Policy Statement

The Commonwealth Games Association of Canada Inc. (CGC) respects the privacy, and values the trust, of all individuals. CGC recognizes that in order to maintain this trust, CGC must be accountable in how it collects, uses and protects the personal information of its members, Canadian athletes, officials, volunteers, staff, and individuals with which it comes in contact with, in all its activities.

Purpose

The objective of the CGC Privacy Policy is to promote responsible and transparent management practices of personal information in a manner that is consistent with the provisions of Personal Information Protection and Electronic Documents Act (Canada). The Policy is to inform individuals about CGC’s ongoing commitment to ensure that the Personal Information obtained during the course of activities remains accurate, confidential, and the use of any information will be in accordance with this Policy.

Scope

This Privacy Policy (The Policy) describes the policies and practices of CGC with respect to the collection, use and disclosure of personal information. The Policy may be updated from time to time to reflect developments in practices, new technology or the law. Updates will be approved by the CGC Board of Directors.

This Privacy Policy does not impose any limits on the collection, use or disclosure of personal information that:

• Is covered by one of the exceptions in Sections 12, 15 and 18 of PIPEDA to collection, use and disclosure of personal information without consent;
• Was collected prior to January 1, 2004, where the personal information is used and disclosed in order to fulfill the same reasonable purpose for which it was collected.

This Privacy Policy does not apply to personal information if superseded by:

• the Freedom of Information and Protection of Privacy Act
• the Federal Access to Information Act and Privacy Act

POLICY

For the purposes of this policy, CGC considers Personal Information to be defined as any information that can be used to distinguish, identify or contact a specific individual. This Policy applies to personal information of members, athletes, volunteers, and other individuals who have participated in an event or program sponsored or organized by CGC or have expressed an interest in the Commonwealth Games Movement.
Personal information that the CGC may collect, retain, use and disclose includes but is not limited to: name, date of birth, home or work addresses, contact information, passport information, health and medical information or history, banking or credit card information (card number, type and expiry date), interests of an individual or other information the CGC deems necessary to fulfill its duties.

This Policy does not cover aggregated data from which the identity of an individual cannot be determined. CGC retains the right to use aggregated data in any way that it determines appropriate.

Purposes for Collecting Personal Information

CGC may collect personal information in order to fulfill the following purposes:

a) Provide, administer, and manage CGC programs and services and to maintain associated databases;

b) Comply with the law and regulatory requirements, as part of normal business transactions and record keeping, for said programs and services;

c) Organize the participants attending the Commonwealth Games and other CGC organized or sponsored events;

d) Provide information to participants, clients, contractors, partner organizations, and other third parties about the CGC’s programs and services;

e) Manage the CGC’s relationship and communication with participants, staff and volunteers, sponsors, clients, contractors, partner organizations, and other third parties; and

f) Such other purposes consistent with these purposes.

The Personal Information CGC requests from an individual will depend upon the programs, events and services in which that individual participates or derives benefit from.

Accountability

The CGC is responsible for all personal information under its custody or control, including information that it may transfer to a third party.

The CEO will appoint a primary Privacy Officer and a secondary Privacy Officer for the CGC. The Privacy Officer is directly accountable for CGC's handling of personal information.

CGC is responsible for personal information provided to third parties who provide services to CGC. CGC requires any such third parties to use the personal information only for the purposes for which it is provided to them, and to protect the privacy of the personal information in accordance with privacy laws and in a manner that is consistent with the CGC Privacy Policy.

Information Received From Other Sources

The CGC may receive personal information from others who may have collected information from athletes, participants and volunteers who wish to participate in the Commonwealth Games, Commonwealth Youth Games or other events or programs organised or sponsored by CGC. The CGC may request personal information of individuals who have consented to the sharing of their information. The CGC will handle all information it obtains according to this Policy regardless of the source.

How CGC Collects and Uses Personal Information

CGC will only collect, retain, use or disclose personal information where it is necessary to fulfill the purposes for which it was collected, or for a purpose reasonably related to those purposes.

