected by Hockey Canada through other means. It is always your choice to provide
information in certain fields although failure to complete certain sections may inhibit your ability to fully
access all areas of the web site. Our web site also collects non-identifiable information about users such as
the users IP address, the sections of the web site visited and the information downloaded. Hockey Canada may
use this non-identifiable information and disclose it to service providers, for system administration
purposes and to improve the web site.
3. Consent
3.1 Hockey Canada will use the personal information for the uses
specified above in section 2 and in Sections 3.2 and 3.3 below. By consenting to provide your information to
Hockey Canada, you are deemed to consent to our use of the information for the purposes of Hockey Programming
listed in Section 2 of this Privacy Policy and to disclosure of the information to other associated
organizations for the same purpose.
3.2 In addition to using personal information for Hockey
Programming purposes, Hockey Canada may from time to time wish to use member name, address and contact
information for the purposes of providing promotional opportunities, including by providing the information
to Hockey Canada’s branches, leagues and associations and other third parties who Hockey Canada believes
provide services or goods that may be of interest to you. Hockey Canada and any such third parties may
contact you to with promotions [or to provide further hockey specific communications and association/league
Branch information updates]. Hockey Canada will provide an opportunity for the member to consent to these
opportunities during the registration process. If you consent but later wish to opt out of this use of
information later, you may do so by contacting us as described at Section 3.4 below.
3.3 Hockey Canada recognizes that hockey by its nature is a contact
sport and injuries are to a certain extent inherent in the game. We believe medical records, medical history
and medical forms of the individual may be of assistance in an emergency situation and therefore we may
request them. While our members and prospective members are under no obligation whatsoever to supply this
information and may refuse to do so without penalty, Hockey Canada will consider receipt of this information
as consent for its subsequent use in an emergency medical situation.
3.4 If at any time you wish to withdraw your consent to the use of
your information for any purposes, you may do so by contacting the Privacy Officer for Hockey Canada. We will
do our best to accommodate your request in a timely fashion without diminishing the services we provide to
you. We will explain to you the impact of your withdrawal on any services we provide to you.
3.5 Hockey Canada may collect personal information without consent
where reasonable to do so and where permitted by law.
4. Limiting
Collection
4.1 All information shall be collected fairly and lawfully within
the criteria as set forth in our Privacy Policy.
4.2 Hockey Canada shall not indiscriminately collect information.
The amount and type of information we collect shall be limited to that which is required to fullfill our
identified purposes.
4.3 Hockey Canada will not use any form of deception in gaining
personal information from its members.
5. Limiting Use, Disclosure
and Retention
5.1 Subject to applicable legislation, Hockey Canada shall limit
use of personal information it collects to purposes that we have disclosed in Sections 2 (Identifying
Purposes) and 3.2, Consent.
5.2 Hockey Canada shall maintain documents for
certain periods of time dependant upon necessity. More specifically:
• We will normally maintain registration data for a three period after an individual has left our programs in
the event that an individual chooses to return to our programs after leaving.
• Parental/family information will be normally maintained for a similar three year period after a member has
left our programs.
• Affiliates. Hockey Canada has numerous organizations which offer hockey programs under the auspices of
Hockey Canada. As explained above, Hockey Canada may from time to time share information with these Branches,
associations, and leagues in order to facilitate Hockey Programming and ensure compliance with rules and
regulations.
• Hockey Canada may from time to time enlist the services of third party vendors in order to provide hockey
programs, technical and support services. Prior to enlisting the services of these firms we will
contractually commit them to treat your personal information consistent with the Privacy Policy of Hockey
Canada.
• Hockey Canada may at some point be involved in the sale, merger, transfer or reorganization of its
activities. We may disclose personal information to the other party in such a transaction. Hockey Canada will
ensure that we contractually obligate the other party to treat this information in a manner consistent with
our Privacy Policy.
• Hockey Canada may disclose your 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 permitted by applicable law.
• Hockey Canada may at its discretion release personal information for the purposes of collecting debts which
may be owed to Hockey Canada.
5.3 Certain documents may be subject to legislated retention
periods either federally or provincially and these will be respected at all times by Hockey
Canada.
6. Accuracy
6.1 Hockey Canada shall strive to ensure to the extent it can that
the information entrusted to us is maintained in an accurate manner. We shall try to maintain the interests
of the individual and attempt to ensure that decisions are not made for or about an individual based on
personal information that is flawed.
6.2 Hockey Canada shall only update information in the event of a
renewal or registration and/or an update.
7. Safeguards
7.1 Security safeguards have been implemented to ensure your
personal information is protected from theft as well as unauthorized access, disclosure, copying, use or
modification thereof.
7.2 The level of safeguards employed shall be directly related to
the level of sensitivity of the personal information collected. The more sensitive the information, the
higher the level of security employed.
7.3 Methods of protection and safeguards to be employed shall
include but in no way be necessarily 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.
8. Openess
8.1 Hockey Canada publicly discloses the methods by which we handle
your personal information. This information is readily available through our Privacy Policy, on our web site
or upon request by contacting the Hockey Canada Privacy Officer is Glen McCurdie and can be reached at
gmccurdie@hockeycanada.ca, or by phone at 613-562-5677, extension #2314.
8.2 The information available includes:
• The name address and phone number of the Hockey Canada Privacy Officer.
• The forms (attached) which you may use to access your information or change your information.
• A description of the type of personal information held by Hockey Canada and our general uses thereof. This
includes:
• registration information, including name, date of birth, address, past teams played on, medical information
and e-mail addresses
• information used for scouting, potential sponsorship opportunities, donors, alumni and information retained
for the purposes of Hockey Canada business contacts.
• Information that may be made available to related organizations, Branches, associations, leagues and/or
third party service providers, in accordance with the provisions of this Privacy Policy.
9. Individual
Access
9.1 Subject to applicable legislation, upon request by the
individual concerned Hockey Canada shall disclose whether or not it actually holds personal information on an
individual. We shall disclose the source of this information when requested and provide an account of third
parties to whom the information may have been disclosed.
9.2 Hockey Canada may request sufficient information to confirm
your identity before releasing your personal information to you.
9.3 Subject to applicable legislation, Hockey Canada shall
endeavour to provide this information within 30 days of receipt of the information requested and only charge
nominal fees for the purpose of off-setting its expenses incurred in supplying the requested information.
This information shall be provided in an understandable format, at the time you make a request.
9.4 Any inaccurate information that is brought to our attention
shall be corrected by Hockey Canada as quickly as possible and any pertinent third parties shall be apprised
of the corrections in due course.
10. Challenging
Compliance
10.1 Hockey Canada has in place procedures for the resolution of
grievances in the administration of its Privacy Policy.
10.2 Upon receipt of a complaint Hockey Canada shall make available
the complaint procedures which will be simple and easy to access.
10.3 Hockey Canada shall investigate all complaints. If the
complaint is deemed justified Hockey Canada shall take the appropriate steps to ensure that compliance is
achieved and will make changes to its policies to allow for compliance in the future.
10.4 All complaints shall be addressed to the Hockey Canada Privacy
Officer Glen McCurdie who can be reached at gmccurdie@hockeycanada.ca, or by phone at 613-562-5677, extension
#2314.
For more information specifically regarding
Hockey Canada's Privacy and Copyright Policies,
please contact:
Glen McCurdie
Director, Insurance & Member Services
Hockey Canada
by phone at 613-562-5677, extension #2314
gmccurdie@hockeycanada.ca
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