Purpose of the Policy
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.”
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:
- Training NSGA Executive Committee members and staff about the organization’s policy and procedures on privacy
- Maintaining data on a secured network server
- Response by means of a written report within 30 days of receiving the complaint
- Communicating information to Executive Committee members and staff about the organization’s policies and practices; and
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:
- To determine eligibility for provincial and/or national amateur golf competitions and events
- To process applications for members and provide requested information, products or services
- To understand and assess members ongoing needs and offer products or services to meet those needs
- For billing and accounting services related to our organization
- For member communication, service and administration
- For internal, external and regulatory audit purposes
- To comply with legal and regulatory requirement
- To audit special programs
- 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.
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:
- NSGA Executive Committee nomination form - is an application completed by the nominee and given to the NSGA.
- NSGA Tournament Entry Form - to be completed by each competitor and submitted to the NSGA along with entry fee.
- Various background check forms – these forms are required by law for any person volunteering who may be working with children.
- 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.
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:
- Paper Shredder for hard copy financials and sensitive data
- Direct removal from database records, immediately wipes record from storage
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.
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:
- 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.
- 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.
- All computers containing personal information are secured with passwords.
- All personal information that must be transmitted will be done through sealed and addressed envelopes/boxes using only reputable courier/delivery companies.
- 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.
- Employees who send sensitive personal information via faxes will use the necessary procedure safeguards and ensure the fax has a fax cover sheet.
Nova Scotia Golf Association will make the following information available:
- The name or title, address, and telephone number of the person who is responsible for dealing with complaints or inquiries regarding policies and practices;
- The means of gaining access to personal information held by NSGA;
- A description of the type of personal information held by the NSGA;
- What personal information is made available to related organizations.
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:
- The information is prohibitively costly to provide;
- The information contains references to other individuals;
- The information cannot be disclosed for legal, security, or commercial proprietary reasons; and
- 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.
- Record and date the written complaint when received.
- This complaint will be forwarded to the Executive Director.
- 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.
- The Executive Director/appointed investigator will have access to all files necessary to carry out an objective and impartial investigation.