In order to fulfill the purposes for which the information was collected, CGC may disclose personal information to third parties. To the extent that the CGC may enter into contracts or other arrangements with third parties which involve the transfer of personal information, the CGC will ensure that the third party enters into appropriate covenants with the CGC to provide the same level of protection over the personal information that CGC provides.

The CGC may seek consent for the use and disclosure of personal information after it has been collected, but before it is used or disclosed, for a purpose not previously identified to you.

The CGC does not require you to consent to collection, use or disclosure of personal information beyond what is necessary to provide the product or service, as a condition of supplying products or services to you.

The CGC does not attempt to obtain consent for collecting, using or disclosing personal information by providing false or misleading information regarding the purposes for the collection, use or disclosure of personal information or by using deceptive or misleading practices. The CGC will not sell, rent or lease your personal information to third parties unless they have obtained your explicit consent to do so.

When CGC May Disclose Your Personal Information

The CGC may disclose a participant’s Personal Information only when required to do so in the conduct of its business to:

a) Relevant national/provincial sporting organizations;

b) The Commonwealth Games Federation;

c) Commonwealth Games Associations of other countries;

d) Host Organising Committees;

e) Relevant municipal recreation departments, community service organisations, schools, and educational institutions

f) Government agencies, foundations, sponsors, and other funders of CGC;

g) Collecting agencies, lawyers, and others when collecting a debt to CGC or enforcing an agreement between an individual and CGC;

h) Print and electronic media in connection with promotional materials;

i) Individuals or organizations who assist CGC in informing individuals about the Commonwealth Games, our programs and/or services;

j) Individuals or organizations who are advisers or service providers of CGC;

k) Individuals or organizations involved in maintaining, reviewing and developing CGC’s business systems, procedures, and infrastructure including testing or upgrading our computer systems

Where the CGC discloses Personal Information to organizations that perform services on its behalf, CGC will require those service providers to use such information solely for the purpose of providing services to the CGC/CGCF and to have appropriate safeguards for the protection of that Personal Information.

The CGC may be obliged to disclose information without consent. Such circumstances may include:

a) Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;

b) Where the CGC believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety, or property of an identifiable person or group;

c) Where it is necessary to establish or collect monies owing to the CGC;

d) Where it is necessary to permit the CGC to pursue available remedies or limit any damages that the CGC may sustain; or

e) Where the information is public.

Where obliged or permitted to disclose information without consent, the CGC will not disclose more information than is required.

Consent

The CGC will require personal consent to collect, retain and use personal information. The CGC may seek consent to use and disclose Personal Information after it has been collected in those cases where the CGC wishes to use the information for a purpose not previously identified or for which the individual has not previously consented.

The CGC will obtain signed consent from all individuals for all personal information that it collects.

By providing Personal Information to CGC an individual agrees and consents that CGC may collect, use, and disclose Personal Information in accordance with this Policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time.

Subject to legal and contractual restrictions, any individual may refuse or withdraw consent at any time. Such refusal or withdrawal may restrict the individual’s involvement or participation or may impact the level of services provided by the CGC the individual.

To Decline to Have Personal Information Collected, Used, or Disclosed for Certain Purposes

An individual may decline to have his/her Personal Information collected, used, or disclosed for particular purposes. These purposes may include but are not limited to receiving information regarding programs or services and/or sharing a participant’s information with other organizations.

To choose this option, participants must contact the Privacy Officer of CGC and request to change their consent permissions.

Accuracy

CGC endeavours to ensure that any Personal Information provided and its possession is as accurate, current and complete as necessary for the purpose for which CGC uses that information. If CGC becomes aware that Personal Information is inaccurate, incomplete or out of date, CGC will revise the Personal Information and, if necessary, use its best efforts to inform any third party agencies which CGC provided with inaccurate information in order that those third parties may also correct their records.

Retention

CGC keeps a participant’s Personal Information at the National Office and only as long as it is required for the reasons it was collected. This period may extend beyond the end of a participant’s relationship with the CGC but it will be only for so long as it is necessary.

When the Personal Information is no longer required for CGC purposes, CGC will destroy, delete, erase, or convert it into an anonymous form.

Security

CGC staff, volunteers and designated recipients are required to treat all Personal Information confidentially. CGC will maintain reasonably available safeguards that comply in all material respects with industry standards to guard Personal Information against loss, destruction, or modification.

