Background

Football Canada, the national governing body of amateur football in Canada, provides these services to its members and the public:

Football Canada’s mission is, through its members, to initiate, regulate, and manage programs, services, and activities that promote participation and excellence in Canadian Amateur Football.

Purpose of the Privacy Policy

Football Canada recognizes the importance of, and is committed to, maintaining the accuracy, confidentiality, and security of personal information.

Football Canada has, as a result of and following the requirements of the federal Personal Information Protection and Electronic Documents Act (PIPEDA), developed this Privacy Policy for implementation commencing January 1, 2004.

The Personal Information Protection and Electronic Documents Act limits the collection, use, and disclosure of personal information:

An Act to support and promote electronic commerce by protecting personal information that is collected, used or disclosed in certain circumstances, by providing for the use of electronic means to communicate or record information or transactions and by amending the Canada Evidence Act, the Statutory Instruments Act and the Statue Revision Act.

This Privacy Policy describes the manner in which Football Canada shall adhere to all relevant legislative privacy requirements, referencing the 10 Canadian Standards Association (CSA) principles.

Personal Information

Personal information is defined as information about an identifiable individual. Personal information includes that which relates to personal characteristics (e.g., age, gender, home address, phone number, ethic background), health (e.g. health history, health conditions), or activities and views (e.g. religion, politics, opinions or evaluations). Personal information does not include business information (e.g. business address, business phone).

Scope

Football Canada’s Privacy Policy sets out the principles and practices regarding the protection of personal information that is collected, used, or disclosed. Each Provincial and affiliate Association is responsible for adopting a similar policy and adapting it to provincial, regional or local requirements as appropriate.

Principles

ACCOUNTABILITY

Football Canada is responsible for personal information under its control. Furthermore, all Football Canada employees and volunteers who collect, maintain and/or use personal information are responsible for ensuring that the collection, use and disclosure of this information is carried out in accordance with this policy and relevant procedures.

IDENTIFYING PURPOSES

The purpose for which personal information is collected shall be identified by Football Canada at or before the time the information is collected.

1. Football Canada shall only collect information pertinent to its Football Programming and services.
2. Privacy policies and procedures shall be made readily accessible and available.
3. Access to the challenge process regarding compliance and/or adherence to PIPEDA shall be made readily available.

TYPE OF INFORMATION COLLECTED

Football Canada collects personal information from interested parties, typically its members, prospective members, coaches, officials, participants, administrators, volunteers, contractors, and vendors directly for the purposes of conducting Football Programming. This information may be obtained in person, by mail, over the phone/facsimile or electronically through Football Canada’s web site. Individuals provide the necessary information, as requested, based on their personal need. This information may include, but is not limited to:

1. Names, addresses, phone and fax numbers, and email addresses collected for the purposes of facilitating membership communication related to Football Canada’s upcoming events, programs, and activities.
2. Names, addresses, email addresses provided voluntarily by an individual who accesses secure areas of www.footballcanada.com.
3. Information pertaining to athletes:
   • a) Names, addresses, phone and fax numbers, email addresses, dates of birth, and historical information (athlete biography and statistics) of players may be collected to determine eligibility, geographical, division of play (age group), level of play, and transfer information consistent with Football Canada regulations.
   • b) Information concerning an individual’s skill level and development, and feedback on programs may be collected to ensure present and future program success.
   • c) Personal health information including provincial health card numbers, allergies, emergency contact and past medical history for use in the case of medical emergency.
   • d) Body weight, mass and body fat index to monitor physical response to training and to maintain an appropriate weight for competition.
   • e) Athlete information including height, weight, uniform size, shoe size, feedback from coaches and trainers, performance results for athlete registration forms, outfitting uniforms, media relations, and various components of athlete and team selection.
   • f) Athlete whereabouts information including sport/discipline, training times and venues, training camp dates and locations, travel plans, competition schedule, and disability, it applicable, Canadian Centre for Ethics in Sport inquiries for the purposes of out-of-competition drug testing.
   • g) Emergency contact information such as the names, addresses, phone numbers, and email addresses of players’ parents, and information regarding educational information, skill levels, ability, and health may be collected to ensure compliance with Football Canada’s residency regulations are that activities are carried out in a safe and secure environment.