Protection

CGC endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to disposal or destruction of Personal Information.

CGC further protects Personal Information by restricting access to those individuals that the management of CGC has determined require that information.

Any individual, associated with the CGC which misuses Personal Information, will be considered to have committed a serious offence for which disciplinary action may be taken. This may include but is not limited to termination of employment or termination of any agreement between the CGC and that individual or organization.

Access to Personal Information

CGC permits the reasonable right of access and review of Personal Information held in confidence about an individual by that individual and will endeavour to provide the information within a reasonable time, no later than 30 days following the request. Only those individuals with the legal right to access the information may request the personal information.

In the event the individual wishes the personal information to be changed, the CGC reserves the right to append any alternative text the individual concerned believes to be appropriate and to retain the original information.

CGC reserves the right to decline to provide access to Personal Information where the information requested:

a) Would disclose

(i) Personal Information, including opinions, about another participant or about a deceased participant; or

(ii) trade secrets or other business confidential information that may harm the CGC or the competitive position of a third party;

b) Would interfere with contractual or other negotiations of the CGC or a third party;

c) Is subject to solicitor-client or litigation privilege;

d) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;

e) Does not exist, is not held, or cannot be found by CGC

f) Could reasonably result in

(i) serious harm to the treatment or recovery of the individual concerned;

(ii) serious emotional harm to the participant concerned or another participant; or

(iii) serious bodily harm to another participant;

g) May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or

h) May be withheld or is requested to be withheld under applicable legislation.
Where information will not or cannot be disclosed, the participant making the request will be provided with the reasons for non-disclosure.

Commonwealth Games Canada Website - www.commonwealthgames.ca

CGC web servers routinely track general information about visitors such as IP addresses, time of visit, and pages that are being accessed. This information is used internally, only in aggregate form, to better serve visitors by helping us to:

a) Manage our site;

b) Diagnose any technical problems; and

c) Improve the content of our site.

CGC provides information and services via its website (the “Site”). By using the Site, users agree that information may be collected, used and disclosed in accordance with this Policy.

Cookies

All Websites use temporary cookies to customize the site to an individual's interests and to allow individuals to access the website. A user can set his or her browser not to accept cookies and still access the Site. This may make portions of the Site unavailable or difficult to use. This information is not collected by the CGC.

Non-Personal Information

The CGC Website automatically collects certain non-personal information regarding website users. The Website also collects non-personal data which is used for system administration purposes and to update the Site.

Forms, email, etc.

Individuals may provide CGC with personal information when completing forms or contacting CGC via email. This information is stored in a secure environment. The Individual’s personal information will not be used or disclosed unless permitted by this policy.

Links

The CGC Website may contain links to other third party websites, that are provided for the convenience of users. CGC has no responsibility or liability for or control over those websites or their collection, use and disclosure of personal information.

Children’s Privacy Policy - Website

CGC recognizes the particular need to provide additional privacy protections for children who visit the Site.
CGC approaches the communication on the Internet with respect for, and commitment to protecting, the privacy rights, concern, and respect for the different sensibilities of our child participants.

The CGC may collect Personal Information from children (under 13 years of age) only on a voluntary basis. CGC does not require this information for children to obtain access, to surf or to view the content on the CGC Website. In order to participate in certain programs, such as surveys, polls, and the bulletin board, offered on the CGC Website, children may have to provide the following personal information: first name, last name, and e-mail address. CGC will not collect more information than is necessary to participate in such programs. CGC will only use such information for the purposes of administering each program.

Compliance and Complaints

The CEO of the CGC is responsible to appoint a primary and secondary Privacy Officer. One of these Privacy Officers will promptly review and investigate allegations of violations of this Policy. This review will look at practices and procedures which occurred and determine the appropriate measures to be taken. The Primary Privacy Officer will annually review and assess CGC’s compliance with this policy.

Individuals wishing to contact the Privacy Officer may do so by:

a) Phoning: 613- 244-6868 and asking for one of the Privacy Officers

b) Faxing: 613- 244-6826, Attention: Privacy Officer