4. The names, addresses, phone and fax numbers, email addresses of officials, coaches, and administrators may be collected to determine geographical, division of participation, and level of certification and coaching qualifications, are consistent with Football Canada regulations.
5. Passport numbers and Aeroplan/frequent flyer numbers for the purposes of arranging travel.
6. Marketing information including attitudinal and demographic data on individual members to determine membership demographic structure and program wants and needs.
7. Personal information collected for the purposes of football registrations may also be utilized for football specific research purposes, including but not necessarily limited to, football demographic research.
8. Performance data, typical of football, may be collected for the purpose of promoting both the individual and contest.
9. Names, addresses, phone and fax numbers, and email addresses for the purpose of providing insurance coverage, managing insurance claims and conducting insurance investigations.
10. Personal information (such as credit card information) that is required to undertake the supply of services or products and payment for said services or products an individual has requested in compliance with the law and regulatory requirements as part of normal business transactions and record keeping.
11. Personal information required to provide, administer, and manage the service, program, or product requested and as needed, and to provide information to third party suppliers (example: Human Kinetics Publishing), integral with Football Canada’s products and services.
12. Banking information, social insurance numbers, criminal records checks, personal reference information, and resumés required to administer Football Canada’s hiring policy and payroll.
13. Appeals and regulations challenges as well as information collected to defend Football Canada against legal action brought against Football Canada.
14. If a purpose has not been identified herein nor consent given for such purpose, Football Canada shall seek consent from individuals. This consent shall be documented as to when and how it was received.

 CONSENT

The knowledge and consent of the individual are required for the collection, use or disclosure of personal information.

Football Canada shall use personal information for only the specified uses. By consenting to provide information to Football Canada, the individual is deemed to consent to the use of the information for the purposes of Football Programming and to disclosure of the information to other associated organizations for the same purpose.

In addition to using personal information for Football Programming purposes, Football Canada may use personal information for the purposes of providing promotional opportunities or football specific communications and association updates. Football Canada shall provide an opportunity for the member to consent to these opportunities during the registration process.
Football Canada believes medical records, medical history and medical forms of the individual may be of assistance in an emergency situation and therefore Football Canada may request them and consider receipt of this information as consent for its subsequent use in an emergency medical situation.
Individuals may decline to have their personal information collected, used, or disclosed for certain purposes. If at any time individuals wish to withdraw consent, they may do so by contacting the Privacy Officer. The Privacy Officer shall explain the impact of withdrawal on any services provided by Football Canada.
Because football by its nature is a contact sport and injuries are to a certain extent inherent in the game, Football Canada reserves the right to refuse participation for the safety and well-being of the individual and public interest should the necessary personal information required not be disclosed.
Football Canada may collect personal information without consent where reasonable to do so and where permitted by law.

LIMITING COLLECTION

The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization.

1. All information shall be collected by fair and lawful means.
2. All documents obtaining personal information shall have a collection, use, and disclosure of personal information statement contained therein, such as:

THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

Football Canada collects, uses, and discloses only such information from individuals as is required for the purpose of providing services or information to them, managing databases, conducting research and such other purposes as described in Football Canada’s Privacy Policy.

Football Canada does not sell, trade, barter, or exchange for consideration any Personal Information obtained. Football Canada’s collection, use and disclosure of personal information shall be done in accordance with its Privacy Policy, a copy of which is available at www.footballcanada.com.

3. Football Canada shall not use any form of deception in gaining personal information from its members.
4. Football Canada shall advise potential registration candidates, through its members or by reference to our web site at www.footballcanada.com, of the purpose for the collection of the data requested at the time of registration.
5. Football Canada shall ensure that all collectors of personal information are familiar with the potential use of the personal data.
6. All personal data collected by Football Canada shall be maintained by Football Canada.
7. Football Canada shall request individual permission for the use of any personal data collected which is extraneous to that which has been identified above unless authorized by law.

LIMITING USE, DISCLOSURE AND RETENTION

Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.

1. Football Canada shall limit the use of personal information collected to only those purposes identified within this Policy, except with the consent of the individual as legally required.
2. Football Canada shall retain personal information in a manner that is consistent with its other statutory and legal requirements. Football Canada shall only retain personal information only as long as is reasonably necessary to meet these requirements.
3. Registration data and athlete information shall be retained for a period of three years after an individual has left a program of Football Canada, in the event that the individual chooses to return to the program.
4. Parental/Family information shall be retained for a period of three years after an individual has left a program of Football Canada, in the event that the individual chooses to return to the program.
5. Information collected by coaches shall be retained for a period of three years after an individual has left a program of Football Canada, in the event that the individual chooses to return to the program.
6. Employee information shall be retained for a period of seven years in accordance with Canada Customs and Revenue Agency Requirements.
7. Personal health information shall be immediately destroyed when an individual chooses to leave a Football Canada program.
8. Information pertaining to infractions shall be retained for a period of four years, in the event that the individual chooses to return to the program.
9. Marketing information shall be immediately destroyed upon compilation and analysis of collected data.
10. Football Canada has numerous affiliates which offer football programs under the auspices of Football Canada. Football Canada may share personal information with these associations and leagues in order to facilitate Football Programming and ensure compliance with rules and regulations.
11. Football Canada may from time to time enlist the services of third party vendors in order to provide football programs, technical and support services. Prior to enlisting the services of these firms, Football Canada shall ensure that treatment of personal information remains consistent with the Privacy Policy of Football Canada.
12. Football Canada may disclose to a government authority that has asserted lawful authority to obtain the information or where Football Canada 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 or otherwise as permitted by applicable law.
13. Football Canada may at some point be involved in the merger, transfer or reorganization of its activities. Football Canada may disclose personal information to the other party in such a transaction. Football Canada shall ensure that treatment of personal information remains consistent with the Privacy Policy of Football Canada.
14. Football Canada may at its discretion release personal information for the purposes of collecting debts which may be owed to Football Canada.
15. Football Canada shall not sell, trade, barter, or exchange for consideration any personal information obtained.
16. Documents shall be destroyed via shredding. Electronic files shall be deleted in their entirety. Football Canada shall also ensure that the hard drive is physically destroyed should any hardware be discarded.

ACCURACY

Personal information shall be accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

1. Football Canada shall make all efforts to ensure that all entrusted personal information is maintained in an accurate manner.
2. Football Canada shall consider the interests of individuals in decision-making, ensuring that decisions are not based on flawed personal information.
3. Football Canada shall update information upon notification.

SAFEGUARDS

Security safeguards appropriate to the sensitivity of the information shall protect personal information.

1. Football Canada’s employees are required to treat all personal information confidentially.
2. Football Canada maintains reasonably available safeguards that comply in all material respects with industry standards to guard personal information against unauthorized access, disclosure, copying, loss, destruction, use, or modification.
3. Methods of protection and safeguards to be employed shall include but in no way be limited to locked files, offices and storage areas, security clearances, and need-to-know access, as well as technological measures such as passwords, encryption, and firewalls.
4. The level of safeguards employed by Football Canada shall be directly related to the level of sensitivity of the personal information collected.
5. The following steps shall be taken to ensure security:
   • a) Paper information is either under supervision or secured in a locked or restricted area.
   • b) Electronic hardware is either under supervision or secured in a locked or restricted area. In addition, passwords are used on computers.
   • c) Paper information is transmitted through sealed, addressed envelopes or in boxes by reputable courier/delivery companies.
   • d) Electronic information is transmitted through a direct line or is encrypted.
   • e) External consultants and agencies with access to personal information shall provide Football Canada with appropriate privacy assurances.

OPENESS

An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

1. Football Canada shall publicly disclose (via web site or upon request by contacting the Privacy Officer) the methods by which Football Canada handles personal information.
2. The information available may include but is not limited to:
   • The name, address, and phone number of the Football Canada Privacy Officer.
   • The required forms to access or change personal information.
   • A description of the type of personal information held by Football Canada and the general uses thereof.

INDIVIDUAL ACCESS

Upon request, individuals shall be informed of the existence, use and disclosure of their personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

1. Subject to applicable legislation and upon reasonable notice in writing, Football Canada shall allow an individual access and review of the personal information held by Football Canada.
2. Football Canada shall provide the requested information in a timely manner and understandable format at either no expense or at nominal expense relating to photocopying and shipping expenses.
3. Football Canada shall disclose the source of the information when requested and provide an account of third parties to whom the information may have been disclosed.
4. Should the individual believe that any personal information is incomplete or incorrect, the individual may advise Football Canada to update the information. The information shall be corrected by Football Canada in a timely manner. If the information is subject to interpretation or is an opinion, Football Canada shall not change the record of information but may annotate the record to indicate the individual’s views. Pertinent third parties shall also be made aware of the corrections.
5. Football Canada may request sufficient information to confirm an individual’s identity before the release of personal information to the individual.
6. Individuals may be denied access to their personal information. Upon refusal, Football Canada shall inform the individual of the reasons for such actions and the associated provisions of PIPEDA. The denial of requests may be based upon:
   • The information being too prohibitively costly to provide
   • The information containing reference to other individuals
   • The information being subject to solicitor-client or litigation privilege
   • Legal, security, or commercial proprietary reasons

CHALLENGING COMPLIANCE

An individual shall address any challenges concerning compliance with these principles and PIPEDA to the Privacy Officer.

1. Football Canada shall have procedures in place to resolve possible grievances.
2. Upon receipt of a challenge, Football Canada shall acknowledge receipt of the complaint, clarify the nature of the complaint, and make the complaint procedures readily available and accessible.
3. The Privacy Officer shall promptly review and investigate all allegations of policy violations and/or complaints. The review shall look at practices and procedures which have occurred and determine the appropriate measures to be taken.
4. The Privacy Officer shall submit a written report to Football Canada within twenty-eight (28) days of receipt of the complaint.
5. The Privacy Officer shall notify the complainant of the investigation outcome and the measures taken to rectify the challenge within thirty (30) days of the original complaint.

PRIVACY ON THE INTERNET

Football Canada respects the privacy of its Internet users and shall protect that privacy as vigorously as possible.

1. Football Canada does not collect information that personally identifies individuals except when individuals provide such information on a voluntary basis.
2. Football Canada shall only collect information that is voluntarily provided by the user and undertakes that such information shall be kept strictly confidential. Individual information provided to Football Canada to gain access to its web site shall not be sold or made available to a third party.
3. Football Canada reserves the right to perform statistical analyses of user behaviour and characteristics in order to measure interest in and use of the web site so as to improve design and navigation. Only aggregated data shall be used for this sole purpose.
4. Users should also be aware that certain non-personal information and data may be automatically collected by Football Canada through the operation of “cookies”. “Cookies” are small text files that identify an individual computer’s browser entering a web site. They allow the site to track that browser’s movement through the site over several sessions. Through cookies, a web site can recognize repeat users, facilitate the user’s access to and use of the site, and allow a site to track usage behaviour that allows content improvements.
5. If individuals do not want a cookie placed on their computer by Football Canada, they may disable cookies altogether by modifying the Preference section of Netscape or Internet Explorer browser.
6. If individuals wish to be informed of the appearance of cookies, they may turn on a warning prompt by modifying the cookie warning section.
7. Individuals should be cognizant that other sites linked to the Football Canada web site may not share the same policies as Football Canada.

PROTECTION OF PERSONAL INFORMATION AT FOOTBALL CANADA

The Football Canada Privacy Coordinator is accountable for Football Canada’s policies and practices, with respect to the management of personal information, and is the individual to whom complaints and inquiries can be forwarded.

 

Football Canada
100-2255 St. Laurent
Ottawa, ON K1G 4K3

Tel: 613-564-0003
Fax: 613-564-6309
Email: communications@footballcanada.com

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